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Form ADV Part 2A - Brochure
ITEM 1 – Cover Page
April 6, 2026
Segall Bryant & Hamill, LLC
10 South Wacker Drive, Suite 3100
Chicago, IL 60606
312-474-1222 / 800-836-4265
www.cisbh.com
This Brochure provides information about the qualifications and business
practices of Segall Bryant & Hamill, LLC, d.b.a. CI Segall Bryant & Hamill
Asset Management (“SBH”). If you have any questions about the contents
of this Brochure, please contact us at 312-474-1222 or 800-836-4265 or
compliance@cisbh.com.
The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state
securities authority.
SBH is registered with the SEC as an investment adviser. Registration of an
investment adviser does not imply any level of skill or training. Additional
information about SBH
the SEC’s website at
is available on
https://adviserinfo.sec.gov/firm/summary/106505.
ITEM 2 – MATERIAL CHANGES
This section provides a Summary of Material Changes (the “Summary”) reflecting any material
changes to this Brochure since our last required “annual update” filing.
In the event of any material changes, the Summary is provided to all clients within 120 days of
our fiscal year-end, and a copy of this complete Brochure is available to you at any time upon
request. Since SBH’s last update was filed on October 10, 2025, SBH notes the following
material changes:
•
•
Item 1 – updated to reflect changes in ownership structure
Item 5 – updated to reflect changes in fee billing rates for certain strategies
ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ................................................................................................................................... 1
ITEM 2 - MATERIAL CHANGES ....................................................................................................................... 2
ITEM 3 - TABLE OF CONTENTS ...................................................................................................................... 3
ITEM 4 - ADVISORY BUSINESS ....................................................................................................................... 4
ITEM 5 - FEES AND COMPENSATION ............................................................................................................ 7
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................. 12
ITEM 7 -TYPES OF CLIENTS .......................................................................................................................... 13
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................................... 14
ITEM 9 - DISCIPLINARY INFORMATION ....................................................................................................... 30
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................... 31
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ..................................................................................................................................................... 32
ITEM 12 - BROKERAGE PRACTICES .............................................................................................................. 33
ITEM 13 - REVIEW OF ACCOUNTS ............................................................................................................... 36
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................... 37
ITEM 15 - CUSTODY ..................................................................................................................................... 37
ITEM 16 - INVESTMENT DISCRETION .......................................................................................................... 38
ITEM 17 - VOTING CLIENT SECURITIES ........................................................................................................ 38
ITEM 18 - FINANCIAL INFORMATION .......................................................................................................... 40
ITEM 4 - ADVISORY BUSINESS
Firm Description
Segall Bryant & Hamill, LLC (“SBH”) is a registered investment adviser based in Chicago, Illinois
with additional offices in Denver, Colorado; Chesterfield, Missouri; Ardmore, Pennsylvania; and
New York, New York. SBH was established in 1994.
SBH is wholly owned by Corient Management LLC, which is wholly owned by Corient Holdings
Inc. Corient Holdings Inc. is an indirect majority owned subsidiary of Mubadala Capital LP,
which is ultimately owned by the Government of Abu Dhabi through various wholly owned
intermediate entities. See SBH ADV Part 1 schedule B for the complete ownership structure.
Investment Advisory Services
SBH provides discretionary and non-discretionary investment management and advisory services
of domestic and international equity, domestic fixed income, alternative investments and custom
solutions to clients which include but are not limited to individuals, corporations, foundations,
endowments, public funds, multi-employer plans through separate accounts, wrap programs,
unified managed programs, U.S. registered investment companies and other commingled
vehicles. SBH also provides sub-advisory services to other registered investment advisers. Our
client base is geographically diverse with investors in the U.S. and several foreign countries.
SBH manages client portfolios utilizing a diverse offering of investment strategies listed below.
For more information on SBH’s strategies, please visit www.cisbh.com.
These strategies are typically implemented through a separately managed account for clients,
although certain strategies listed are also available through, SBH’s proprietary family of mutual
funds - the Segall Bryant & Hamill Funds, collective investment trusts (“CITs”), private funds, an
exchange-traded fund (“ETF”), Corient Registered Alternatives Fund (“CoRA Fund”), a closed-end
management investment company registered under the Investment Company Act of 1940,
separately managed wrap programs (“Wrap Fee Programs"), private investment funds, and
model portfolios. Clients should read the prospectus or offering memoranda for these
investment vehicles before investing.
EQUITY STRATEGIES
FIXED INCOME STRATEGIES
OTHER INVESTMENT
STRATEGIES
Alternative Investments
Small Cap Core
Small Cap Value
Short Term Fixed Income
Short Term Plus Fixed Income
Small Cap Value Select
Small Cap Growth
SMID Cap
All Cap
Select Equity
Intermediate Fixed Income
1-10 Year Managed Municipal
Fixed Income
Enhanced Intermediate
Municipal Fixed Income
Core Fixed Income
Core Plus Fixed Income
Form ADV Part 2A – September 2025
4
EQUITY STRATEGIES
FIXED INCOME STRATEGIES
OTHER INVESTMENT
STRATEGIES
All Cap Core – Thematic
Emerging Markets Small Cap
Emerging Markets
International Small Cap
Global All Cap
Quantitative U.S. Small Cap
Global Small Cap
Current Income Portfolio
Preferred Securities Portfolio
Quality High Yield
Liability-Driven Investing
Tax Advantaged Municipal Fixed
Income
Intermediate Fixed Income
Managed (Taxable Ladder)
Municipal Short Maturity Fixed
Income
International Equity
Registered Investment Companies
SBH provides investment advice to domestic and international open-ended mutual funds and an
ETF. In addition, SBH provides investment advice to the CoRA Fund, the shares of which are not
registered under the Securities Act of 1933 (the “Securities Act”) and will be issued solely in
private placement transactions that do not involve any “public offering” within the meaning of
Section 4(a)(2) of, and/or Regulation D under, the Securities Act. SBH also sub-advises several
other open-end mutual funds (each, a “Fund,” and collectively, the “Funds”).
SBH manages the assets of the Funds in accordance with the Funds’ investment objectives,
policies and restrictions set forth in its registration statements. A portion of the CoRA Fund is
managed by Churchill Asset Management LLC subject to the oversight of SBH and the board of
the CoRA Fund.
The services that SBH provides to the Funds can present conflicts of interest as SBH can be
incentivized to use the Funds based on compensation rather than the client’s needs. To help
manage that conflict of interest, SBH has implemented various controls including maintaining a
Code of Ethics which details SBH’s fiduciary duties, monitoring of portfolio holdings versus client
objectives, along with the controls mentioned above. This document should not be considered
an offering document for the Funds. Please see the respective Fund’s offering materials such as
the Prospectus, Statement of Additional Information, Offering Memoranda, and other reports to
investors for complete disclosures relating to each Fund.
Collective Investment Trusts
SBH provides investment advice to collective investment trusts. The Segall Bryant & Hamill
International Small Cap Trust, Segall Bryant & Hamill Emerging Markets Trust, Segall Bryant &
Hamill Emerging Markets Small Cap Trust, Segall Bryant & Hamill Quality High Yield Trust, Segall
Bryant & Hamill All Cap Trust, Segall Bryant & Hamill Small Cap Core Trust, Segall Bryant & Hamill
Small Cap Growth Trust, Segall Bryant & Hamill SMID Cap Trust, and the Segall Bryant & Hamill
Core Plus Trust (the “SBH Trusts”) are trusts for the collective investment of assets or
participating tax qualified pension and profit-sharing plans and related trusts, and governmental
plans as more fully described in the Declaration of Trust. As bank collective trusts, SBH Trusts are
exempt from registration as an investment company. The SBH Trusts are managed by SEI Trust
Form ADV Part 2A – March 2026
5 5
Company, the trustee, based on the investment advice of SBH, the investment adviser to the
trusts. If these SBH Trusts are held in a client account, the value of the investment in the SBH
Trusts is excluded from the billing value for the purpose of calculating the client’s periodic fee
due SBH.
Private Funds
SBH provides investment advice to several privately offered non-registered investment vehicles:
• Segall Bryant & Hamill Emerging Markets Small Cap Fund, LP
• Segall Bryant & Hamill Emerging Markets Fund, LP; and a related offshore fund
• Segall Bryant & Hamill Private Opportunities Fund, LP; and a related offshore fund (no
longer accepting new investors)
• Segall Bryant & Hamill Private Opportunities Fund 2020, LP; and a related offshore fund
(no longer accepting new investors)
• Segall Bryant & Hamill Private Opportunities Fund III, LP; and a related offshore fund (no
longer accepting new investors)
Segall Bryant & Hamill Emerging Markets Small Cap Fund, LP invests in marketable securities,
primarily common stocks with small market capitalizations tied economically to emerging market
countries. Segall Bryant & Hamill Emerging Markets Fund, LP invests in marketable securities,
primarily common stocks tied economically to emerging market countries. Segall Bryant & Hamill
Emerging Markets Offshore Fund, LTD invests all of its assets, except those assets needed for
cash-management purposes, into Segall Bryant & Hamill Emerging Markets Fund, LP. Segall
Bryant & Hamill Private Opportunities Fund, LP and related offshore fund, and Segall Bryant &
Hamill Private Opportunities Fund 2020, LP and related offshore fund, and Segall Bryant & Hamill
Private Opportunities Fund III, LP, and a related offshore fund seek primarily to invest in non-
traditional asset classes including private equity strategies, private debt strategies, and real asset
strategies.
Wrap Fee Programs
SBH does not sponsor a wrap fee program. SBH does provide investment strategies to accounts
under wrap fee programs sponsored by other firms or “wrap sponsors.” The wrap sponsors
determine the suitability of the investment strategy as well as the suitability of the wrap structure
and fee for each client. They recommend and assist clients in selecting an appropriate SBH
investment strategy, taking into account their financial situation and investment objectives.
SBH’s role is to manage the client’s account according to the strategy selected. In a wrap fee
program, the wrap sponsor provides investment advisory, execution, and custodial services to
clients in return for an all-inclusive—or “wrap”—fee paid to the sponsor. SBH receives a portion
of the wrap fee for managing these strategies. SBH will allow reasonable investment restrictions
if they do not differ materially from a strategy’s investment objectives. Clients who impose
investment restrictions should be aware that the performance of their accounts may differ from
that of the investment strategies not subject to investment restrictions.
Form ADV Part 2A – March 2026
6 6
Unified Managed Account “UMA” Programs (Model Portfolio Provider)
SBH provides investment strategies via model portfolios to other investment advisers. As the
model portfolio provider, SBH designs, monitors, and updates the portfolio. The investment
advisers may then implement the model portfolio for their clients and adjust the model portfolio
as recommended by SBH. Model portfolio providers may grant shared trading authority to SBH
or “dual discretion” over the clients’ assets, whereby SBH has discretion to execute trades on
behalf of the clients.
Separate Managed Account Dual Contract
Under these programs, a third-party adviser has a contract with a client to perform investment
management and possibly custodian services. SBH may establish a contract directly with the
client or contract with the third-party adviser on the client’s behalf. SBH may from time to time
establish other such relationships.
Legal Actions and Class Actions
SBH does not take responsibility for filing class action claims on behalf of its clients. However,
regarding class actions, SBH has retained an outside company to provide an option for clients to
electronically file class action claims. Fees for this service are typically on a contingency basis, as
a percentage of the proceeds received.
Assets Under Management
As of December 31, 2025, our total regulatory assets under management were $22,636,030,345.
($22,621,553,988 discretionary and $14,476,357 non-discretionary). There are $694,619,328 in
Model UMA assets included in assets under advisement (“AUA”).
ITEM 5 - FEES AND COMPENSATION
All fees are subject to negotiation. The extent and nature of the advisory services that SBH
provides will vary depending on the specific arrangements it makes with each client. As a result,
SBH’s fees will differ among its client accounts due to several factors such as the size of the
account, relationships with other accounts, competitive pricing conditions at inception, the
historical or projected nature of trading for the account, and the extent of supplemental client
services provided to the account.
Clients elect to be billed directly for fees or authorize their custodian to directly debit fees from
client accounts.
Under the terms of SBH’s standard form investment advisory agreements, the compensation of
SBH is payable quarterly in advance and fees are calculated on market values following SBH’s
valuation policies and procedures as of the last business day of the quarter. The standard form
agreements do not have fixed termination or renewal dates but do provide for the termination
of SBH’s services to the client by notice from either the client or SBH to the other within 30 days’
Form ADV Part 2A – March 2026
7 7
written notice. If at the time of termination and subject to the required notice period, SBH has
not fully earned a fee amount prepaid by the client, the unearned portion (determined by
proration on a daily basis) is refunded to the client. Accounts initiated or terminated during a
calendar quarter will be charged a pro rata fee.
In addition to the schedules of fees set forth below that apply to new clients, fee schedules with
some clients may differ. From time to time, special requirements of clients will result in advisory
contracts with terms or fee arrangements differing from those set forth in SBH’s standard forms.
There are circumstances under which fees, including performance-based fee arrangements in
compliance with Securities and Exchange Commission Rule 205-3 and applicable state securities
laws and regulations, if any, may be negotiated. The minimum account size noted below may be
waived or reduced when, for example, a new account is expected to grow rapidly in size, a
relationship exists with a current client of SBH, or for other reasons, at the discretion of SBH. SBH
may offer a discount from its standard fee schedules for accounts of persons associated with SBH,
its affiliates, or members of their families.
SBH’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. SBH strives to keep their fees to a minimum. In
addition to SBH’s fees, clients may incur certain charges imposed by custodians, brokers, third-
party investment and other third parties, such as fees charged by managers, custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions. In
circumstances where a client’s account includes mutual funds (not advised by SBH), clients should
be aware that they are paying an investment management fee to the adviser of the mutual fund,
which is disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of
and in addition to SBH’s fee, and SBH does not receive any portion of these commissions, fees,
and costs.
The Brokerage Practices section in Item 12 further describes the factors that SBH considers in
selecting or recommending broker dealers for client transactions and determining the
reasonableness of their compensation (e.g., commissions).
INVESTMENT STYLE
MANAGEMENT FEE*
MIN. SEPARATE
ACCOUNT SIZE
Core Equity
All Cap
$1 Million
Select Equity
$1 Million
Global All Cap
$1 Million
SMID Cap
$1 Million
Small Cap Core
$1 Million
0.55% - First $25 Million
0.45% - Next $25 Million
0.30% - Over $50 Million
0.55% - First $25 Million
0.45% - Next $25 Million
0.30% - Over $50 Million
0.65% - First $50 Million
0.55% - Next $50 Million
0.50% - Over $100 Million
0.70% - First $50 Million
0.60% - Next $50 Million
0.55% - Over $100 Million
0.80% - First $50 Million
0.70% - Next $50 Million
Form ADV Part 2A – March 2026
8 8
INVESTMENT STYLE
MANAGEMENT FEE*
MIN. SEPARATE
ACCOUNT SIZE
0.65% - Over $100 Million
Core Equity Thematic
All Cap - Thematic
$1 Million
0.55% - First $25 Million
0.45% - Next $25 Million
0.30% - Over $50 Million
Growth Equity
Small Cap Growth
$1 Million
0.80% - First $50 Million
0.70% - Next $50 Million
0.65% - Over $100 Million
Quantitative
International Equity
$50 Million
Quantitative U.S. Small Cap
$1 Million
Global Small Cap
$50 Million
International Small Cap
$50 Million
0.65% - First $50 Million
0.55% - Next $50 Million
0.50% - Over $100 Million
0.70% - First $50 Million
0.60% - Next $50 Million
0.55% - Over $100 Million
0.75% - First $50 Million
0.65% - Next $50 Million
0.60% - Over $100 Million
0.80% - First $50 Million
0.70% - Next $50 Million
0.65% - Over $100 Million
Emerging Markets
$50 Million
Emerging Markets Small Cap
$50 Million
0.70% - First $50 Million
0.60% - Next $50 Million
0.55% - Over $100 Million
0.80% - First $50 Million
0.70% - Next $50 Million
0.65% - Over $100 Million
Value Equity
Small Cap Value
$1 Million
Small Cap Value Select
$1 Million
0.80% - First $50 Million
0.70% - Next $50 Million
0.65% - Over $100 Million
0.80% - First $50 Million
0.70% - Next $50 Million
0.65% - Over $100 Million
Fixed Income
Intermediate
$5 Million
$250,000
Intermediate Fixed Income Managed
Account (Taxable Ladder)
Core
$5 Million
Core Plus
$5 Million
Current Income Portfolio
$150,000
Preferred Securities Portfolio
0.25% - First $50 Million
0.20% - Next $50 Million
0.15% - Over $100 Million
0.25% - First $25 Million
0.20% - Next $25 Million
0.15% - Over $50 Million
0.25% - First $50 Million
0.20% - Next $50 Million
0.15% - Over $100 Million
0.30% - First $50 Million
0.25% - Next $50 Million
0.20% - Over $100 Million
0.25% - First $25 Million
0.20% - Next $25 Million
0.15% - Over $50 Million
0.25% - First $25 Million
$200,000
Form ADV Part 2A – March 2026
9 9
INVESTMENT STYLE
MANAGEMENT FEE*
MIN. SEPARATE
ACCOUNT SIZE
0.20% - Next $25 Million
0.15% - Over $50 Million
Quality High Yield
$5 Million
Liability-Driven Investing
$5 Million
Short Term
$5 Million
Short Term Plus
$5 Million
0.50% - First $25 Million
0.45% - Next $25 Million
0.40% - Over $50 Million
0.25% - First $50 Million
0.20% - Next $50 Million
0.15% - Over $100 Million
0.25% - First $50 Million
0.20% - Next $50 Million
0.15% - Over $100 Million
0.25% - First $50 Million
0.20% - Next $50 Million
0.15% - Over $100 Million
$500,000
Municipal – Short Maturity
$250,000
Municipal: 1-10 Years Managed
$250,000
Municipal – Enhanced Intermediate
$500,000
Municipal - Tax Advantaged Fixed Income 0.25% - First $5 Million
0.20% - Over $5 Million
0.25% - First $5 Million
0.20% - Over $5 Million
0.25% - First $5 Million
0.20% - Over $5 Million
0.25% - First $5 Million
0.20% - Over $5 Million
* All fees noted represent institutional strategies unless specifically stated otherwise.
In most cases, each of the foregoing schedules of fees is applied to the fair market value of the
assets under management by SBH, as reasonably determined by SBH, as of the end of each
quarterly period.
If these Funds are held in a client separate account, the value of the investment in the Funds is
excluded from the billing value for the purpose of calculating the client’s periodic fee due SBH.
Wrap Fee Programs
The wrap sponsor contracts with the client to perform investment management and/or custodial
services. Clients pay a single all-inclusive fee quarterly in advance to the wrap sponsor based on
assets under management. From the all-inclusive fee, the sponsor will pay SBH a management
fee. The wrap fee is set forth in the sponsor’s brochure. The fees payable to SBH are negotiable
for these accounts.
Unified Managed Account “UMA” Program (Model Portfolio Provider)
The fees that SBH receives from third parties for providing its model portfolios are subject to
negotiation.
Form ADV Part 2A – March 2026
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Separate Managed Account Dual Contract Programs
In dual contract programs, the end client pays a separate quarterly fee to SBH based on the
market value of the account. The fees payable to SBH are negotiable but will generally not exceed
the amounts set forth for a particular investment strategy above.
Private Funds
As is more fully described in the offering materials for the private funds, SBH receives a
management fee from each of the private funds. The management fee is accrued in arrears on
the same frequency as the private fund’s net asset value calculation, which is either monthly or
quarterly. The standard management fee for the private funds is up to 1.2% per annum. Certain
private funds may also have a performance fee. Certain private funds may have multiple classes
that are offered to investors with different fee schedules. SBH reserves the right to apply a
different management fee and/or performance fee to different investors and to waive any
management fee and/or performance fee in whole or in part at its discretion, including SBH or
affiliate employees and family members.
Certain SBH Private Funds also will pay SBH an incentive fee equal to 10% of all distributions
received by a limited partner in excess of the limited partner’s contribution to such investment.
The incentive fee will remain provisional and unpaid until the calculation is considered final
following a “realization event” as more fully described in the SBH Private Fund offering
documents. SBH may, in its sole discretion, waive all or part of the incentive fee for any of the
limited partners.
When private funds are held in a client account, the value of the investment in private funds is
excluded from the billing value for the purpose of calculating the client’s periodic fee due to SBH.
Mutual Funds and ETF
SBH receives annual fees from the SBH Funds for investment advisory and administration services
provided to the Funds. SBH is paid a monthly management fee on average daily net assets at an
annual rate up to 1.00%. SBH serves as the sub-adviser to mutual funds where it receives a fee
from the adviser for its services. Specific advisory fees and expense-related information can be
found in each Fund’s Prospectus, Statement of Additional Information, Annual Shareholder
Report, Annual Financial Statements and Additional Information, Semi-Annual Shareholder
Report, and Semi-Annual Financial Statements and Additional Information. If these Funds are
held in a client separate account, the value of the investment is excluded from the billing value
for the purpose of calculating the client’s periodic fee due SBH.
Corient Registered Alternatives Fund (“CoRA Fund”)
fund. Management
SBH receives two forms of compensation from CoRA, a standard management fee along with an
incentive fee if certain criteria are met. CoRA pays SBH a management fee of 1.25% per
annum as adviser to the
fees are paid quarterly and calculated
and accrued monthly based on the value of the net assets as of the last day of each month. Both
in CoRA’s offering documents.
the management fee and
incentive fee are described
Form ADV Part 2A – March 2026
11 11
A portion of CoRA’s assets are managed by a third-party sub-adviser. SBH pays a sub-advisory fee
based on a tiered schedule agreed to in the sub-advisory agreement. The sub-adviser also
receives an incentive fee if certain criteria are met. Specific fees and expense-related information
can be found in the CoRA confidential private placement memorandum and financial reports.
Collective Investment Trusts
SBH receives a management fee from SBH Trusts for its investment advisory services. The trustee
of Segall Bryant & Hamill Collective Investment Trust pays SBH a monthly management fee based
on the average daily net assets of up to 1.25%. Specific advisory fees and expense-related
information can be found in the Segall Bryant & Hamill Collective Investment Trust Disclosure
Memorandum. If a SBH Collective Investment Trust Fund is held in a client separate account, the
value of the investment is excluded from the billing value for the purpose of calculating the
client’s periodic fee due SBH.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Performance-Based Fees
In some cases, SBH has entered into performance fee arrangements with qualified clients: such
fees are subject to individualized negotiation with each client. SBH will structure any
performance or incentive fee arrangement subject to Section 205(a)(1) of the Investment
Advisers Act of 1940, as amended, (the “Advisers Act”), in accordance with the available
exemptions thereunder, including the exemption set forth in Rule 205-3. In measuring clients’
assets for the calculation of performance-based fees, SBH shall include realized and unrealized
capital gains and losses. Performance-based fee arrangements create an incentive for SBH to
recommend investments which may be riskier or more speculative than those which would be
recommended under a different fee arrangement. Such fee arrangements also create an
incentive to favor higher fee-paying accounts over other accounts in the allocation of investment
opportunities. SBH has procedures designed and implemented to ensure that all clients are
treated in a fair and equitable manner, and to prevent this conflict from influencing the allocation
of investment opportunities among clients.
Performance-based fees also create an incentive for SBH to overvalue investments that lack a
market quotation. To address this possible conflict, SBH has adopted policies and procedures that
require SBH to “fair value” any investments that do not have a readily available market value.
Certain SBH private funds and the CoRA Fund charge performance/incentive fees. Refer to the
offering materials of each Fund for further information.
Form ADV Part 2A – March 2026
12 12
Side-by-Side Management
In some cases, SBH manages clients in the same or similar strategies. This gives rise to potential
conflicts of interest if the funds and accounts have, among other things, different objectives,
benchmarks, or fees. For example, potential conflicts arise in the following areas:
• The portfolio manager must allocate time and investment ideas across funds and
accounts,
• Funds or accounts orders do not get fully executed,
• Trades get executed for an account that may adversely impact the value of securities held
by a fund,
• Certain accounts or funds receive an allocation of an investment opportunity when other
accounts do not, and/or,
• Trading and securities selected for a particular fund or account can cause differences in
the performance of different accounts or funds that have similar strategies.
SBH has adopted trade allocation policies and procedures and monitors such transactions to help
ensure SBH is not favoring Funds or accounts over each other as well as to help ensure fair and
equitable treatment over time for both the Funds and accounts. During periods of unusual
market conditions, SBH may deviate from its normal trade allocation practices. There can be no
assurance, however, that all conflicts have been addressed in all situations.
ITEM 7 -TYPES OF CLIENTS
SBH provides its investment management services to many types of clients including:
Individuals, including high net worth individuals;
▪
▪ Corporations;
▪ Educational institutions, charitable organizations, religious organizations and healthcare
organizations;
Insurance companies;
▪
▪ Unions and Taft-Hartley plans;
▪ Health and Welfare Plans;
▪ ERISA, pension, profit-sharing plans and other benefit plans or retirement plans;
▪ Trusts, estates, and endowments;
▪ State or local government entities;
▪ Pooled investment vehicles, registered investment companies and other investment
entities.
The minimum conditions for opening or maintaining an account are as follows:
Institutional Relationships: Minimum relationship size based on investment strategy is
noted above.
SMA Wrap Fee Accounts: Minimum $100,000.
Form ADV Part 2A – March 2026
13 13
The minimum account size may, however, be modified by mutual agreement with a client as
determined on a case-by-case basis. The investment objective, strategy or guidelines of the
account, the expectation of future cash inflows into the account for new investment, the present
or expected business relationship with the client, and similar considerations can affect the
minimum initial account size agreed upon.
should
review
the offering documents
For registered investment companies, collective investment trusts, and private fund investments,
for qualifications and minimum
clients
investment/subscription requirements.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Research Process
SBH uses a variety of investment strategies and techniques in managing accounts, both
qualitative and quantitative, with emphasis on the use of proprietary investment research.
Proprietary research involves analysis that is conducted on the business and characteristics of
specific companies and when forming investment decisions. Proprietary research can include
interviews with company management, customers, suppliers and industry analysts, analysis of a
company’s historical financial statements, and creation of financial models of the company or
issuer’s projected financial performance, among other things. SBH makes substantial use of
various quantitative screening techniques through its own proprietary models. The research
professionals at SBH consider environmental, social, and corporate governance (“ESG”) policies
of the issuing entities when forming investment decisions alongside other considerations for each
investment strategy.
With respect to its quantitatively driven portfolios, SBH’s investment philosophy emphasizes a
systematic, diversified and risk-aware process.
Investment Strategies
All Cap
SBH focuses on companies that have strong management, broad resources and a competitive
market position. The strategy seeks long-term capital appreciation.
• Allocates assets opportunistically; not constrained by market capitalization or style
parameters.
Invests in a portfolio of securities (primarily common stocks) across economic sectors.
•
• Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our
proprietary intrinsic valuation.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Utilizes a low turnover approach to active management.
Form ADV Part 2A – March 2026
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Select Equity
SBH focuses on companies that have strong management, broad resources and a competitive
market position. The strategy seeks long-term capital appreciation through a concentrated
portfolio.
•
Invests in 20 highest conviction holdings from the All-Cap strategy, as defined by weight,
determined by our analyst team. The portfolio is rebalanced on a monthly basis to reflect
deviations due to conviction levels or market movements.
• Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our
proprietary intrinsic valuation.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Utilizes a low turnover approach to active management.
All Cap Core – Thematic
SBH’s All Cap Core – Thematic strategy invests primarily in common stock of all investment styles
and market capitalizations. At the heart of our investment philosophy is thorough, independent,
fundamental research. We attempt to identify structural changes, whether they might be
economic, political, social, demographic, or industry-specific, which are translated into long-term
investment themes. The goal of our risk management approach is to seek to reduce the
portfolio’s downside market exposure while allowing for its participation in up-markets.
Small Cap Core Equity
SBH uses in-depth proprietary research to uncover investments that have the potential to offer
consistent returns over the long term and downside protection through market cycles. SBH
believes combining a focus on high or improving return on invested capital (ROIC) with niche
market companies that have defendable competitive advantages and target smaller overall
markets allows companies to compound value over time by generating strong free cash flow,
reinvesting that cash at high rates of return, which results in compounding free cash flow and
can ultimately lead to an increase in equity value.
• Utilizes a core investment approach consisting of companies with a market capitalization
that does not typically exceed those in the Russell 2000® Index.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Leverages our investment process with the goal of identifying catalysts of change for
improved returns while guarding for risk.
SMID Cap Equity
SBH uses in-depth proprietary research to uncover investments that have the potential to offer
consistent returns over the long term and downside protection through market cycles. SBH
believes combining a focus on high or improving return on invested capital (ROIC) with niche
market companies that have defendable competitive advantages and target smaller overall
markets allows companies to compound value over time by generating strong free cash flow,
reinvesting that cash at high rates of return, which results in compounding free cash flow and
can ultimately lead to an increase in equity value.
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• Utilizes a core investment approach consisting of companies with a market capitalization
that does not typically exceed those in the Russell 2500TM Index.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Leverages our investment process with the goal of identifying catalysts of change for
improved returns while guarding for risk.
Small Cap Value
SBH uses in-depth proprietary research to uncover investments that have the potential to offer
consistent returns over the long term and downside protection through market cycles. SBH views
significant improvement in Return on Invested Capital (or ROIC) and its by product, free cash
flow, as the ultimate driver of underlying equity value. SBH looks for companies with
management teams focused on driving improvements in ROIC that also have defendable
competitive advantages and low embedded expectations. This combination leads us to
companies capable of compounding value over time by generating strong free cash flow,
reinvesting that cash at increasing rates of return, which results in increasing equity value.
• Utilizes a fundamental, bottom-up approach designed to identify companies with
improving business models that have the capability to generate significant improvement
in ROIC over the investment horizon.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Leverages our investment process with the goal of identifying catalysts of change for
improved returns while guarding for risk.
Small Cap Value Select
SBH uses in-depth proprietary research to uncover investments that have the potential to offer
consistent returns over the long term and downside protection through market cycles. SBH views
significant improvement in Return on Invested Capital (ROIC) and its byproduct, free cash flow,
as the ultimate driver of underlying equity value. SBH looks for companies with management
teams focused on driving improvements in ROIC that also have defendable competitive
advantages and low embedded expectations. This combination leads us to companies capable of
compounding value over time by generating strong free cash flow and reinvesting that cash at
increasing rates of return, which results in increasing equity value.
•
Invests in 30 to 40 of the highest conviction holdings from the SBH Small Cap Value
strategy.
• Utilizes a fundamental, bottom-up approach designed to identify companies with
improving business models that have the capability to generate significant improvement
in ROIC over the investment horizon.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Leverages our investment process with the goal of identifying catalysts of change for
improved returns while guarding for risk.
Global All Cap
SBH focuses on companies that have strong management, broad resources and a competitive
market position. The strategy seeks long-term capital appreciation.
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• Allocates assets opportunistically; not constrained by market capitalization or style
parameters.
Invests in a portfolio of securities (primarily common stocks) across economic sectors.
•
• Seeks high return on invested capital (ROIC) companies trading at a 20% discount to our
proprietary intrinsic valuation.
• Employ proprietary screens to limit the universe to companies with low embedded
expectations.
• Utilizes a combination of fundamental and quantitative analysis to invest in well-
established companies, both in the U.S. and developed foreign markets.
• Utilizes a low turnover approach to active management.
Small Cap Growth
SBH utilizes a fundamental research process focused on being early in identifying companies that
exhibit fundamentally stable growth prospects. The strategy seeks to achieve long-term capital
appreciation.
• Seeks to invest in companies with fundamentally stable growth prospects that offer a
•
measurable competitive advantage by leading or disrupting industries.
Invests in companies that we believe are attractively valued relative to future growth
opportunities.
• Uses a proprietary quantitative risk screening tool to systematically flag stocks at risk of
underperforming and to reduce behavioral biases.
• SBH believes the sell decision is as important as the buy decision in small cap growth
investing.
International Small Cap
The portfolio is comprised of companies with traditional value characteristics coupled with
positive company momentum factors. SBH utilizes an investment approach that is systematic,
diversified, and risk aware. The strategy seeks long-term capital appreciation.
• Utilize quantitatively driven process with stock selection model based on valuation,
profitability and momentum factors.
• Focus on stocks that meet our valuation criteria but also have positive earnings and price
momentum.
• Utilizes an optimization process that seeks to maximize returns while minimizing risk by
taking calculated risk where alpha can be systematically captured and aiming to avoid
uncompensated risk.
• Displays diversified exposure with geographic and sector neutrality.
Emerging Markets
The portfolio is comprised of companies with traditional value characteristics coupled with
positive company momentum factors. SBH utilizes an investment approach that is systematic,
diversified, and risk aware. The strategy seeks long-term capital appreciation.
• Utilizes a quantitatively driven process with a stock selection model based on valuation,
profitability, and momentum factors.
• Focuses on stocks that meet our valuation criteria but also have positive earnings and
price momentum.
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• Utilizes an optimization process that seeks to maximize returns while minimizing risk by
taking calculated risk where alpha can be systematically captured and aiming to avoid
uncompensated risk.
• Displays diversified exposure with geographic and sector neutrality.
Emerging Markets Small Cap
The portfolio is comprised of companies with traditional value characteristics coupled with
positive company momentum factors. SBH utilizes an investment approach that is systematic,
diversified, and risk aware. The strategy seeks long-term capital appreciation.
• Utilizes a quantitatively driven process with a stock selection model based on valuation,
profitability, and momentum factors.
• Focuses on stocks that meet our valuation criteria but also have positive earnings and
price momentum.
• Utilizes an optimization process that seeks to maximize returns while minimizing risk by
taking calculated risk where alpha can be systematically captured and aiming to avoid
uncompensated risk.
• Displays diversified exposure with geographic and sector neutrality.
International Equity
SBH’s International Equity philosophy utilizes a systematic, objective methodology that focuses
on three main components: quantitative analysis, valuation and intelligent risk taking. The
systemization of SBH’s investment methodology also allows this rigorous investment process to
be applied effectively over broad investment universes, such as the international equity space.
SBH concentrates its focus on where it can be most effective and where the largest payoff is
expected, while correspondingly limiting exposure that could introduce an excessive amount of
risk for the associated return. Strict adherence to its disciplines—including neutrality to region
and sector exposures—aims to give the portfolio attractive risk/return characteristics.
Quantitative U.S. Small Cap
SBH’s Quantitative U.S. Small Cap philosophy utilizes a systematic, objective methodology that
focuses on three main components: quantitative analysis, valuation and intelligent risk taking.
The systemization of SBH’s investment methodology also allows this rigorous investment process
to be applied effectively over broad investment universes, such as the U.S. small cap space. SBH
concentrates its focus on where it can be most effective and where the largest payoff is expected,
while correspondingly limiting exposure that could introduce an excessive amount of risk for the
associated return. Strict adherence to its disciplines—including neutrality to sector industry
group exposures—aims to give the portfolio attractive risk/return characteristics.
Global Small Cap
SBH’s Global Small Cap philosophy utilizes a systematic, objective methodology that focuses on
three main components: quantitative analysis, valuation and intelligent risk taking. The
systemization of SBH’s investment methodology also allows this rigorous investment process to
be applied effectively over broad investment universes, such as the global small cap space. SBH
concentrates its focus on where it can be most effective and where the largest payoff is expected,
while correspondingly limiting exposure that could bring an excessive amount of risk for the
to
to
associated
return.
Strict
adherence
its disciplines—including neutrality
Form ADV Part 2A – March 2026
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to give
the portfolio attractive
risk/return
regional/country/sector exposures—aims
characteristics.
Intermediate Fixed Income
SBH focus is on fundamental analysis and disciplined risk controls rather than market timing, and
our consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy seeks to achieve long-term total rate of return consistent with
preservation of capital.
•
Invests in diversified portfolio of securities with typically less than 10-year average
maturities.
• Focuses on investment grade domestic, U.S. dollar, cash-pay bonds that are registered
with the SEC.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
• Uses bottom-up bond selection and quality focus to create a portfolio that may differ
significantly from peers and the benchmark.
Core Fixed Income
SBH focuses on fundamental analysis and disciplined risk controls rather than market timing, and
the consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy seeks to achieve long-term total rate of return consistent with
preservation of capital.
• Focuses on investment grade domestic, U.S. dollar, cash-pay bonds that are registered
with the SEC.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
• Uses bottom-up bond selection and quality focus to create a portfolio that may differ
•
significantly from peers and the benchmark.
Interest rate risk profile of the underlying index.
Short Term Fixed Income
SBH focuses on fundamental analysis and disciplined risk controls rather than market timing, and
the consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy seeks to achieve long-term total rate of return consistent with
preservation of capital.
Invests in shorter maturity securities (typically less than 3 years).
•
• Focuses on investment grade domestic, U.S. dollar, cash-pay bonds that are registered
with the SEC.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
• Generally overweight corporate bonds.
• Utilizes bottom-up bond selection and quality focus to create a portfolio that may differ
significantly from peers and the benchmark.
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Current Income Portfolio
The Current Income Portfolio (CIP) seeks to benefit investors who desire reliable levels of income
from an investment grade portfolio. CIP seeks to provide a sustainable income stream by
maximizing annual cash flows while preserving capital.
Incorporate a sleeve of investment grade preferred securities
• Construct a diversified, high quality, intermediate corporate bond portfolio
•
• Opportunistically manage the preferred securities as a key element to the portfolio’s
enhanced current income
Preferred Securities Portfolio
An enhanced yield option for use in the context of a fixed income asset allocation for U.S. taxable
and nontaxable investors. The strategy seeks capital preservation, and risk reduction, while also
maintaining high credit quality, liquidity and tax efficiency. The portfolio consists of both $1,000
par-value ‘institutional’ fixed-to-floating rate preferred securities as well as $25 par-value ‘retail’
fixed, and fixed-to-floating, rate preferred securities with the goal of diversifying exposure and
sensitivity to changes in interest rates.
• Screen the universe of preferred securities for what we believe are high quality, liquid
issues with attractive yield spreads for given interest rate sensitivities.
• The portfolio consists of 50% - 75% fixed-to-floating rate preferred securities. We believe
the volatility typically associated with fixed rate instruments should be reduced due to
the potential for these securities to convert to floating rates of interest.
The portfolio is designed to benefit from the tax advantages of ‘qualified income’.
Liability-Driven Investing Fixed Income
SBH focus is on fundamental analysis and disciplined risk controls rather than market timing, and
the consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy is designed for investors seeking fully customized Liability-Driven
Investing solutions tailored to client requirements and constraints.
• Focus on domestic, U.S. dollar cash pay bonds.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
• Focus on bottom-up research and quality to create a portfolio that may differ significantly
from peers and the benchmark.
Core Plus Fixed Income
SBH focus is on fundamental analysis and disciplined risk controls rather than market timing, and
the consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy seeks to achieve long-term total rate of return consistent with
preservation of capital.
• Focuses on domestic, U.S. dollar, cash-pay bonds (not emerging markets, derivatives, or
levered loans).
• Generally overweight corporate bonds while typically carrying limited exposure to high
quality high yield securities.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
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• Uses bottom-up bond selection and quality focus to create a portfolio that may differ
significantly from peers and the benchmark.
Quality High Yield
SBH focus is on fundamental analysis and disciplined risk controls rather than market timing, and
the consistent process seeks to perform well in all periods with an emphasis on downside
protection. The strategy seeks to achieve long-term total rate of return consistent with
preservation of capital.
• Focuses on high-quality high yield investments, which generally leads to an emphasis on
BB rated bonds, while emphasizing downside protection and low volatility.
• Focus on domestic, U.S. dollar cash pay bonds.
• Seeks to take advantage of inefficiencies created by small issue sizes and rating agency
classifications.
• Uses bottom-up bond selection and quality focus to create a portfolio that may differ
significantly from peers and the benchmark.
Municipal Fixed Income
SBH’s Municipal Fixed Income philosophy is investing in sectors and securities that offer relative
value within the context of current pricing and SBH’s top-down forecast. For municipal bond
portfolios, SBH’s emphasis is on segments of the yield curve that offer strong risk/reward
characteristics and capture trading inefficiencies unique to the municipal bond market. Municipal
Fixed Income portfolios can be customized to meet client’s investment objectives.
Corient Private Wealth – Sub Advised Accounts
From time to time, our affiliate, Corient private Wealth LLC, will direct client assets to be
managed by SBH in one of the SBH investment strategies described above or in a combination of
SBH equity and fixed income strategies to create a “balanced” account through a sub-advisory
arrangement. These sub-advisory arrangements may also include different investment strategies
that were in place at the time the client entered into an advisory agreement but are not
investment strategies that are currently offered to new client relationships. Corient and SBH
continue to honor these arrangements for these clients. Some of these investment strategies
include investments in strategies that invest only in third-party exchange traded funds. Please
see the disclosure elsewhere in this document addressing the fees and risks associated with third-
party exchange traded funds.
Segall Bryant & Hamill Private Opportunities Fund, LP, Segall Bryant & Hamill Private
Opportunities Fund 2020, LP, Segall Bryant & Hamill Private Opportunities Fund III, LP
The investment objective of the Segall Bryant & Hamill Private Opportunities Fund, LP, Segall
Bryant & Hamill Private Opportunities Fund 2020, LP and the Segall Bryant & Hamill Private
Opportunities Fund III, LP is to deliver long-term risk‐adjusted returns that are not highly
correlated with traditional asset classes by pursuing strategies across the private markets
including private equity, private debt, real estate and real assets. Each Fund seeks to accomplish
its objective by allocating its assets primarily among a select group of portfolio funds along with
co‐investment and direct investment opportunities, which are managed by individuals that SBH
Form ADV Part 2A – March 2026
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believes are highly talented and motivated private markets managers who combine due diligence
and investment analysis expertise.
Corient Registered Alternatives Fund
The investment objective of the CoRA Fund is to seek long-term capital appreciation as well as
income. The CoRA Fund invests at least 80% of its net assets (plus the amount of any borrowings
for investment purposes) in alternatives investments and investment with exposure to
alternative investments.
Investment Restrictions
Concentration limits on investments may be imposed to maintain the desired level of
diversification in client portfolios. These limits include security‐specific limits, industry limits and
limits on investments in companies in the same business. The limits will vary among the different
strategies. In applying industry limits to its domestic strategies, SBH may categorize certain
diversified companies into more than one industry classification. A diversified company’s industry
classification may be determined by reviewing the company’s lines of business that produce
significant revenues. For related information about the Funds, see the Funds’ Prospectus and
Statement of Additional Information.
SBH’s clients in the aggregate may own a significant percentage of the stock of certain companies,
and in some cases the aggregate or individual percentage of an issuer that clients hold may be
limited or affected by corporate restrictions, federal and state regulatory restrictions, state
control statutes, or foreign country restrictions. In order to comply with such restrictions on
aggregate holdings, SBH may, on occasion, be required to limit or sell a portion of clients’
positions or may be unable to initiate or build a position for new clients in the stock of certain
companies. In these cases, such clients’ portfolios will differ from SBH’s model portfolios.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While SBH’s
investment approaches are designed to mitigate risk, there is no guarantee that clients will not
lose money. The value of an investment will fluctuate over time in response to overall
movements in the market. The value of a security or other asset may decline due to changes in
general market conditions, economic trends or events that are not specifically related to the
issuer of the security or other asset, or factors that affect a particular issuer or issuers, country,
group of countries, region, market industry, group of industries, sector or asset class. Local,
regional, or global events such as war, acts of terrorism, the spread of infections, illness or other
public health issues, recessions, or other events could have a significant impact. Additionally,
funds comprised of securities will face all the same risks of the underlying securities as outlined
prior. During a general market downturn, multiple asset classes may be negatively affected.
Changes in market conditions and interest rates generally do not have the same impact on all
types of securities and instruments. The value of a portfolio may decrease if the value of an
individual company or security, or multiple companies or securities, in the portfolio decreases.
Further, regardless of how well individual companies or securities perform, the value of a
portfolio could also decrease if there are deteriorating economic or market conditions.
Investments are subject to the risk that geopolitical and other events will disrupt securities
Form ADV Part 2A – March 2026
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markets, adversely affect global economies and markets and thereby decrease the value of
investments. Widespread disease, including pandemics and epidemics, may also affect financial
markets. Securities markets may be susceptible to market manipulation or other fraudulent
trade practices, which could disrupt the orderly functioning of these markets or adversely affect
the value of investments traded in these markets.
The common risks of loss described in this section are intended as a high‐level overview. Please
see other disclosure documents for a complete discussion of the risks attributable to an individual
investment including, but not limited to, prospectuses, private placement memorandum and
other offering documents.
Common Risks Associated with all Investment Types
Cybersecurity Risk
Cybersecurity - SBH information and technology systems may be vulnerable to damage or
interruption from computer viruses, network failures, computer and telecommunication
failures, infiltration by unauthorized persons and security breaches, usage errors by its
professionals, power outages and catastrophic events such as fires, tornados, floods,
hurricanes, and earthquakes. Although SBH has implemented various measures to protect the
confidentiality of its internal data and to manage risks relating to these types of events, if these
systems are compromised, become inoperable for extended periods of time or cease to
function properly, SBH will likely have to make a significant investment to fix or replace them.
The failure of these systems and/or of disaster recovery plans for any reason could cause
significant interruptions in SBH’s operations and result in a failure to maintain the security,
confidentiality, or privacy of sensitive data, including personal information relating to clients.
SBH uses third-party service providers who are also heavily dependent on computers and
technology for their operations. Cybersecurity failures or breaches by us, our affiliates, other
service providers and the issuers of securities in which a client invests, may disrupt, and
otherwise adversely affect their business operations. This may result in financial losses to us or
our clients or cause violations of applicable privacy and other laws, regulatory fines, penalties,
reputational damage, reimbursement or other compensation costs, litigation costs, or
additional compliance costs. In addition, substantial costs may be incurred in order to prevent
any cyber incidents in the future. While SBH and our service providers have established
business continuity plans and risk management systems intended to identify and mitigate
cyber-attacks, there are inherent limitations in such plans and systems including the possibility
that certain risks have not been identified. SBH cannot control the cybersecurity plans and
systems put in place by service providers and issuers in which SBH invests on behalf of our
clients. SBH and our clients could be negatively impacted as a result.
Defensive Risk
To the extent a strategy attempts to hedge its portfolio or takes defensive measures, such as
holding a significant portion of its assets in cash or cash equivalents, the strategy may
underperform in a rising market environment or the defensive measures may not work as
intended.
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Environmental, Social and Governance (“ESG”) Risk
Although ESG factors are not a primary focus but rather one of many factors that are integrated
during the investment process which may result in SBH investing in securities or industry sectors
that underperform the market, or forgoing opportunities to invest in securities that might
otherwise be advantageous to buy. ESG is not a uniformly defined characteristic and considering
ESG factors involves a subjective assessment. ESG considerations can vary over different periods
and can evolve over time. Such considerations may also be difficult to apply consistently across
regions, countries, industries, or sectors.
ETF and Mutual Fund Risk
ETFs and mutual funds are subject to investment advisory and other expenses, which will be
indirectly paid by a client. As a result, the cost of investing by the client will be higher than the
cost of investing directly in ETFs or mutual funds and may be higher than other mutual funds that
invest directly in securities. ETFs and mutual funds are subject to specific risks, depending on the
nature of the underlying fund.
Inflation Risk
When any type of inflation is present, a dollar today will not buy as much as a dollar next year,
because purchasing power is eroding at the rate of inflation.
Issuer Risk
The price of any security issued by a company may drop in reaction to events and conditions that
impact the business of a particular company or its industry. For example, changes in key
personnel, shifts in supply or demand for the company’s product or its materials, or regulatory
events may affect business operations, while other comparable issuers are unaffected.
Liquidity Risk
Liquidity is the ability to readily convert an investment into cash. The less liquid an asset is, the
greater the risk that, if circumstances require an investor to sell the asset quickly, it will be sold
at a price below fair value. Generally, an asset is more liquid if it represents a standardized
product or security and there are many traders interested in making a market in that product or
security. For example, Treasury Bills are highly liquid, while real estate properties are not.
Market Risk
The price of an equity security, bond or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic and social
conditions may trigger market events.
Sector Risk
A portfolio may, for finite periods and from time to time, have a significant weighting of its
investments in companies that are in a single sector or related sector, due to reasons such as a
rebalancing or reconstitution of a benchmark index. Focusing investments in a sector may make
the portfolio more susceptible to adverse economic, business, regulatory or other developments
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affecting that sector. If an economic downturn occurs in a sector in which the portfolio’s
investments are focused, the portfolio may perform poorly during that period.
Below are the various types of risks that may be present depending on the type of investment
strategy as noted below: (listed alphabetically):
Common Risks Associated with Equity Investments
Equity and Equity-Related Instruments
Stocks and other equity-related instruments may be subject to various types of risk, including
market risk, liquidity risk, counterparty credit risk, legal risk and operations risk. In addition,
equity-related instruments can involve significant economic leverage and may, in some cases,
involve significant risk of loss. “Equity securities” may include common stocks, preferred stocks,
interests in real estate investment trusts, convertible debt obligations, convertible preferred
stocks, equity interests in trusts, partnerships, joint ventures or limited liability companies and
similar enterprises, warrants and stock purchase rights. Equity securities fluctuate in value, and
such fluctuations can be pronounced. In general, stock values fluctuate in response to the
activities of individual companies and in response to general market and economic conditions.
Accordingly, the value of the stocks and other securities and instruments that a client holds may
decline over short or extended periods.
Indirect Foreign Exposure Risk
Investments in U.S.-traded securities that are organized under the laws of a foreign country or
have significant business operations abroad may be impacted by certain foreign exposure risks
described above indirectly.
Market Capitalization Risk
Securities issued by small-, medium- or large capitalization companies, will be subject to the risks
associated with securities issued by companies of the applicable market capitalization. Securities
issued by companies of different market capitalizations tend to go in and out of favor based on
market and economic conditions. During a period when securities of a particular market
capitalization underperform other types of investments, an investment’s performance could be
adversely impacted. The small- and medium-sized companies may be more vulnerable to adverse
business or economic events than larger, more established companies. In particular, these small-
and medium-sized companies may pose additional risks, including liquidity risk, because these
companies tend to have limited product lines, markets, and financial resources, and may depend
upon a relatively small management group. Therefore, small- and medium-sized stocks may be
more volatile than those of larger companies. Small- and medium-sized companies may be more
thinly traded than larger, more established companies.
Style Risk
The value of a portfolio may fluctuate based on the investment style employed in the
management of the portfolio. The risk of value investing includes that the price of a security may
not approach its anticipated value or may decline in value. The risk of growth investing incudes
that the anticipated underlying earnings or operational growth may not occur, or the market
price of the security may decline in value.
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Common Risks Associated with Non-U.S. Investments
Currency Risk
Securities issued in currencies other than the U.S. dollar are subject to fluctuations in value due
to fluctuations in the value of the U.S. dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk. U.S. dollar-denominated securities of
foreign issuers may also be subject to currency risk due to changes in exchange rates that impact
the issuer’s ability to transact business or make interest payments on debt obligations in U.S.
dollars.
Emerging Markets Risk
The risks associated with foreign investments are heightened when investing in emerging
markets. The governments and economies of emerging market countries may show greater
instability than those of more developed countries. Such investments tend to fluctuate in price
more widely and to be less liquid than other foreign investments.
Foreign Exposure Risk
There are risks and costs involved in investing in non-U.S. traded securities which are in addition
to the usual risks inherent in securities that are traded on a U.S. exchange. These risks will vary
from time to time and from country to country, especially if the country is considered an
emerging market or developing country and may be different from or greater than the risks
associated with investing in developed countries. These risks may include, but are not limited to,
higher transaction costs, the imposition of additional foreign taxes, less market liquidity, security
less comprehensive security settlement procedures and
registration requirements and
regulations, significant currency devaluation relative to the U.S. dollar, restrictions on the ability
to repatriate investment income or capital, less government regulation and supervision, less
public information, less economic, political and social stability and adverse changes in diplomatic
relations between the United States and that foreign country.
Global Market Risk
Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires
and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public
health crises (such as COVID-19), and similar “Act of God” events have led, and may in the future
lead, to increased short-term market volatility and may have adverse long-term and wide-spread
effects on world economies and markets generally. Clients may have exposure to countries and
markets impacted by such events, which could result in material losses.
Common Risks Associated with Fixed Income Investments
Below-Investment Grade Securities Risk
High-yield fixed income securities, sometimes referred to as “junk” bonds, are considered
speculative. While generally providing greater income than investments in higher-quality
securities, these lower quality securities involve greater risk to principal and income than higher-
quality securities, including the possibility of default or bankruptcy of the issuers of the security.
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Like other fixed income securities, the value of high-yield securities will also fluctuate as interest
rates change.
Credit (Default) Risk
The owner of a fixed income security may lose money if the issuer is unable or unwilling to make
timely principal and/or interest payments or to otherwise honor its payment obligations. Further,
when an issuer suffers adverse changes in its financial condition or credit rating, the price of its
debt obligations may decline and/or experience greater volatility. These adverse changes can also
affect the liquidity of an issuer’s debt securities and make them more difficult to sell.
Extension Risk
An issuer may exercise it’s right to pay principal on an obligation held by a portfolio (such as a
mortgage- or asset-backed security) later than expected. This may happen when there is a rise in
interest rates. These events may lengthen the duration and potentially reduce the value of these
securities.
Fixed Income Securities Risk
Fixed income securities markets may, in response to governmental intervention, economic or
market developments (including potentially a reduction in the number of broker-dealers willing
to engage in market-making activity), or other factors, experience periods of increased volatility
and reduced liquidity. Additionally, to the extent a Fund invests in fixed income securities, there
is a possibility that the Fund’s income may decline due to a decrease in interest rates.
Interest-rate Risk
Fluctuations in interest rates may cause prices of fixed income securities to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Municipal Securities Risk
To the extent a portfolio invests in municipal securities, the portfolio will be highly impacted by
events tied to the overall municipal securities markets, which can be very volatile and significantly
affected by unfavorable legislative or political developments and adverse changes in the financial
conditions of municipal securities issuers and the economy. Income from municipal securities
held by a portfolio could be declared taxable because of changes in tax laws or interpretations
by taxing authorities, or noncompliant conduct of a municipality. In addition, a portion of the
Fund’s otherwise tax-exempt dividends may be taxable to those investors subject to the
alternative minimum tax.
Prepayment Risk
When the issuer of a fixed income security has the right to prepay principal, if it exercises that
right earlier or at a higher rate than expected, an investor may incur losses from being unable to
recoup the initial investment and/or from having to reinvest in lower-yielding securities. This can
have an adverse effect on income, total return and/or price of the security. Prepayment risk tends
to be highest in periods of declining interest rates. Asset-backed securities, including mortgage-
backed and commercial mortgage-backed securities, are subject to greater prepayment risk than
other types of fixed income securities.
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Quantitative Modeling Risk
Quantitative models including stock and country selection ranking models use mathematical and
statistical techniques to identity investment opportunities may not yield the desired goals. The
accuracy of quantitative model depends on the quality and reliability of the data used for
analysis.
Reinvestment Risk
This is the risk that future proceeds from investments may have to be reinvested at a potentially
lower rate of return (e.g., interest rate). This primarily relates to investments in fixed income
securities, but also applies to investment in other income-generating securities, including shares
of funds.
U.S. Government Securities Risk
Although U.S. Government securities are considered among the safest investments, they are not
guaranteed against price movements due to changing interest rates. Obligations issued by some
U.S. Government agencies are backed by the U.S. Treasury, while others are backed solely by the
ability of the agency to borrow from the U.S. Treasury or by the agency’s own resources.
Alternative Investments (Private Funds) Risk
Aggressive Investment Technique Risk
The manager of certain underlying funds may use investment techniques and financial
instruments that may be considered aggressive, including but not limited to investments in
derivatives such as futures contracts, options on futures contracts, securities and indices, forward
contracts, swap agreements and similar instruments. Such techniques may also include taking
short positions or using other techniques that are intended to provide inverse exposure to a
particular market or other asset class, as well as leverage, which can expose an SBH private fund
to potentially dramatic changes (losses or gains). These techniques may expose an SBH private
fund to potentially dramatic changes (losses) in the value of certain of its portfolio holdings.
Counterparty Risk
The institutions (such as banks) and prime brokers with which a manager does business, or to
which securities have been entrusted for custodial purposes, could encounter financial
difficulties. This could impair the operational capabilities or the capital position of a manager or
create unanticipated trading risks.
For investors in SBH private funds or the Funds, the summary above is qualified in its entirety by
the risk factors set forth in the applicable offering materials for the applicable product.
Limitations on Withdrawal of Capital
Certain SBH private funds and the underlying funds in which they invest have broad rights to
defer, suspend, side pocket, or otherwise delay all or a portion of a withdrawal request, as well
as to delay payment of all or a portion of withdrawal proceeds. In periods of market disruption,
when an SBH private fund may have the most need for the withdrawal proceeds, the private fund
or an investor in such private fund may be unable to withdraw its capital. No assurances can be
Form ADV Part 2A – March 2026
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made that an SBH private fund will be able or willing to liquidate investments sufficient to satisfy
all or any portion of withdrawal requests, and SBH private funds and investors therein must be
prepared to bear the financial risks of an investment for an indefinite period of time materially
increasing the risk of investment.
Liquidity and Transferability of Underlying Fund Interests
Certain underlying funds offer their investors only limited liquidity and interests are generally not
freely transferable. In addition to other liquidity restrictions, SBH’s private funds generally offer
only monthly or quarterly liquidity following prior notice for investors. Investments in underlying
funds may offer liquidity at infrequent times (i.e., monthly, quarterly, annually, or less
frequently). Accordingly, investors in SBH’s private funds should understand that they may not
be able to liquidate their investment in the event of an emergency or for any other reason.
Possibility of Fraud and Other Misconduct
Certain SBH private funds invest in underlying funds. In these instances, the private fund does
not have custody of the underlying fund’s assets. Therefore, there is the risk that the underlying
fund or its custodian could divert or abscond with those assets, fail to follow agreed upon
investment strategies, provide false reports of operations, or engage in other misconduct.
Moreover, there can be no assurances that all underlying funds will be operated in accordance
with all applicable laws and that assets entrusted to underlying funds will be protected.
Real Estate
Certain SBH private fund investments will be subject to the risks inherent in the ownership and
operation of real estate and real estate-related businesses and assets. Some risks that may be
associated with the direct ownership of real property include declines in the value of real estate,
risks related to general and local economic conditions, overbuilding and increased competition,
increase in property taxes and/or operating expenses, and variations in rental income.
Alternative Investments (CoRA Fund) Risk
The CoRA Fund will invest in various companies, ventures and business (“Portfolio Companies”)
as well as private funds and registered investment companies (“Portfolio Funds”). Certain private
equity assets may also be included in the term “Portfolio Funds.”
The risks included below represent a summary of the general investment risks associated with
an investment in the CoRA Fund. Additional risk factors are described in more detail within the
CoRA Fund’s offering documents. Investors should read carefully the Confidential Private
Placement Memorandum for further information on the various risks prior to investing into the
CoRA Fund.
No right of Redemption
The CoRA Fund is a closed-end investment company, and as such its shareholders will not have
the right to cause the CoRA Fund to redeem their shares. Instead, the CoRA Fund expects to
provide liquidity through tender offers following the initial two year “lock-up” period.
Shareholders have no rights to redeem or transfer their shares, other than limited rights of a
shareholder’s descendants or estate to request a repurchase of Shares in the event of such
shareholder’s death. Such repurchase may be made, at the CoRA Fund’s discretion, in a manner
Form ADV Part 2A – March 2026
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consistent with the CoRA Fund’s periodic repurchases or in such other manner as may be
permitted.
Fluctuations in Performance
The CoRA Fund could experience fluctuations in its performance due to a number of factors. Past
performance should not be relied upon as being indicative of future results.
Competition for Investment Opportunities
The CoRA Fund will compete for investments with other investment funds (including registered
investment companies, private equity funds, mezzanine funds and collateralized loan obligation
funds), as well as traditional financial services companies such as commercial banks, finance
companies, business development companies, small business investment companies and other
sources of funding. The CoRA Fund may lose investment opportunities if it does not match its
competitors’ pricing, terms and structure. Furthermore, many of the CoRA Fund’s competitors
are not subject to the source-of-income, asset diversification and distribution requirements that
the CoRA Fund must satisfy to maintain its qualification as a RIC.
Co-Investment Risk.
As a co-investor, the CoRA Fund may have interests or objectives that are inconsistent with those
of the lead private equity investors that generally have a greater degree of control over such
investments.
Restricted and Illiquid Investments.
The CoRA Fund may invest a portion of the value of its total assets in restricted securities and
other investments that are illiquid. SBH may be unable to sell restricted and other illiquid
securities at the most opportune times or at prices approximating the value at which they
purchased such securities.
Legal and Regulatory Constraints.
The CoRA Fund is subject to constraints on its operations under both the 1940 Act and the
Internal Revenue Code. These constraints, among others, may hinder SBH’s ability to take
advantage of attractive investment opportunities and to achieve the Fund’s investment
objective.
ITEM 9 - DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of SBH or the integrity of SBH’s
management. SBH has no material information responsive to this Item.
Form ADV Part 2A – March 2026
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ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Other Financial Industry Activities or Affiliation
Corient Private Wealth LLC (“Corient”) and other affiliates are also registered investment
advisers, tax preparation service companies, and other financial services-related companies
located in the U.S. and Canada. Some affiliates manage or advise private funds, investment
companies or other investment vehicles as disclosed in their respective Form ADV’s. To the extent
that SBH clients are referred to other affiliates, additional disclosures are provided below.
For both its US domiciled private funds and its non-US domiciled private funds, LWF, Inc., a wholly
owned subsidiary of SBH, serves as the managing member of such funds. For its non-U.S.
domiciled SBH private funds, two employees of SBH hold a position on each non-U.S. SBH private
fund’s board of directors.
SBH has entered into investment advisory and/or co-administration agreements with Segall
Bryant & Hamill Funds, within the Segall Bryant & Hamill Trust. Pursuant to these agreements,
SBH provides investment advisory services and/or certain administrative, management and
record keeping services for these funds. Individuals associated with SBH serve as officers of the
Funds within the Segall Bryant & Hamill Trust. In addition, SBH employees may own securities
held in one or more of these mutual funds, subject to the SBH Code of Ethics.
SBH has entered into an investment advisory agreement with Corient Registered Alternatives
Fund. Pursuant to this agreement, SBH provides investment advisory services and/or certain
administrative, management and record keeping services for these funds. Individuals associated
with SBH serve as officers of the CoRA Fund. In addition, SBH employees may own securities held
in the CoRA Fund, subject to the SBH Code of Ethics.
Certain employees of SBH are registered representatives with Foreside Fund Services, LLC
(“Foreside”). As registered representatives, the employees are authorized to sell the SBH Funds
and receive compensation in connection with such activities. SBH is not affiliated with Foreside.
Such registered representatives have an incentive to sell SBH’s products over other products
where such registered representatives do not receive compensation.
Certain employees serve as dual employees of SBH and Corient Private Wealth and are under
common control. SBH and Corient Private Wealth both have supervisory responsibilities over
these dual employees. Each dual employee is subject to SBH’s and Corient Private Wealth’s Code
of Ethics and policies and procedures.
Form ADV Part 2A – March 2026
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ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
SBH has adopted a Code of Ethics (the “Code”) and compliance policies that require our
employees to follow a high standard of business conduct and emphasize our fiduciary duty to our
clients. The Code requires employees to acknowledge the Code and other compliance policies
annually and when amended.
Employee Personal Trading
The Code is designed to seek assurance that the personal securities transactions, activities, and
interests of the employees of SBH (including all beneficial ownership) will not interfere with (i)
making decisions in the best interest of advisory clients and (ii) implementing such decisions
while, at the same time, allowing employees to invest for their own accounts. In addition, the
Code requires pre-clearance of many transactions and restricts trading in close proximity to
client-trading activity. The code of ethics permits employees to invest in the same securities as
clients, so there is a possibility that employees might benefit from market activity by a client in a
security held by an employee. Employee trading is monitored under the Code to reasonably
prevent conflicts of interest between SBH and its clients.
SBH employees, including investment professionals having direct responsibility for investment
decisions, may have an interest or position in a certain security or group of securities which may
also be recommended to a client. To address potential conflict of interests, SBH employees must
pre-clear their personal securities transactions (including all beneficial ownership) and are
subject to the Code de minimis requirement. Compliance monitors employees’ personal trading
activity on an ongoing basis to ensure compliance with the Code.
SBH requires prompt reports on all transactions and holdings covered by the Code on a quarterly
basis and annual basis.
SBH buys, sells, and performs research on or through companies for whom a client may be the
company, an employee, officer, or director.
Certain SBH employees that meet eligibility requirements may invest directly in SBH private funds
or participate in private placements offered by the underlying manager(s) of the SBH private
funds directly after receiving pre-clearance to ensure that there are not any material conflicts of
interest relating to those investments. Employees may invest in opportunities that are not
suitable for SBH clients or that cannot be offered to our clients.
In certain instances, employees of Corient and other affiliates may be considered Access Persons
as defined in SBH’s Code and will also be subject to the Code.
SBH will provide a copy of the Code of Ethics to any client or prospective client upon request
Form ADV Part 2A – March 2026
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ITEM 12 - BROKERAGE PRACTICES
Brokerage Selection
Unless other negotiated, SBH has authority to determine, without obtaining specific client
consent, the securities to be bought or sold, the amount of the securities to be bought or sold,
whether transactions should be combined (blocked) with similar trades for other accounts, the
broker dealer to be used, and the commission rate to be paid, unless otherwise negotiated.
SBH’s policy regarding selection of brokers and payment of commissions is to seek "best
execution" with respect to all portfolio transactions. This principle recognizes that commissions
on portfolio transactions must be utilized for the ultimate benefit of SBH’s clients. In selecting a
broker for any transaction, SBH considers both qualitative and quantitative characteristics of
each broker, including:
• Financial strength, stability, and reputation
• Efficiency of execution and error resolution
• Block trading and block positioning capabilities
• Experience of traders
• Access to multiple trading algorithms
• Research relating to the particular transaction
SBH maintains and periodically updates a list of approved brokers and dealers which, in SBH’s
judgment, are capable of providing best execution. SBH’s traders are directed to use only brokers
and dealers on the approved list, except in case of client designations of brokers or dealers to
effect transactions for such clients’ accounts.
SBH receives a benefit when it uses client commissions to receive research, because SBH does
not have to pay for such services on its own. SBH has an incentive to select or recommend a
broker-dealer based on its interest in receiving research from a broker-dealer or third party,
rather than the client’s interest in seeking favorable execution. However, as described below,
SBH trading practices are designed to achieve best execution for its clients even when it is
receiving research services from broker-dealers.
Research and Other Soft Dollar Benefits (including Commission Sharing Arrangements)
SBH may pay commission rates on equity transactions at commission rates that exceed those
that a broker might charge for effecting the same transaction because of the value of the eligible
brokerage and/or research products or services (“Research”) that such broker or third party
provides. This practice is allowable under Section 28(e) of the Securities and Exchange Act of
1934 if SBH determines, in good faith, that the commission paid is reasonable in relation to the
value of the Research provided.
SBH utilizes brokerage commissions for the purpose of obtaining research, research-related
products, and other brokerage services. This practice is known as soft dollars. When SBH uses
soft dollars to obtain these benefits, it is possible that the client may pay a higher cost for
execution services. Use of these products generally benefits SBH clients because the products
and services obtained through soft dollars assist in the formulation of investment advice.
Form ADV Part 2A – March 2026
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The source of the Research can be categorized as either “proprietary” or “third party.” When the
broker-dealer that executes a trade also provides SBH with internally generated research in
exchange for one bundled per share commission price, that Research is referred to as
“proprietary.” “Third party” Research involves the executing broker providing independent
Research generated by a third party in exchange for commission dollars. In these cases, SBH
negotiates the execution cost with the executing broker.
SBH also has arrangements where it receives certain non-research products and services from
unaffiliated third parties providing trading and custody services. These products and services
include assistance in administering clients’ accounts, providing pricing information and other
market data and assistance with back-office functions, recordkeeping, and client reporting. This
practice is allowable under Section 28(e) of the Securities and Exchange Act of 1934 if SBH
determines, in good faith, that the commission paid is reasonable in relation to the value of the
Research provided.
The Research obtained normally benefits many accounts rather than just the one(s) for which
the order is being executed, and in some cases is not used in connection with the account which
actually paid the commissions to the broker providing the Research. SBH does receive a benefit
because SBH does not have to produce or pay for the Research. There is an inherent conflict of
interest in these arrangements where an incentive exists for SBH to select a broker-dealer based
on the firm’s interest in receiving the Research, rather than on a client’s interest in receiving most
favorable execution.
SBH has addressed these conflicts of interest by periodically evaluating:
• The commission rates paid by clients against industry benchmarks given the size and
nature of SBH’s trading
• The value of the Research obtained to SBH’s investment processes
• Monitoring trade execution
The following products and services acquired by SBH through Research arrangements are as
follows:
• Research services and reports
• Economic and market information
• Technical data
• Research conferences
• Consultations
• Benchmark index data
• Company specific data
• Trade order management software
• Quotation services
On a quarterly basis, the Equity and Fixed Income Best Execution committees, each review the
quality of research and execution services of the various broker-dealers and independent
research firms. In addition, the Equity Best Execution committee also evaluates the commission
rates negotiated with the various brokers to make a good faith determination that they are
reasonable in relation to the value of products and services provided.
Form ADV Part 2A – March 2026
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Client-Directed Brokerage Arrangements
Clients can direct SBH in writing to affect portfolio transactions for their accounts through
specified brokers or dealers. Such a direction may be conditioned upon the broker or dealer being
competitive as to net price and execution of each transaction or may be subject to varying
degrees of “restriction,” i.e., an instruction to use the particular broker or dealer whether or not
competitive as to net price and execution, or at specified commission rates which are less
favorable than otherwise might be obtainable by SBH.
Clients sometimes wish to restrict brokerage to a particular broker or dealer in recognition of
custodial or other services (including, in some cases, referral of the client to SBH for investment
advisory services) provided to the client by the broker or dealer. A client which chooses to
designate use of a particular broker or dealer completely or on a “restricted” basis, including a
client which designates a broker or dealer as custodian of the client’s assets, should consider
whether such a designation may result in certain costs or disadvantages described below
regarding priority of execution, allocation of new issue purchases and aggregation of orders. In
determining whether to instruct SBH to use a particular broker or dealer on a “restricted” basis,
the client may wish to compare the possible costs or disadvantages of such an arrangement with
the value of the custodial or other services provided.
Clients who restrict brokerage for their accounts may be disadvantaged in obtaining allocations
of securities which SBH purchases or recommends for purchase in other clients’ accounts.
In order to execute client orders most efficiently, SBH’s traders may assign a lower priority to
execution of orders for client accounts which have restricted brokerage. Accordingly, the
execution of orders for accounts which restrict brokerage may be less timely than the execution
of orders for other client accounts. This priority of execution may or may not result in any
consistent price disadvantage, depending upon the market activity in the security to be
purchased or sold.
Trading for wrap programs is typically executed by the program sponsor. Wrap sponsors charge
a combined fee to clients which includes execution services and trading away from such sponsors
causes clients to incur additional execution charges. SBH follows its trade aggregation and
allocation policies with respect to wrap program trading, however in certain circumstances
following contractual arrangements, wrap program trades may be executed after “unrestricted”
and “restricted” trades are executed. Where SBH determines to seek to obtain best execution
away from such wrap sponsor, such trades will generally be executed with other non-restricted
and unrestricted trades.
For those strategies that have SMA Wrap / UMA Model platforms with contractual requirements
of fair and equitable trading over time, a random trade rotation is assigned across the three types
Institutional/SMA Wrap (discretionary) and Model (non-discretionary)
of relationships:
platforms. SMA Wrap trades are directed to the wrap trading desk for each wrap sponsor and
trades are communicated to the model sponsor via the sponsor’s established processes and
requirements.
Form ADV Part 2A – March 2026
35 35
Trade Aggregation and Allocation
SBH may place purchase or sale orders for a single security with a broker dealer for an aggregate
group of similar clients when determined that it is consistent with the best interest of clients to
do so. In instances where the purchase or sale order for a single security cannot be aggregated
across all clients, SBH maintains aggregation policies and procedures to ensure the order of
execution is fair and equitable over time among all clients that granted SBH full discretionary
trading authority or clients that have a contractual requirement through certain wrap programs.
To the extent that an aggregated order is filled at different prices during a trading day, each
participating account will receive the same average price and pay the same average commission
for the transaction. Should an aggregated order be partially completed during a trading day,
securities will be allocated pro rata based upon each participating account’s percentage of the
entire order. If the pro rata allocation would result in numerous accounts receiving small
positions, SBH has fair and equitable procedures in place to allocate such “partial fills” to
accounts. Generally, fixed income securities will be aggregated and allocated in a fair and
equitable manner taking into account that such securities may be available in limited quantities
that preclude pro-rata allocation and the fact that other fixed income securities of equal quality
and yield may be suitable substitutes.
SBH engages in “step-out” brokerage transactions subject to best price and execution. In a “step-
out” trade, one broker-dealer executes the transaction, while a second broker-dealer clears and
settles the transaction. The first broker-dealer then shares part or all of its commission with
respect to the transaction with the second broker-dealer. SBH engages in step-out transactions
primarily (1) to satisfy directed brokerage arrangements of certain of its client accounts and/or
(2) to pay commissions to broker-dealers that supply research or analytical services to the
Adviser. Shares traded via step-out are traded on a pre-determined cost per share, which is
netted into the trade regardless of account type. The cost varies by broker.
Cross Trades
It is SBH’s policy to not engage in principal or agency cross transactions.
Initial Public Offering (“IPO”)
SBH does not currently maintain strategies that purchase securities which are part of an initial
public offering (“IPO”).
ITEM 13 - REVIEW OF ACCOUNTS
Accounts are reviewed on a continual basis by the portfolio manager and their respective teams.
There is no specific sequence in which accounts are reviewed. Rather, an ongoing review process
is in place. Additional reviews are initiated when market conditions dictate, client circumstances
warrant, or any other pertinent factors surface. Thus, the frequency of reviews may vary. Reviews
are undertaken in context of the applicant’s current investment policy guidelines, individual
security analysis, and/or client investment considerations. Institutional accounts frequently
Form ADV Part 2A – March 2026
36 36
utilize a consulting firm which SBH’s professionals work closely with in servicing the account. The
level of review on individual accounts within a third-party wrap program, where SBH serves as a
portfolio manager, is typically limited subject to the agreement with the wrap program sponsor.
Reporting is customized based on the needs of each client. Clients and/or client representatives
receive written information via mail or electronic information via a client portal on performance,
portfolio appraisal, transaction history and portfolio characteristics on a periodic basis which is
typically either monthly, or quarterly. SBH relies on the sponsor of the wrap programs for any
wrap program client reporting.
See Custody section for information on the frequency of client reports.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Additional Compensation
SBH from time to time may compensate, either directly or indirectly, any person for client
referrals. SBH is aware of the requirements under Section 206(4)-1 (The “Marketing Rule”) of
the Investment Advisors Act of 1940 and endeavors to comply therewith. SBH maintains
written agreements and client acknowledgements for each relationship.
ITEM 15 - CUSTODY
A qualified custodian holds all client certificated assets. Accordingly, clients should receive at
least quarterly statements from a qualified custodian. Other than for the SBH Funds, CoRA Fund,
and SBH private funds, SBH prepares and delivers to all clients, either hard copies or electronically
via a secured client portal, valuations of their accounts at least quarterly, showing cash and all
currently held investments categorized by maturity (fixed income investments) or industry
(equity investments), market value and unit cost. A summary of transactions for the prior quarter
accompanies the inventory. Clients may request more frequent or detailed reports in accordance
with their individual needs. SBH has a reasonable belief that the custodian is sending statements
in accordance with SEC’s Custody Rule. Reports or statements produced by SBH are provided to
clients. The client should compare the information provided by SBH with the statements provided
by the custodian.
Investors in the SBH private funds receive written valuations of their account balances monthly
from the fund administrator, however certain SBH private equity funds with certain underlying
investments in private offerings with longer reporting time periods are generally sent on a
quarterly basis once the necessary information has been received from the underlying
fund/investment. In its capacity as manager of certain private funds, SBH is deemed to have
custody of such fund’s assets. SBH maintains such private funds’ cash and securities with a
qualified custodian and provides investors in these private funds with an annual audited financial
statement within 120 days of the end of such private fund’s fiscal year. Certain SBH private funds
meet certain exemptions based on the types of investments made by the fund which results in
Form ADV Part 2A – March 2026
37 37
the annual audited financial statement being delivered to investors within 180 days or 260 days
of the end of such private fund’s fiscal year, depending on the types and amounts of investments
within the SBH private fund.
ITEM 16 – INVESTMENT DISCRETION
SBH manages its clients on a discretionary basis.
When a client chooses to grant investment discretion to SBH, SBH will have authority to supervise
and direct the investments of and for the client’s account without prior consultation with the
client. Pursuant to this discretionary authority, SBH will determine which securities are bought
or sold for the account, the total amount of such purchases and sales, the brokers or dealers
through which transactions will be affected, and the commission rates, if any, paid to affect the
transactions. When selecting securities and determining amounts, SBH observes the investment
policies, limitations, and restrictions of the clients for which it advises.
SBH’s authority may be made subject to conditions imposed in writing by the client, e.g., where
the client restricts or prohibits purchases of certain types of securities, or directs that
transactions be affected through specific brokers or dealers.
While SBH does not accept non-discretionary assignments, in those cases where a client does not
choose to grant SBH investment discretion, SBH makes investment recommendations to the
client as to which securities are to be purchased or sold, and the amounts to be purchased or
sold. Upon approving the recommended transactions, the client may request that SBH direct the
execution of purchase or sale orders to implement the recommended transactions for the client’s
account. SBH then may be given authority to determine the brokers or dealers through which the
transactions will be executed, and the commission rates, if any, paid to affect the transactions.
As described above with respect to discretionary accounts, the client may direct that transactions
are affected by specific brokers or dealers.
ITEM 17 - VOTING CLIENT SECURITIES
Policy
SBH acts as a discretionary investment adviser for various clients, which includes clients governed
by the Employee Retirement Income Security Act of 1974 (“ERISA”) and registered investment
companies. SBH’s standard investment management agreement requires the client to delegate
proxy voting authority to SBH SBH’s standard investment management agreement for accounts
governed by ERISA (certain pension or retirement plans, non-IRA’s) require SBH to vote proxies
unless an ERISA client specifically reserves the right, in writing, to vote its own proxies or to take
shareholder action with respect to other corporate actions requiring shareholder actions.
Procedures
SBH uses an outside service provider, Institutional Shareholder Services (“ISS”), to vote proxies.
ISS considers each proxy issue individually. ISS issues proxy voting guidelines which are available
upon request.
Form ADV Part 2A – March 2026
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As a general rule, the operations group will provide instructions to the custodian to forward all
proxies to ISS. ISS receives all proxies and votes them in accordance with the standing instruction
to vote with the ISS recommendation, unless instructions are provided to override the ISS
recommendation. In the rare instance where our portfolio manager or analyst believes that an
ISS recommendation would be to the detriment of our investment clients, we can and will
override ISS’ recommendation through a manual vote. In the event of more than one SBH
investment team holding the security, the decision to override should be authorized by a member
of each SBH investment team. The final authorization to override an ISS recommendation must
be approved by the CCO or their designee. A written record supporting the decision to override
the ISS recommendation will be maintained.
Conflicts of Interest
By utilizing an independent service provider for proxy voting, SBH seeks to minimize conflicts of
interest related to proxy voting.
Limitations
As described above, in accordance with a client’s investment advisory contract (or other written
directive) or where SBH has determined that it is in the client’s best interest, ISS and/or SBH will
not vote proxies received. The following are certain circumstances where ISS and/or SBH will limit
its role in voting proxies:
1. Client Maintains Proxy Voting Authority: As is ordinarily the case, where a client specifies in
writing that it will maintain the authority to vote proxies itself or that it has delegated the
right to vote proxies to a third party, ISS and/or SBH will not vote the securities and will direct
the relevant custodian to send the proxy material directly to the client. If any proxy material
is received by SBH, it will promptly be forwarded to the client or specified third party.
2. Terminated Account: Once a client account has been terminated with SBH in accordance with
its investment advisory agreement, ISS and/or SBH will not vote on any proxies received after
the termination. However, the client may specify in writing that proxies should be directed
to the client (or a specified third party) for action.
3. Limited Value: If ISS and/or SBH determines the value of a client’s economic interest or the
value of the portfolio holding is indeterminable or insignificant, ISS and/or SBH may abstain
from voting a client’s proxies. ISS and/or SBH also will not vote proxies received for securities
which are no longer held by the client’s account.
4. Securities Lending Programs: When securities are out on loan, they are transferred into the
borrower’s name and are voted by the borrower, in its discretion. However, where SBH
determines that a proxy vote (or other shareholder action) is materially important to the
client’s account, SBH may recall the security for purposes of voting.
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5. Unjustifiable Costs: In certain circumstances, after doing a cost-benefit analysis, SBH may
abstain from voting where the cost of voting a client’s proxy would exceed any anticipated
benefits to the client of the proxy proposal.
How to Obtain Proxy Records and Voting Policy
Clients may obtain information on how proxies were voted with respect to the clients’ portfolio
securities or a copy of our Proxy Voting Policy by writing to SBH at 10 South Wacker Drive,
Chicago, IL 60606 or by emailing compliance@cisbh.com.
For information regarding how proxies were voted for the Segall Bryant & Hamill Funds, please
refer to www.cisbh.com/funds/literature and select Proxy Voting Record. The Segall Bryant &
Hamill Funds’ proxy voting records also are available on the SEC’s EDGAR website at
www.sec.gov/edgar/search.
ITEM 18 - FINANCIAL INFORMATION
SBH does not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance.
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