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Form ADV Part 2A – Firm Brochure
Item 1 – Cover Page
Seneca Financial Advisors LLC
500 Linden Oaks, Suite 150
Rochester, NY 14625
585-203-1211
www.senecafinancialadvisors.com
Date of Brochure: February 2026
____________________________________________________________________________________
This brochure provides information about the qualifications and investment advisory business practices of
Seneca Financial Advisors, LLC. If you have any questions about the contents of this brochure, please
contact us at 585-203-1211. 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.
Additional information about our investment advisory business is also available on the Internet at
www.adviserinfo.sec.gov. You can view information on this website by searching for “Seneca Financial
Advisors, LLC”. You can also search using the Firm’s CRD number. The CRD number for the Firm is
152824.
*Registration as an investment advisor does not imply a certain level of skill or training.
Item 2 – Material Changes
Since the last annual update of this brochure was filed in February 2025, we updated Item 4 to clarify and
refine the types of investments for which we provide advisory services. In addition, we removed the Part
2B Brochure Supplement for John Klee, as he is no longer with our firm.
We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure
brochures within 120 days after our fiscal year ends. Our fiscal year ends on December 31 so you will
receive the summary of material changes, if any, no later than April 30 each year. At that time, we will
also offer a copy of the most current disclosure brochure. We may also provide other ongoing disclosure
information about material changes as necessary.
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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 ........................................................................................................................... 5
General Description of Primary Advisory Services ................................................................................... 5
Limits Advice to Certain Types of Investments ......................................................................................... 6
Tailor Advisory Services to Individual Needs of Clients ............................................................................ 6
Retirement Plan Rollover Recommendations ........................................................................................... 7
Client Assets Managed by Seneca Financial Advisors ............................................................................. 8
Item 5 – Fees and Compensation ................................................................................................................. 8
1. Comprehensive Financial Planning ..................................................................................................... 8
2. Tax Planning Services ......................................................................................................................... 8
3. Investment Consulting Services ........................................................................................................... 8
4. Investment Management Services ....................................................................................................... 9
5. Fee Schedule ..................................................................................................................................... 10
6. General Information ........................................................................................................................... 11
Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 12
Item 7 – Types of Clients ............................................................................................................................ 12
Minimum Investment Amounts Required ................................................................................................ 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 12
Item 9 – Disciplinary Information ................................................................................................................. 15
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 15
Third-Party Money Managers .................................................................................................................. 15
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 16
Standards of Conduct ............................................................................................................................. 16
Affiliate and Employee Personal Securities Transactions Disclosure..................................................... 17
Item 12 – Brokerage Practices .................................................................................................................... 18
Client Directed Brokerage Arrangements ............................................................................................... 19
Trading Policy ......................................................................................................................................... 19
Trade Errors ............................................................................................................................................ 19
Item 13 – Review of Accounts .................................................................................................................... 20
Account Reviews and Reviewers ............................................................................................................ 20
Statements and Reports ......................................................................................................................... 20
Item 14 – Client Referrals and Other Compensation .................................................................................. 21
Referrals to Unaffiliated Third-Parties ..................................................................................................... 21
Other Compensation ............................................................................................................................... 21
Item 15 – Custody ....................................................................................................................................... 21
Item 16 – Investment Discretion ................................................................................................................. 22
Item 17 – Voting Client Securities ............................................................................................................... 23
Item 18 – Financial Information ................................................................................................................... 23
CUSTOMER PRIVACY POLICY ................................................................................................................ 24
Information Required by Part 2B of Form ADV: Brochure Supplement ...................................................... 26
Steve Green, Member, Chief Executive Officer, and Financial Advisor ................................................. 26
Item 1 – Cover Page ........................................................................................................................... 26
Item 2 – Educational Background and Business Experience ............................................................. 26
Item 3 – Disciplinary Information ......................................................................................................... 26
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Item 4 – Other Business Activities ...................................................................................................... 26
Item 5 – Additional Compensation ...................................................................................................... 26
Item 6 – Supervision ........................................................................................................................... 26
Scott Lefebre, Member, Managing Director of Business Development, and Financial Advisor ............. 27
Item 1 – Cover Page ........................................................................................................................... 27
Item 2 – Educational Background and Business Experience ............................................................. 27
Item 3 – Disciplinary Information ......................................................................................................... 28
Item 4 – Other Business Activities ...................................................................................................... 28
Item 5 – Additional Compensation ...................................................................................................... 28
Item 6 – Supervision ........................................................................................................................... 28
Zach Erskine, Member and Financial Advisor ........................................................................................ 29
Item 1 – Cover Page ........................................................................................................................... 29
Item 2 – Educational Background and Business Experience ............................................................. 29
Item 3 – Disciplinary Information ......................................................................................................... 30
Item 4 – Other Business Activities ...................................................................................................... 30
Item 5 – Additional Compensation ...................................................................................................... 30
Item 6 – Supervision ........................................................................................................................... 30
Kathy Raabe, Member and Financial Advisor ......................................................................................... 31
Item 1 – Cover Page ........................................................................................................................... 31
Item 2 – Educational Background and Business Experience ............................................................. 31
Item 3 – Disciplinary Information ......................................................................................................... 32
Item 4 – Other Business Activities ...................................................................................................... 32
Item 5 – Additional Compensation ...................................................................................................... 32
Item 6 – Supervision ........................................................................................................................... 32
Matt Darcy, Member, Chief Investment Officer, and Chief Compliance Officer ..................................... 33
Item 1 – Cover Page ........................................................................................................................... 33
Item 2 – Educational Background and Business Experience ............................................................. 33
Item 3 – Disciplinary Information ......................................................................................................... 34
Item 4 – Other Business Activities ...................................................................................................... 34
Item 5 – Additional Compensation ...................................................................................................... 34
Item 6 – Supervision ........................................................................................................................... 34
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Item 4 – Advisory Business
Seneca Financial Advisors, LLC is an investment advisor registered with the United States Securities and
Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of the State of
New York.
• We have been registered as an investment advisor since February 2010.
• The Firm’s majority owners and majority control persons are co-founders Steve Green, Member,
Chief Executive Officer, and Financial Advisor, and Scott Lefebre, Member, Managing Director of
Business Development, and Financial Advisor.
• Matt Darcy, Member, Chief Compliance Officer and Chief Investment Officer, Zach Erskine,
Member and Senior Wealth Advisor, Kim Merry, Member and Business Manager, and Kathy
Mezei Raabe, Member and Senior Wealth Advisor, are minority owners of the Firm.
• More information about all of our Financial Advisors’ business and education backgrounds can be
found in the Information Required by Part 2B of Form ADV: Brochure Supplement section of this
Disclosure Brochure.
General Description of Primary Advisory Services
The following are brief descriptions of Seneca Financial Advisors’ primary services. A detailed description
of Seneca Financial Advisors’ services is provided in Item 5 – Fees and Compensation so that clients and
prospective clients can review the services and description of fees in a side-by-side manner.
Financial Planning Services - Seneca Financial Advisors provides advisory services in the form of
financial planning services. Financial planning services do not involve the active management of client
accounts but instead focus on a client’s overall financial situation. Financial planning can be described as
helping individuals determine and set their long-term financial goals through investments, tax planning,
asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is
to find ways to help the client understand his/her overall financial situation and help the client set financial
objectives.
Investment Management Services – Seneca Financial Advisors provides advisory services in the form
of investment management services. Investment management services involve providing clients with
continuous and on-going supervision over client accounts. This means we will continuously monitor a
client’s account and make trades in client accounts when necessary.
Investment Consulting Services – We also provide investment consulting services in the form of oral
advice and written recommendations. These services are somewhat similar to investment management
services, except for the fact that we do not implement any recommendations. Clients signing up for this
service must understand that the Firm does not provide on-going reviews of accounts through this service
and information about such accounts is limited to information provided exclusively by the client. The client
always has the sole discretion to accept or reject the Firm’s advice. The client must implement all trades
in such accounts because the Firm will have no access to the account.
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Limits Advice to Certain Types of Investments
When providing Investment Management Services, the Firm will typically construct each client’s portfolio
using mutual funds, Exchange-Traded Funds and separate account managers to build a diversified
portfolio. It is not Seneca Financial Advisors’ typical investment strategy to attempt to time the market,
however, we do use a tactical asset allocation strategy whereby we will overweight or underweight certain
asset classes based on our expectations of market behavior, extreme undervaluation (or overvaluation),
and stages of the risk cycle. Further, we may modify our investment strategy to accommodate special
situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses,
collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies
and Risk of Loss for more information.)
Investment advice typically involves both generic and specific asset allocation recommendations.
Investment advice may be offered on any investments held by a client at the start of the advisory
relationship. Specifically, the Firm may provide investment advice on the following types of investments:
• Exchange-listed securities (i.e., stocks)
• Securities traded over-the-counter (i.e., stocks)
• Foreign Issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
•
Interests in partnerships investing in real estate, oil and gas interests
If requested, Seneca Financial Advisors may occasionally assist clients with assessing private real estate
investments, tax credit partnerships (including low-income housing and/or oil and gas), conservation tax
credits, REITs (real estate investment trusts), hedge funds, 529 college savings plans, private equity,
venture capital, timber and hedge funds, real estate partnerships or other private placement investments.
Tailor Advisory Services to Individual Needs of Clients
Seneca Financial Advisors’ services are always provided based on the individual needs of each client.
This means, for example, that you are given the ability to impose restrictions on the accounts we manage
for you, including specific investment selections and sectors. We work with each client on a one-on-one
basis through interviews and educational materials to determine the client’s investment objectives and
suitability information.
When managing client accounts through the Firm’s Investment Management Services program, we may
manage accounts in accordance with one or more investment models that are developed and monitored
by our investment team. When client accounts are managed using models, investment selections are
based on the underlying model. However, the determination to use a particular model or models is always
based on each client’s individual investment goals, objectives and mandates.
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Retirement Plan Rollover Recommendations
When Seneca Financial Advisors provides investment advice about your retirement plan account or
individual retirement account (“IRA”), including whether to maintain investments and/or proceeds in the
retirement plan account, roll over such investments/proceeds from the retirement plan account to an IRA
or make a distribution from the retirement plan account, we acknowledge that Seneca Financial Advisors
is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”)
and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts.
The way Seneca Financial Advisors makes money creates conflicts with your interests, so Seneca
Financial Advisors operates under a special rule that requires Seneca Financial Advisors to act in your
best interest and not put our interests ahead of yours.
Under this special rule’s provisions, Seneca Financial Advisors must, as a fiduciary to a retirement plan
account or IRA, under ERISA/IRC:
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Meet a professional standard of care when making investment recommendations (e.g.,
give prudent advice);
Never put the financial interests of Seneca Financial Advisors ahead of your financial
interests when making recommendations (e.g., give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that Seneca Financial Advisors gives
advice that is in your best interest;
Charge no more than is reasonable for the services of Seneca Financial Advisors; and
Give you basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account to an
individual retirement account managed by Seneca Financial Advisors, please know that Seneca Financial
Advisors and our investment adviser representatives may have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your existing
retirement plan to an IRA managed by Seneca Financial Advisors. We may earn fewer investment
advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Seneca
Financial Advisors.
Thus, our investment adviser representatives may have an economic incentive to recommend a rollover
of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that
you open an IRA account to be managed by our firm can be based on our economic incentive and not
based exclusively on whether or not moving the IRA to our management program is in your overall best
interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard
whereby our investment adviser representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status
described below, (ii) not recommend investments which result in Seneca Financial Advisors receiving
unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii)
fully disclose compensation received by Seneca Financial Advisors and our supervised persons and any
material conflicts of interest related to recommending the rollover of funds from the retirement plan to an
IRA and refrain from making any materially misleading statements regarding such rollover.
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When providing advice to you regarding a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then
prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the
conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk,
tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests
of Seneca Financial Advisors or our affiliated personnel.
Client Assets Managed by Seneca Financial Advisors
The amount of client assets managed by Seneca Financial Advisors totaled $847,190,882 as of
December 31, 2025. $740,002,562 is managed on a discretionary basis and $107,188,320 is managed
on a non-discretionary basis.
Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides details
regarding Seneca Financial Advisors’ services along with descriptions of the fees and compensation
arrangements. Fees charged by Seneca Financial Advisors may be higher or lower than fees charged by
other financial professionals offering similar services.
1. Comprehensive Financial Planning
Seneca Financial Advisors may provide financial planning services to its clients that include all or some of
the following areas:
On-going financial planning including preparation of net worth statements, annual savings needs,
retirement projections, etc.;
Employee benefits analysis;
Retirement planning;
Life insurance and disability planning;
Estate planning;
College education funding;
Tax planning and compliance; and
Other areas of importance to the client.
2. Tax Planning Services
Seneca Financial Advisors may provide tax planning and compliance services to the client that will
include all or some of the following areas:
Collection of data from client and third-party sources;
Preparation of federal, state, and local tax returns;
Calculation of estimated tax payments;
Preparation of income and gift tax projections;
Discussion of tax saving opportunities and cash flow needs;
Assistance with audits by federal and state authorities.
3. Investment Consulting Services
Seneca Financial Advisors may provide investment consulting services to the client that will include all or
some of the following areas:
Determination of current and future asset allocation needs;
Determination of the client’s risk profile;
Determination of the client’s goals and objectives;
Preparation of an Investment Policy Statement;
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Reallocation recommendations for current portfolios.
4. Investment Management Services
Seneca Financial Advisors may also provide Investment Management services to the client. This process
may include all or a part of the following:
• Determining appropriate asset allocation policy for the client;
• Recommend various investment vehicles (including, but not limited to mutual funds, ETFs, and
separate account managers) to develop a diversified portfolio based on the client’s goals,
objectives and risk profile;
• Rebalancing of the client’s portfolio to maintain the proper allocation for each asset class in the
model;
• Rendering of monthly statements of positions held by the client as well as quarterly performance
reports;
• Monitor performance of the entire portfolio in relation to the client’s goals and objectives;
• Monitor performance of the individual funds and managers relative to an appropriate benchmark.
Through its Investment Management services, Seneca Financial Advisors provides investment
supervisory services defined as giving continuous investment advice to a client and making investments
for the client based on the individual needs of the client. Through this service, Seneca Financial Advisors
offers a customized and individualized investment program for clients. Various investment strategies are
provided through this service; however, a specific investment strategy and investment policy is crafted for
each client to focus on the specific client’s goals and objectives. Clients may select Seneca Financial
Advisors as the manager of all or a portion of their assets. For many of these clients, the accounts will be
managed with the recommendations for various investments that are chosen based on the asset
allocation, investment objectives and risk tolerance of the particular client.
Recommendation of Unaffiliated Sub-Advisers: As part of our Investment Management Services,
we may recommend the use of unaffiliated, third-party investment advisers serving as “Sub-
Advisers” to manage all or a portion of your assets. Any Sub-Adviser recommended by us shall be
registered or exempt from registration in your home state. The recommendation of a Sub-Adviser
shall be made on a non-discretionary basis. The decision to use a Sub-Adviser is always based on
each client’s individual needs. You will enter into an agreement directly with the unaffiliated Sub-
Adviser(s). A complete description of the third-party investment advisor’s services acting as Sub-
Adviser, fee schedules and account minimums will be disclosed in the third-party investment
advisor’s Form ADV Disclosure Brochure which will be provided to clients at the time an agreement
for services is executed and account is established with the Sub-Adviser.
We are always available to answer questions you may have regarding the portion of your account
managed by the Sub-Adviser and act as the communication conduit between you and the Sub-
Adviser. Sub-Advisers will generally take discretionary authority to determine the securities to be
purchased and sold for your accounts.
Seneca Financial Advisors shall obtain clients’ information to determine each individual client’s financial
situation and investment objectives. Accounts are therefore managed on the basis of each client’s
financial situation and investment objectives. At least quarterly, clients are instructed to notify Seneca
Financial Advisors whether the client’s financial situation or investment objectives have changed, or if the
client wants to impose and/or modify any reasonable restrictions on the management of their accounts. At
least annually, Seneca Financial Advisors shall contact individual clients to determine whether their
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financial situation or investment objectives have changed, or if the client wants to impose and/or modify
any reasonable restrictions on the management of accounts managed. Seneca Financial Advisors shall
be reasonably available to consult with individual clients relative to the status of their accounts. Clients
shall have the ability to impose reasonable restrictions on the management of their accounts including the
ability to instruct Seneca Financial Advisors not to purchase certain securities. A client’s beneficial
interest in a security does not represent an undivided interest in all the securities held by the custodian,
but rather represents a direct and beneficial interest in the securities which comprise the account. A
separate account is maintained for each client with the custodian and clients retain right of ownership of
the Account (e.g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive
transaction confirmations).
These accounts will be held at an independent custodian (such as Schwab and Fidelity) (Please see Item
15 – Custody of this Disclosure Brochure for more information) and they may be managed on a
discretionary or non-discretionary basis. For discretionary accounts, Seneca Financial Advisors will select
the investments to be purchased or sold for the client’s account(s) while staying within the asset
allocation mutually agreed upon by the client and Seneca Financial Advisors (Please see Item 16 –
Investment Discretion of this Disclosure Brochure for more information).
5. Fee Schedule
Fees for comprehensive financial planning, tax planning, investment consulting, and investment
management services will be charged in one or more of three ways:
1. As an annual fixed fee. The standard annual fee for financial planning is $5,000 but could be more or
less based on the scope and complexity of each individual’s situation. The annual fixed fee can also be
adjusted to include tax planning, investment consulting, and investment management services and can
typically range from $4,000 to $60,000. The fixed fee will be divided into four quarterly installments
payable in arrears and pro-rated for partial quarters.
2. On an hourly basis that ranges from $100 - $500 per hour, depending on the nature and complexity of
the client’s circumstances and the individual providing the service. Financial planning, tax planning, and
investment consulting services may be charged on an hourly basis. These fees will be billable and due as
earned.
3. As a percentage of the market value of assets under management (AUM), as further described below.
AUM fees are billed quarterly in arrears and are pro-rated for partial quarters.
Clients may choose to pay for the services they receive from Seneca Financial Advisors based on one of
these methods or a combination thereof. It is customary for clients to pay for financial planning services
as a fixed fee, tax planning and compliance services on an hourly basis, and investment consulting and
management based on their assets under management.
Additional Details – Fees Based on Assets Under Management
When fees are billed based on the value of assets under management, the quarterly fee is calculated
based on the market value at the end of the quarter. Fees are generally deducted directly from the client’s
account. Clients must provide the custodian with written authorization to have fees deducted from the
account and paid to Seneca Financial Advisors. Upon discretion of Seneca Financial Advisors, clients
may pay fees directly to Seneca Financial Advisors. For clients that pay directly, payment is due upon the
client’s receipt of the billing statement from Seneca Financial Advisors. The statements sent by the
custodian will outline the fees paid to Seneca Financial Advisors during that time period. No other invoice
will be provided by Seneca Financial Advisors.
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Each client’s exact AUM fee schedule will be outlined in detail in the Financial Advisory Agreement based
on the services chosen by the client. Fees based on the value of assets under management are outlined
below and are billed on a graduated schedule. The standard annual fee schedule for investment
management and consulting is:
STANDARD (MAXIMUM) FEES
Value of Assets
Fee
Less than $1,000,000
1.00%
Next $1,000,000 to $2,500,000
0.85%
Next $2,500,000 to $3,250,000
0.75%
Next $3,250,000 and over
0.65%
It should be noted that advisory fees are negotiable depending upon the composition of the portfolio and
certain other factors and that some clients may be assessed fee schedules lower than this schedule.
When clients have a portion of their assets managed by a Sub-Adviser, the Sub-Adviser fees are always
charged separately from our fee. Sub-Advisers are also responsible for calculating and collecting their
fees directly from clients. Seneca Financial Advisors is not responsible for the collection of Sub-Adviser
fees. The exact fee charged by a Sub-Adviser will be in accordance with the Sub-Adviser’s current fee
policies and arrangements. Clients need to refer to the Sub-Adviser’s Form ADV Disclosure Brochure for
full details.
6. General Information
Recommendations and strategies necessary to work towards the client’s goals and objectives will be
discussed orally and, where appropriate, provided in a written summary format. Financial planning and
financial consulting services are advisory only and the client has no obligation to take any action or to act
on any recommendation made by Seneca Financial Advisors.
A client agreement can be canceled at any time, by either party, for any reason upon receipt of written
notice. Upon termination of any account, any earned, unpaid fees will be due and payable. The client has
the right to terminate an agreement within five business days after entering into the agreement without
incurring fees. For Investment Management Services, termination shall be effective from the time the
terminating party notifies the other party of the request for termination or such other time as may be
mutually agreed upon, subject to the settlement of transactions in progress and the final payment of
advisory fees. There will be no penalty charge upon termination. The final fee payment will be pro-rated
based on the number of days remaining in the final quarter. The date of termination will be used to
calculate the final fee payment.
Brokerage commissions and/or transaction ticket fees charged by the custodian will be billed directly to
the client. Seneca Financial Advisors will not receive any portion of such commissions or fees from the
custodian or client. In addition, all fees paid to Seneca Financial Advisors for investment management
services are separate and distinct from the fees and expenses charged by mutual funds to their
shareholders. These fees and expenses are described in each fund’s prospectus. These fees will
generally include a management fee and other fund expenses. A client could invest in a mutual fund
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directly without the services of Seneca Financial Advisors. In that case, the client would not receive the
services provided by Seneca Financial Advisors which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client’s financial condition
and objectives. Accordingly, the client should review both the fees charged by the funds and the fees
charged by Seneca Financial Advisors to fully understand the total amount of fees to be paid by the client
and to thereby evaluate the investment management services being provided.
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 6 of the Form ADV Part 2 instructions is not applicable to this Disclosure Brochure because Seneca
Financial Advisors does not charge or accept performance-based fees, which can be defined as fees
based on a share of capital gains on or capital appreciation of the assets held within a client’s account.
Item 7 – Types of Clients
Seneca Financial Advisors generally provides investment advice to the following types of clients:
Individuals
•
• Trusts, estates or charitable organizations
• Limited Partnerships, Limited Liability Companies, and Corporations
Minimum Investment Amounts Required
There are no minimum investment amounts or conditions required for establishing an account managed
by Seneca Financial Advisors. Although there are no minimums imposed by Seneca Financial Advisors,
the Firm may offer other programs through select managers with a minimum investment size. Certain
account minimums and fees are negotiable at Seneca Financial Advisors’ discretion.
All clients are required to execute an agreement for services prior to commencing any work.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Seneca Financial Advisors uses the following investment strategies when managing client assets
and/or providing investment advice.
Seneca Financial Advisors uses the following strategic asset allocation portfolios:
• Equity - The Equity portfolio is appropriate for investors with a long time horizon and a
substantial risk tolerance for market volatility. This investment strategy is intended to provide
portfolio appreciation by investing primarily in equity securities, with limited exposure to fixed
income.
• Equity-Tilted Balanced - The Equity-Tilted portfolio is appropriate for investors who have a
relatively long time horizon and a high risk tolerance for market volatility. This investment
strategy is intended to provide a blend of portfolio appreciation and modest current income by
investing principally in equity securities, with a moderate exposure to fixed income.
• Balanced - The Balanced portfolio is appropriate for investors who have a medium-to-long
time horizon and a moderate tolerance for market volatility. This investment strategy is
intended to provide a blend of current income and portfolio appreciation by investing in a
balanced mix of fixed income securities and equities.
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• Conservative Balanced - The Conservative Balanced portfolio is appropriate for investors
who have a short-to-medium time horizon and modest tolerance for market volatility. This
investment strategy is intended to provide a higher level of current income by investing
primarily in fixed income securities with modest exposure to equity securities.
• Defensive Balanced - The Defensive Balanced portfolio is appropriate for investors who
have a relatively short time horizon and minimal tolerance for market fluctuations. This
investment strategy is intended to provide reduced volatility of principal and a high level of
current income by investing primarily in fixed income securities with a limited allocation to
equities.
The above-listed strategic asset allocation portfolios provide a general framework for constructing client
portfolios. Within that framework, Seneca Financial Advisors builds customized portfolios that consider
the unique circumstances, goals and objectives of each client and/or each individual account that a client
may have.
Seneca Financial Advisors uses a limited tactical asset allocation overlay in managing portfolios for its
clients. Each portfolio has a long-term strategic asset allocation target, and we modestly overweight or
underweight asset classes as perceived market risks or opportunities arise. The strategic allocation
serves as a foundation while the tactical overlay seeks to enhance returns by exploiting shorter-term
valuation disparities that may exist in certain asset classes.
Methods of Analysis
In building the strategic asset allocation portfolios, Seneca Financial Advisors will recommend investment
products that use various investment management styles. Blending mutual funds and ETFs with different
styles can provide diversification and harness some of the benefits of each method. Funds can also use
multiple methods of analysis in managing their portfolios. For example, Seneca Financial Advisors will,
from time to time, recommend investment products that use any, or multiple, of the following methods of
analysis. This is not intended to be an exhaustive list.
Fundamental - A method of evaluating a security by attempting to measure its intrinsic value by
examining related economic, financial and other qualitative and quantitative factors. Fundamental
analysts attempt to study everything that can affect the security's value, including macroeconomic factors
(like the overall economy and industry conditions) and individually specific factors (like the financial
condition and management of companies). The end goal of performing fundamental analysis is to
produce a value that an investor can compare with the security's current price in hopes of determining
what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Although
most analysts use fundamental analysis to value stocks, this method of valuation can be used for just
about any type of security.
Macroeconomic - An approach that considers the current stage of the business cycle and overall
economy, then chooses investments believed to be best suited for those conditions. For example, cyclical
companies tend to make products or provide services that are in lower demand during downturns in the
economy and higher demand during upswings. The stock price of a cyclical company will often rise just
before an economic upturn begins and will often fall just before a downturn begins. An investment
manager taking a macroeconomic approach might purchase cyclical stocks when they believe the
economic outlook is improving.
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Quantitative - An approach that uses mathematical inputs and computer modeling (optimization) to set
allocations, such as the historic correlations between the price or historic return of a potential investment
and the price of another asset, macroeconomic variable or other data. These strategies tend to be rigid
and disciplined, which can help to mitigate the impact of biases.
Passive - Passive investors attempt to produce the same return as their benchmark with as little “tracking
error” (month-to-month deviation from the benchmark) as possible. They can replicate the benchmark by
purchasing investments in the same proportion as their benchmark, they can purchase a representative
sample of the benchmark’s holdings, or they can use derivatives tied to the benchmark’s return. Passive
strategies tend to have very low fees, a lower risk of underperformance, and can be more tax efficient.
Risk of Loss
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients (including you) should never assume that future performance of any specific
investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds,
and bonds) involves risk of loss. Further, depending on the different types of investments there may be
varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss
including loss of original principal.
Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There
are certain additional risks associated when investing in securities through our investment management
program.
Market Risk – Either the stock market as a whole, or the value of an individual
company, goes down resulting in a decrease in the value of client investments.
This is also referred to as systemic risk.
Equity (stock) market risk – Common stocks are susceptible to general stock
market fluctuations and to volatile increases and decreases in value as market
confidence in and perceptions of their issuers change. If you held common stock,
or common stock equivalents, of any given issuer, you would generally be
exposed to greater risk than if you held preferred stocks and debt obligations of
the issuer.
Company Risk – When investing in stock positions, there is always a certain level
of company or industry specific risk that is inherent in each investment. This is
also referred to as unsystematic risk and can be reduced through appropriate
diversification. There is the risk that the company will perform poorly or have its
value reduced based on factors specific to the company or its industry. For
example, if a company’s employees go on strike or the company receives
unfavorable media attention for its actions, the value of the company may be
reduced.
Fixed Income Risk – When investing in bonds, there is the risk that the issuer will
default on the bond and be unable to make payments. Further, individuals who
depend on set amounts of periodically paid income face the risk that inflation will
erode their spending power. Fixed-income investors receive set, regular
payments that face the same inflation risk.
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Options Risk – Options on securities may be subject to greater fluctuations in
value than an investment in the underlying securities. Purchasing and writing put
and call options are highly specialized activities and entail greater than ordinary
investment risks.
ETF and Mutual Fund Risk – When Seneca Financial Advisors invests in an ETF
or mutual fund for a client, the client will bear additional expenses based on its
pro rata share of the ETF’s or mutual fund’s operating expenses, including the
potential duplication of management fees. The risk of owning an ETF or mutual
fund generally reflects the risks of owning the underlying securities the ETF or
mutual fund holds. Clients may also incur brokerage costs when purchasing
ETFs.
Management Risk – Your investment with our Firm varies with the success and
failure of our investment strategies, research, analysis and determination of
portfolio securities. If our investment strategies do not produce the expected
returns, the value of the investment will decrease.
Item 9 – Disciplinary Information
This item is not applicable to our brochure because there are no legal or disciplinary events listed at Item
9 of the Form ADV Part 2 instructions that are material to a client’s or prospective client’s evaluation of
our business or integrity.
Item 10 – Other Financial Industry Activities and Affiliations
Seneca Financial Advisors is not and does not have a related company that is a (1) broker/dealer,
municipal securities dealer, government securities dealer or broker, (2) investment company or other
pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment
trust, private investment company or “hedge fund,” and offshore fund), (3) other investment adviser or
financial planner, (4) futures commission merchant, commodity pool operator, or commodity trading
advisor, (5) banking or thrift institution, (6) accountant or accounting firm, (7) pension consultant, (8) real
estate broker or dealer, (9) sponsor or syndicator of limited partnerships, (10) insurance company, or (11)
law firm.
Third-Party Money Managers
As described in Item 5 – Fees and Compensation, we may recommend independent, third-party
investment advisors to serve as Sub-Advisors in our Asset Management services program.
Unlike other investment advisors, we do not receive a referral fee or solicitor fee from third-party money
managers we recommend for clients. The only compensation we receive is the management fee we
charge directly to our clients. Sub-Advisers will also bill clients directly, but our fees are completely
separate from the fee charged by Sub-Advisers (please refer to Item 5 for more details). This policy helps
us avoid selecting money managers based on our economic interests. Instead, we select money
managers we believe are most appropriate for our clients absent additional economic benefits we could
receive from a money manager.
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Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
The Investment Advisers Act of 1940 (“The Act”) imposes a fiduciary duty on investment advisers. As a
fiduciary, Seneca Financial Advisors has a duty of utmost good faith to act solely in the best interests of
its clients. Seneca Financial Advisors clients entrust Seneca Financial Advisors with their money and
financial future, which in turn places a high standard on the conduct and integrity of Seneca Financial
Advisors and its Employees. Seneca Financial Advisors’ fiduciary duty compels all Employees to act with
the utmost integrity in all of their dealings. This fiduciary duty is the core principle underlying this Code of
Ethics and Personal Trading Policy and represents the expected basis of all dealings with Seneca
Financial Advisors clients.
Standards of Conduct
This Code of Ethics and Personal Trading Policy consists of the following core principles and applies to
all Employees within Seneca Financial Advisors:
1) The interests of clients will be placed ahead of Seneca Financial Advisors’ or any Employee’s
own investment interests.
2) Employees are expected to conduct their personal securities transactions in accordance with
Seneca Financial Advisors’ Code of Ethics and Personal Trading Policy and will strive to avoid
any actual or perceived conflict of interest with the client. Employees with questions regarding the
appearance of a conflict with a client should consult with the Chief Compliance Officer (“CCO”)
before taking action that results in an actual conflict.
3) Employees will not take inappropriate advantage of their position within Seneca Financial
Advisors.
4) Employees are expected to act in the best interest of each client.
5) Employees are expected to comply with federal securities laws. Strict adherence to these policies
and other policies and procedures of Seneca Financial Advisors will assist the Employee in
complying with this important requirement.
As part of the required standards of conduct, Employees are not permitted, in connection with any
purchase or sale, directly or indirectly, of a security held or to be acquired by a client:
1) To defraud such client in any manner;
2) To mislead such client, including by making a statement that omits material facts;
3) To engage in any act, practice or course of conduct which operates or would operate as a fraud
or deceit upon such client;
4) To engage in any manipulative practice with respect to such client; or
5) To engage in any manipulative practice with respect to securities, including price manipulation.
As a fiduciary, Seneca Financial Advisors has an affirmative duty of care, loyalty, honesty, and good faith
to act in the best interests of its clients. Compliance with this duty can be achieved by trying to avoid
conflicts of interest and by fully disclosing all material facts concerning any conflict that does arise with
respect to any client.
A copy of Seneca Financial Advisors’ Code of Ethics and Personal Trading Policy is available to current
and potential clients upon request.
Seneca Financial Advisors serves as investment manager to numerous client accounts. The Firm
provides advice and takes action with respect to any account it manages, or for its own account, that may
differ from actions taken by Seneca Financial Advisors on behalf of other accounts. The Firm is not
obligated to recommend, buy or sell, or to refrain from recommending, buying or selling any security that
Seneca Financial Advisors, or its advisory persons, can buy or sell for its or their own account or for the
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accounts of any other client. The Firm is not obligated to refrain from investing in securities held by
accounts that it manages except to the extent that such investments violate the Code of Ethics and
Personal Trading Policy (“Code”) adopted by Seneca Financial Advisors in conformity with Rule 204A-1
under the Advisers Act. As a condition of employment, all Seneca Financial Advisors persons subject to
the Code (“Employees”) and certain other individuals as provided in the Code must certify that they have
read and understand the Code and agree to be subject to its provisions. As discussed below, the Code
contains provisions relating to personal transactions, insider trading and sets forth standards of business
conduct, including the requirement that Seneca Financial Advisors’ Employees adhere to the Federal
Securities Laws and their fiduciary duties as investment advisers. Any Employee of Seneca Financial
Advisors who fails to comply with the Code risks serious sanctions, including dismissal and personal
liability.
From time to time, the Firm and/or its Employees will have interests in securities owned by or
recommended to Seneca Financial Advisors’ clients. As these situations represent a conflict of interest,
Seneca Financial Advisors’ Code contains procedures relating to personal securities transactions and
insider trading that is designed to identify and mitigate or prevent conflicts of interest.
Seneca Financial Advisors’ Code includes a “Policy Statement on Insider Trading” in accordance with
Section 204A of the Investment Advisers Act which establishes procedures to prevent the misuse of
material nonpublic information by Seneca Financial Advisors and its officers, directors, trustees and
employees. Among other things, all Employees must read, sign and adhere to Seneca Financial Advisors’
policy on insider trading which reflects current securities law, including, but not limited to, the Insider
Trading and Securities Fraud Enforcement Act of 1988.
Affiliate and Employee Personal Securities Transactions Disclosure
Seneca Financial Advisors and its supervised persons can buy or sell securities or have an interest or
position in their personal account in a security that they also recommend to clients. As these situations
represent a conflict of interest, we have established several procedures to control for the conflict of
interest. These procedures are either in addition to or included as part of our Code of Ethics.
• Seneca Financial Advisors is and shall continue to be in compliance with The Insider Trading and
Securities Fraud Enforcement Act of 1988.
•
It is the policy of Seneca Financial Advisors that no supervised person shall prefer his or her own
interest to that of the advisory client.
• No person employed by Seneca Financial Advisors may purchase or sell any security prior to a
transaction or transactions being implemented for an advisory client account.
• Officers, Financial Advisors and Employees shall not buy or sell securities for their personal
account(s) where their decision is derived, in whole or in part, from information obtained as a
result of his/her employment unless the information is also available to the investing public upon
reasonable inquiry.
• Seneca Financial Advisors maintains a list of all securities holdings for itself and all Financial
Advisors and Employees, which is reviewed on a regular basis by a principal of the Firm.
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Item 12 – Brokerage Practices
Clients are under no obligation to act on the financial planning or investment consulting recommendations
of Seneca Financial Advisors. However, if the Firm assists in the implementation of any
recommendations, Seneca Financial Advisors is responsible to obtain for the client the best execution
possible, given all circumstances.
Clients wishing to implement the advice of Seneca Financial Advisors are free to select any broker/dealer
or investment advisor they wish and are so informed. For clients that wish to have the Firm implement its
advice, Seneca Financial Advisors will recommend that clients transfer their assets to Charles Schwab &
Co. Inc. (“Schwab”) or Fidelity Investments Inc. (“Fidelity”). Schwab and Fidelity are registered
broker/dealers and members of the Financial Industry Regulatory Association (FINRA) and the Securities
Investors Protection Corporation (SIPC).
Assets currently owned by the client can be transferred “in kind,” thus no portfolio adjustments need be
made until such time as Seneca Financial Advisors and the client decide they are needed. Seneca
Financial Advisors provides customized, comprehensive quarterly reports to clients, monitors asset
allocation of client assets and how assets are weighted among investment categories, as well as
maintains specific tax reporting records necessary at year-end should clients custody their assets at
Schwab and/or Fidelity. These services may not be available should clients choose a different custodian
for their assets. With the use of Schwab and Fidelity, clients may also implement their own investment
trades based on decisions reached with Seneca Financial Advisors and be able to view their accounts
online at their leisure. Clients who rely on Seneca Financial Advisors for their investment advice give
trading authority to Seneca Financial Advisors. This allows Seneca Financial Advisors to enter trades on
behalf of their clients.
Clients may pay higher commissions than those obtainable from other brokers in return for the products
and services provided by Schwab and/or Fidelity to Seneca Financial Advisors, although Seneca
Financial Advisors believes the charges imposed by these custodians are well within industry norms.
Seneca Financial Advisors will periodically evaluate current and potential custodians using criteria such
as overall expertise, cost competitiveness, and financial condition.
We do not receive client referrals from Schwab nor from Fidelity. Although we have not entered into
formal soft-dollar agreements with Schwab and Fidelity, Seneca Financial Advisors receives benefits that
are not received if Seneca Financial Advisors did not use the services of Schwab and Fidelity to
implement investment advice provided. These benefits include, but are not necessarily limited to receipt
of duplicate client confirmations and bundled duplicate statements, access to a trading desk, the ability to
have investment advisory fees deducted directly from client accounts, access to an electronic
communications network for client order entry and account information, receipt of compliance
publications, and access to mutual funds that generally require significantly higher minimum initial
investments or are generally only available to institutional investors. No single criteria will validate nor
invalidate a custodian, broker/dealer or service provider used, but rather, all criteria taken together will be
used in evaluating the currently utilized custodian.
While Seneca Financial Advisors and its Employees endeavor at all times to put the interest of the clients
first as part of Seneca Financial Advisors’ fiduciary duty, clients should be aware that Seneca Financial
Advisors receives benefits from Schwab and Fidelity. Any compensation and benefits received, whether
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cash or non-cash (such as research or technical support) creates a conflict of interest. However, we
believe benefits received are negligible and do not affect what investments Seneca Financial Advisors
recommends to clients. Services may, however, reduce the overall fees to clients as the additional
services allow our business to be run more efficiently.
Client Directed Brokerage Arrangements
Some clients instruct Seneca Financial Advisors to use one or more particular broker/dealers, other than
those recommend by the Firm, for the transactions in their accounts. Clients who want to direct Seneca
Financial Advisors to use a particular broker/dealer should understand that Seneca Financial Advisors
may be unable to effectively negotiate brokerage compensation on the client’s behalf. When directing
brokerage business, clients should consider whether the commission expenses and execution, clearance
and settlement capabilities that they will obtain through their broker/dealer are adequately favorable in
comparison to those that Seneca Financial Advisors would otherwise obtain for its clients. Clients with
client directed brokerage arrangements should also be aware that Seneca Financial Advisors is limited in
its trading ability (compared to platforms recommended by Seneca Financial Advisors) and may be
required to execute client directed trades after trades are implemented through accounts at platforms
recommended by Seneca Financial Advisors. Clients are encouraged to discuss available alternatives
with their Financial Advisor.
Trading Policy
Our trading policy is to implement the majority of client orders on an individual basis. Therefore, we do not
typically aggregate or “block” client transactions. Considering the types of investments we hold in
advisory client accounts, we do not believe clients are hindered in any way because we trade accounts
individually. The investments we are responsible for trading in client accounts are typically limited to
mutual funds and other broadly traded positions. Our strategies are primarily developed for the long-term
and minor differences in price execution are not material to our overall investment strategy.
However, in some cases when purchasing ETFs, we can decide to purchase or sell the same investment
for several clients at approximately the same time. This process is referred to as aggregating orders,
batch trading or block trading and can be used by Seneca Financial Advisors. If Seneca Financial
Advisors chooses to aggregate client orders, the allocation of securities among client accounts will be
done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to
achieve better execution, to negotiate more favorable commission rates or to allocate orders among
clients on a more equitable basis in order to avoid differences in prices and transaction fees or other
transaction costs that might be obtained when orders are placed independently. Under this procedure,
transactions will be averaged as to price and will be allocated among Seneca Financial Advisors clients in
proportion to the purchase and sale orders placed by an individual Seneca Financial Advisors investment
advisor representative for each client account on any given day. When Seneca Financial Advisors
determines to aggregate client orders for the purchase or sale of securities, including securities in which
an associated person of Seneca Financial Advisors may invest, Seneca Financial Advisors will do so in
accordance with the parameters set forth by applicable regulatory guidance. It should be noted, Seneca
Financial Advisors does not receive any additional compensation or remuneration as a result of
aggregation.
Trade Errors
Based on industry practice and SEC guidance to broker-dealers, a trade error under this policy is defined
as including:
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•
Inaccurate transmission or execution of any term of an order including, but not limited to price;
number of shares or other unit of trading; identification of the security; identification of the account
for which securities are purchased or sold; short sales that were instead sold long or vice versa;
or the execution of an order on the wrong side of a market;
• Unauthorized (because of misunderstanding or mistake) or unintended purchase, sale or
allocation of securities, or the failure to follow specific client instructions; and
•
Incorrect entry of data into relevant systems, including reliance on incorrect cash positions,
withdrawals or securities positions reflected in an account.
Seneca Financial Advisors has implemented procedures designed to prevent trade errors; however, trade
errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of
Seneca Financial Advisors to correct trade errors in a manner that is in the best interest of the client. In
cases where the client causes the trade error, the client will be responsible for any loss resulting from the
correction. Depending on the specific circumstances of the trade error, the client may not be able to
receive any gains generated as a result of the error correction. In all situations where the client does not
cause the trade error, the client will be made whole and any loss resulting from the trade error will be
absorbed by Seneca Financial Advisors if the error was caused by the Firm. If the error is caused by the
broker-dealer, the broker-dealer will be responsible for covering all trade error costs. If an investment gain
results from the correcting trade, the gain will remain in the client’s account unless the same error
involved other client accounts that should also receive the gains and it is not permissible for all clients to
retain the gain. Seneca Financial Advisors may also confer with clients to determine if the client should
forego the gain (e.g., for tax reasons).
Seneca Financial Advisors will never benefit or profit from trade errors.
Item 13 – Review of Accounts
Account Reviews and Reviewers
Reviewers for financial planning, investment consulting and investment management services will be one
or more of the following individuals: Steve Green, Scott Lefebre, Zach Erskine, Kathy Raabe, and Matt
Darcy. For details on their education and experience, please refer to the Information Required by Part 2B
of Form ADV: Brochure Supplement section of this Disclosure Brochure.
All reviews follow the client objectives, asset allocation and risk tolerance as agreed upon with the client.
These objectives and parameters are confirmed with the client on at least an annual basis. Reviews are
performed at least semi-annually for most clients. Additional reviews may be triggered by a major market
occurrence, economic event or a change in the client’s circumstances. Reports and their frequency will
vary by client depending on the services provided.
Statements and Reports
Clients will receive statements at least quarterly from the custodian at which their accounts are
maintained. Seneca Financial Advisors may also provide performance or position reports to clients on a
quarterly or on-demand basis. Clients are urged to compare all reports provided by the Firm against the
account statements received from the qualified custodian which are provided to clients directly from the
qualified custodian at least quarterly.
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Item 14 – Client Referrals and Other Compensation
Referrals to Unaffiliated Third-Parties
Depending on the individual circumstances of a client and the client’s need for services beyond those
provided by Seneca Financial Advisors, an associated person of Seneca Financial Advisors may refer the
client to an unaffiliated, third-party financial or other professional firm. Such professionals can include, but
are not limited to, certified public accountants, law firms, insurance agents, and other securities
professionals (i.e., other financial planners and investment advisors).
Other Professional Firms
We do not have a formal, written agreement with any unaffiliated third party to which we refer clients and
do not receive any form of compensation (i.e., no fee sharing or referral fee payment arrangements exist)
for such referrals. Clients are not obligated in any manner to use the services of a firm recommended by
Seneca Financial Advisors. If clients agree to use a referred party’s services, clients will enter into an
agreement directly with the third party and will pay fees for services rendered by the third party directly to
the third party. Fees charged by third parties are separate from the fees charged by Seneca Financial
Advisors. Seneca Financial Advisors only refers clients to third parties that are properly registered or
exempt from registration in their profession as necessary.
In addition, Seneca Financial Advisors can receive from unaffiliated third-party firms, referrals of potential
clients that are in need of financial planning or other advisory services offered by Seneca Financial
Advisors. Seneca Financial Advisors does not compensate any third party for client referrals and clients
referred to Seneca Financial Advisors are not obligated in any way to engage Seneca Financial Advisors
for its services.
Other Compensation
The only direct form of other compensation received from advisory services are the fees charged for
providing investment advisory and financial planning services as described in Item 5 of this brochure.
While Seneca Financial Advisors and its employees endeavor at all times to put the interest of the clients
first as part of Seneca Financial Advisors’ fiduciary duty, clients should be aware that Seneca Financial
Advisors can receive non-cash compensation from vendors recommended by Seneca Financial Advisors.
Any non-cash compensation received is negligible and does not affect what investments Seneca
Financial Advisors recommends to clients. It may, however, reduce Seneca Financial Advisors’ overall
fees to clients as the additional services allow the business to be run more efficiently. Any compensation
received, whether cash or non-cash (such as research or technical support) can create a conflict of
interest.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or control
over client funds and/or securities. In other words, custody is not limited to physically holding client funds
and securities. If an investment advisor has the ability to access or control client funds or securities, the
investment advisor is deemed to have custody and must ensure proper procedures are implemented.
Seneca Financial Advisors is deemed to have custody of client funds and securities whenever the Firm is
given the authority to have fees deducted directly from client accounts.
In addition, there are a small number of Seneca Financial Advisors client arrangements where Steve
Green, Scott Lefebre, and Zach Erskine, in their individual capacity, serve as trustee for the client. The
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role of trustee is imputed (or “assigned”) to Seneca Financial Advisors and therefore we are deemed to
have custody of the trust client funds and securities.
Our personnel’s trustee clients are billed on a fixed fee or on an hourly-fee basis for their trustee services
depending on the scope and depth of trustee services provided. Fees charged by our personnel for
trustee services are detailed and agreed upon with each client before our personnel, acting in their
individual capacity separate from Seneca Financial Advisors, assume trustee responsibilities. Fees
charged for trustee services are separate from the fees charged for investment advisory services
provided by Seneca Financial Advisors and any fees that are charged for trustee services are paid
directly to the trustee. Please refer to Item 5 for details of our investment advisory fee arrangements. Our
advisor personnel serving as trustees share in the investment advisory fees received by Seneca Financial
Advisors in addition to any fees received by the trustee for services as trustee. Grantors or beneficiaries
of a trust which is appointing one of our personnel as trustee are required to acknowledge in writing our
advisory personnel’s receipt of any trustee fees.
Responsibilities as trustee include administering the trust in accordance with the terms and conditions of
the trust instrument and applicable laws under the trust’s stated domicile. Our personnel serving as
trustee will always fully respect the traditional duties of trusteeship such as the obligation of loyalty, good
faith, prudence, and impartiality in the administration of the trust corpus. Our personnel serving as trustee
will always strive to treat beneficiaries fairly and shall keep and render clear and accurate accounting
records. Disclosure of the trust, trust terms and trust corpus to third parties is limited to the trustee’s
reasonable discretion. Our personnel serving as trustee shall act in accordance with the terms of the trust
and shall continue, at all times, to exercise independent discretionary management of the trust estate.
There are also a small number of Seneca Financial Advisors client arrangements where the Firm has
been authorized by the client to disburse or transfer client funds to a client-designated third party via
Standing Letter of Authorization (“SLOA”). Having the authority to disburse money to a third party on a
client’s behalf pursuant to a SLOA constitutes custody.
For accounts in which Seneca Financial Advisors is deemed to have custody, the Firm has established
procedures to ensure all client funds and securities are held at a qualified custodian in a separate account
for each client under that client’s name. Clients, or an independent representative of the client, will direct
in writing the establishment of all accounts and therefore are aware of the qualified custodian’s name,
address and the manner in which the funds or securities are maintained. Finally, account statements are
delivered directly from the qualified custodian to each client, or the client’s independent representative, at
least quarterly. Clients should carefully review those statements and are urged to compare the
statements against reports received directly from Seneca Financial Advisors. When clients have
questions about their account statements, they should contact Seneca Financial Advisors or the qualified
custodian preparing the statement. Finally, trustee-arrangement accounts, as well as SLOAs to third
parties, are subject to an annual surprise verification examination conducted by a third-party, independent
accounting firm.
Item 16 – Investment Discretion
Upon receiving written authorization from the client, Seneca Financial Advisors may provide
discretionary investment advisory services for client accounts. When discretionary authority is granted,
Seneca Financial Advisors will have the authority to determine the type of securities and the amount of
securities that can be bought or sold for the client portfolio without obtaining the client’s consent for each
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transaction. Discretionary authority, along with any limitations to such discretionary authorization, will be
granted by client in Seneca Financial Advisors’ client agreement.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact
you prior to implementing changes in your account. Therefore, you will be contacted and required to
accept or reject our investment recommendations including:
• The security being recommended
• The number of shares, units or dollar value
• Whether to buy or sell
Once the above factors are agreed upon, Seneca Financial Advisors will be responsible for making
decisions regarding the timing of buying or selling an investment and the price at which the investment is
bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if you
are not able to be reached or are slow to respond to our request, it can have an adverse impact on the
timing of trade implementations, and we may not achieve the optimal trading price.
Clients may elect to implement the recommendations provided by Seneca Financial Advisors and enter
their own trades.
All clients have the ability to place reasonable restrictions on the types of investments that may be
purchased in an account. Clients may also place reasonable limitations on the discretionary power
granted to our Firm so long as the limitations are specifically set forth or included as an attachment to the
client agreement.
Item 17 – Voting Client Securities
Seneca Financial Advisors does not perform proxy voting services on a client’s behalf. Clients are
instructed to read through the information provided with the proxy voting documents and to make a
determination based on the information provided. Upon request from a client, the Firm may provide
limited clarifications of the issues presented in the proxy voting materials based on Seneca Financial
Advisors’ understanding of issues presented in the proxy voting materials. However, clients have the
ultimate responsibility for making all proxy voting decisions.
Clients will receive proxies directly from their custodian or transfer agent and such documents will not be
delivered by our Firm. Although we do not vote client proxies, if you have a question about a particular
proxy feel free to contact us.
Item 18 – Financial Information
This item is not applicable to this brochure. Seneca Financial Advisors does not require or solicit
prepayment of more than $1,200 in fees per client, six months or more in advance (A client may be billed
more than $1,200 per invoice, but it will be for work that has already been performed or will be delivered
in less than 6 months). Therefore, Seneca Financial Advisors is not required to include a balance sheet
for our most recent fiscal year. Seneca Financial Advisors is not subject to a financial condition that is
reasonably likely to impair its ability to meet contractual commitments to clients. Finally, Seneca Financial
Advisors has not been the subject of a bankruptcy petition at any time.
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CUSTOMER PRIVACY POLICY
Seneca Financial Advisors maintains a commitment to confidentiality and privacy of client information. We
are committed and bound to do so as a matter of trust between clients and the employees of Seneca
Financial Advisors.
Please be kind enough to read our privacy policy below to learn more about how we treat and safeguard
the personally identifiable financial information of our clients and former clients.
When we use the words "you" and "your" in this statement, we mean current or former clients who have
or have had a continuing client relationship with Seneca Financial Advisors. "Nonpublic personal
information" means information about you that we collect in connection with providing you our services.
Nonpublic personal information does not include information that is available from public sources such as
real estate records and telephone directories.
How We Gather Information
We collect nonpublic personal information about you to enable us to provide you with our services. We
collect information furnished by you on account applications or other forms you submit. The information is
collected from you in a variety of ways including in written form, by telephone, through information you
provide or direct us to obtain for tax and financial planning organizers, through electronic means such as
e-mail and in the course of your personal consultations, interviews and contacts with our employees. For
example, we may collect nonpublic personal information from other companies or professionals you may
retain such as fiduciaries, accountants and other investment advisors. We collect such information so that
we can effectively provide the services required by you. The information we collect may include your
name, address, telephone and facsimile numbers, email addresses, Social Security number or tax
identification number, and investment objectives. Once you have opened an account, we administer your
account by collecting and maintaining personal information about your transactions including balances,
positions and account history.
Restrictions on Disclosure of Non-Public Personal Information
We do not disclose any non-public personal information about our clients or former clients to anyone,
except as permitted by law. Unless a client has specifically authorized us to do so, we do not disclose
your personal information to others except in three limited circumstances.
• From time to time, Seneca Financial Advisors may choose to hire independent contractors to
assist with various Financial Advisory and Investment Consulting Services provided through the
client engagement. Seneca Financial Advisors may, therefore, share client information with such
contractors if it is deemed necessary and appropriate in connection with the work performed.
• We disclose personal information to non-affiliated co-advisers, brokers and other agents,
including Charles Schwab & Company, Inc., Fidelity Investments Inc., and other custodians, to
help us provide advisory services, process your transactions and service your accounts. We may
also provide your information to vendors providing data processing, computer software
maintenance and development, compliance and legal consulting, and other general business
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consulting services. These vendors are required to sign a nondisclosure agreement agreeing to
maintain the confidentiality of all non-public personal information.
• We may also disclose personal information if we believe in good faith that such disclosure is
required to comply with applicable laws, such as cooperating with regulators, or to resolve
consumer disputes.
Our Security Practices
We will take steps to safeguard your non-public personal information. For example, we restrict access to
non-public personal information of clients and former clients to those employees who need to know that
information in the course of their responsibilities with the Firm. We maintain physical, electronic and
procedural safeguards to guard your information.
Other Information
The examples contained within this Privacy Policy are illustrations; they are not intended to be exclusive.
We also reserve the right to change this Privacy Policy, and any other policies described above, at any
time.
Should you have any questions, please contact your Financial Advisor at the address and/or phone
number provided on the cover page of this Disclosure Brochure.
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Information Required by Part 2B of Form ADV: Brochure Supplement
Steve Green, Member, Chief Executive Officer, and Financial Advisor
Item 1 – Cover Page
This brochure supplement provides information about Steve Green that supplements the information
previously provided in this brochure. Please contact Mr. Green if you have any questions about the
contents of this supplement. Additional information about Mr. Green is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Born: 1972
Education Background:
• Attended University of Buffalo from 1990 to 1991
• Graduated from LeMoyne College in 1995 with a B.A. in Economics
Business Background & Other Business Activity:
• Member and Financial Advisor for Seneca Financial Advisors from 02/2010 to present, Chief
Executive Officer for Seneca Financial Advisors from 01/2024 to present, Chief Investment
Officer for Seneca Financial Advisors from 02/2010 to 12/2023, and Chief Compliance Officer for
Seneca Financial Advisors from 02/2010 to 02/2021;
• Financial Advisor and Investment Committee Member for Nixon Peabody Financial Advisors LLC
from 11/2000 to 01/2010; and
• Financial Services Analyst with Nixon Peabody LLP from 06/1996 to 01/2010.
Item 3 – Disciplinary Information
Mr. Green has never been subject to a legal or disciplinary event required to be reported by the Form
ADV Part 2B – Brochure Supplement instructions.
Item 4 – Other Business Activities
Mr. Green is not engaged in any business activities outside of his role with Seneca Financial Advisors.
Item 5 – Additional Compensation
Mr. Green does not receive compensation in addition to the fees described in Item 5 and Item 15 and
benefits described in Item 14 of this Disclosure Brochure.
Item 6 – Supervision
Matt Darcy is the Chief Compliance Officer of Seneca Financial Advisors and ultimately responsible for
supervising activities and services provided by the Firm including the services provided by Mr. Green.
Investment accounts and the advice provided by Mr. Green are reviewed by Mr. Darcy on an on-going
basis. Mr. Darcy can be contacted at 585-203-1211 x118.
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Scott Lefebre, Member, Managing Director of Business Development, and Financial Advisor
Item 1 – Cover Page
This brochure supplement provides information about Scott Lefebre that supplements the information
previously provided in this brochure. Please contact Mr. Lefebre if you have any questions about the
contents of this supplement. Additional information about Mr. Lefebre is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Born: 1969
Education Background:
• Graduated from University of Nevada in 1993 with a B.S. in Accounting
Business Background & Other Business Activity:
• Member and Financial Advisor for Seneca Financial Advisors from 02/2010 to present and
Managing Director of Business Development for Seneca Financial Advisors from 01/2024 to
present;
• Financial Advisor and Investment Committee Member for Nixon Peabody Financial Advisors LLC
from 01/2008 to 01/2010;
• Financial Services Analyst with Nixon Peabody LLP from 01/2007 to 01/2010;
• Professional Specialist at Nixon Peabody LLP from 01/2000 to 01/2010;
• Audit Agent with State of Nevada Gaming Control Board from 07/1995 to 12/1999; and
• Staff Accountant with Constance M. Lentz, CPA, Ltd. from 11/1993 to 07/1995.
Professional Designations
Mr. Lefebre has earned the following professional designations.
1.
Certified Public Accountant (CPA)
CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations
vary, the education, experience and testing requirements for licensure as a CPA generally include
minimum college education (typically 150 credit hours with at least a baccalaureate degree and a
concentration in accounting), minimum experience levels (most states require at least one year of
experience providing services that involve the use of accounting, attest, compilation, management
advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision
of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to
maintain a CPA license, states generally require the completion of 40 hours of continuing professional
education (CPE) each year (or 80 hours over a two-year period or 120 hours over a three-year period).
Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to
follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due
care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists),
maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public
interest when providing financial services.
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2.
Personal Financial Specialist (PFS)
The Personal Financial Specialist (PFS) credential demonstrates that an individual has met the minimum
education, experience and testing required of a CPA in addition to a minimum level of expertise in
personal financial planning. To attain the PFS credential, a candidate must hold an unrevoked CPA
license, certificate, or permit, none of which are in inactive status; fulfill 3,000 hours of personal financial
planning business experience; complete 75 hours of personal financial planning CPE credits; pass a
comprehensive financial planning exam and be an active member of the AICPA. A PFS credential holder
is required to adhere to AICPA’s Code of Professional Conduct and the Statement on Standards in
Personal Financial Planning Services, when providing personal financial planning services. To maintain
their PFS credential, the recipient must complete 60 hours of financial planning CPE credits every three
years. The PFS credential is administered through the AICPA.
Item 3 – Disciplinary Information
Mr. Lefebre has never been subject to a legal or disciplinary event required to be reported by the Form
ADV Part 2B – Brochure Supplement instructions.
Item 4 – Other Business Activities
Mr. Lefebre is not engaged in any business activities outside of his role with Seneca Financial Advisors.
Item 5 – Additional Compensation
Mr. Lefebre does not receive compensation in addition to the fees described in Item 5 and Item 15 and
benefits described in Item 14 of this Disclosure Brochure.
Item 6 – Supervision
Matt Darcy is the Chief Compliance Officer of Seneca Financial Advisors and ultimately responsible for
supervising activities and services provided by the Firm including the services provided by Mr. Lefebre.
Investment accounts and the advice provided by Mr. Lefebre are reviewed by Mr. Darcy on an on-going
basis. Mr. Darcy can be contacted at 585-203-1211 x118.
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Zach Erskine, Member and Financial Advisor
Item 1 – Cover Page
This brochure supplement provides information about Zach Erskine that supplements the information
previously provided in this brochure. Please contact Mr. Erskine if you have any questions about the
contents of this supplement. Additional information about Mr. Erskine is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Born: 1987
Education Background:
• Graduated from Rensselaer Polytechnic Institute in 2010 with a dual B.S. in Management
Information Systems and Economics
• Completed the College for Financial Planning, CFP® Professional Education Program in 2015.
Business Background & Other Business Activity:
• Member for Seneca Financial Advisors from 01/2024 to present, Financial Advisor for Seneca
Financial Advisors from 01/2016 to present, Investment Committee Member for Seneca Financial
Advisors from 07/2011 to present, and Financial Analyst for Seneca Financial Advisors from
07/2011 to 12/2015.
Professional Designations
Mr. Erskine has earned the following professional designations.
1.
Certified Financial Planner™ professional
The CERTIFIED FINANCIAL PLANNER™ and CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by
Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries
for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice;
and (3) ethical requirements that govern professional engagements with clients. Currently, more than
62,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a Bachelor’s Degree
from a regionally accredited United States college or university (or its equivalent from a foreign
university). CFP Board’s financial planning subject areas include insurance planning and risk
management, employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
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• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or
the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Item 3 – Disciplinary Information
Mr. Erskine has never been subject to a legal or disciplinary event required to be reported by the Form
ADV Part 2B – Brochure Supplement instructions.
Item 4 – Other Business Activities
Mr. Erskine is not engaged in any business activities outside of his role with Seneca Financial Advisors.
Item 5 – Additional Compensation
Mr. Erskine does not receive compensation in addition to the fees described in Item 5 and Item 15 and
benefits described in Item 14 of this Disclosure Brochure.
Item 6 – Supervision
Matt Darcy is the Chief Compliance Officer of Seneca Financial Advisors and ultimately responsible for
supervising activities and services provided by the Firm including the services provided by Mr. Erskine.
Investment accounts and the advice provided by Mr. Erskine are reviewed by Mr. Darcy on an on-going
basis. Mr. Darcy can be contacted at 585-203-1211 x118.
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Kathy Raabe, Member and Financial Advisor
Item 1 – Cover Page
This brochure supplement provides information about Kathy Raabe that supplements the information
previously provided in this brochure. Please contact Ms. Raabe if you have any questions about the
contents of this supplement. Additional information about Ms. Raabe is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Born: 1959
Education Background:
• Graduated from The American University in Washington, D.C. in 1981 with a B.A. in Economics
and International Relations with a Minor in Business
Business Background & Other Business Activity:
• Member for Seneca Financial Advisors from 01/2024 to present, Financial Advisor and
Investment Committee Member for Seneca Financial Advisors from 10/2020 to present, and Chief
Compliance Officer for Seneca Financial Advisors from 01/2024 to 12/2024;
• Senior Wealth Advisor for Frontier Wealth Management LLC from 02/2020 to 10/2020;
• Portfolio Manager for Highwater Wealth Management LLC from 09/2014 to 01/2020; and
• Portfolio Manager for Capital Investment Counsel Inc. from 10/2003 to 09/2014.
Professional Designations
Ms. Raabe has earned the following professional designations.
1.
Certified Financial Planner™ professional
The CERTIFIED FINANCIAL PLANNER™ and CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by
Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries
for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice;
and (3) ethical requirements that govern professional engagements with clients. Currently, more than
62,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services and attain a Bachelor’s Degree
from a regionally accredited United States college or university (or its equivalent from a foreign
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university). CFP Board’s financial planning subject areas include insurance planning and risk
management, employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or
the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Item 3 – Disciplinary Information
Ms. Raabe has never been subject to a legal or disciplinary event required to be reported by the Form
ADV Part 2B – Brochure Supplement instructions.
Item 4 – Other Business Activities
Ms. Raabe is not engaged in any business activities outside of her role with Seneca Financial Advisors.
Item 5 – Additional Compensation
Ms. Raabe does not receive compensation in addition to the fees described in Item 5 and benefits
described in Item 14 of this Disclosure Brochure.
Item 6 – Supervision
Matt Darcy is the Chief Compliance Officer of Seneca Financial Advisors and ultimately responsible for
supervising activities and services provided by the Firm including the services provided by Ms. Raabe.
Investment accounts and the advice provided by Ms. Raabe are reviewed by Mr. Darcy on an on-going
basis. Mr. Darcy can be contacted at 585-203-1211 x118.
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Matt Darcy, Member, Chief Investment Officer, and Chief Compliance Officer
Item 1 – Cover Page
This brochure supplement provides information about Matt Darcy that supplements the information
previously provided in this brochure. Please contact Mr. Darcy if you have any questions about the
contents of this supplement. Additional information about Mr. Darcy is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Born: 1994
Education Background:
• Graduated Cum Laude from Siena College in 2015 with a B.S. in Finance
Business Background & Other Business Activity:
• Member and Chief Investment Officer for Seneca Financial Advisor from 01/2024 to present,
Chief Compliance Officer for Seneca Financial Advisor from 01/2025 to present, Investment
Adviser Representative for Seneca Financial Advisors from 03/2023 to present, Investment
Committee Member for Seneca Financial Advisors from 09/2017 to present, Portfolio Manager for
Seneca Financial Advisors from 08/2021 to 12/2023, Investment Analyst for Seneca Financial
Advisors from 09/2017 to 08/2021, and Investment Intern for Seneca Financial Advisors from
06/2017 to 09/2017;
• Receipts and Distribution Specialist for KeyBank National Association from 03/2016 to 06/2017;
•
and
Intern for Alesco Advisors from 05/2015 to 07/2015
Professional Designations
Mr. Darcy has earned the following professional designations.
1.
Chartered Financial Analyst® Charterholder
The CFA designation is globally recognized and attests to a charterholder’s success in a rigorous and
comprehensive study program in the field of investment management and research analysis.
CFA® and Chartered Financial Analyst® are registered trademarks owned by CFA Institute. To attain the
right to use the CFA® marks, an individual must Pass a three-part exam, each part covering a wide range
of investment topics, with increasing levels of complexity. It is generally recommended that candidates
spend at least 300 hours studying for each of the 3 levels. The individual must also achieve qualified work
experience in a role that is directly involved in the investment decision-making process or adds value to
that process.
Charterholders are required to maintain a membership with the CFA Institute and a local CFA society,
which provides access to networking and educational events. Members must submit a professional
conduct statement annually and attest that they will follow the CFA Institute Code of Ethics and Standards
of Professional Conduct.
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Item 3 – Disciplinary Information
Mr. Darcy has never been subject to a legal or disciplinary event required to be reported by the Form
ADV Part 2B – Brochure Supplement instructions.
Item 4 – Other Business Activities
Mr. Darcy is not engaged in any business activities outside of her role with Seneca Financial Advisors.
Item 5 – Additional Compensation
Mr. Darcy does not receive compensation in addition to the fees described in Item 5 and benefits
described in Item 14 of this Disclosure Brochure.
Item 6 – Supervision
Matt Darcy is the Chief Compliance Officer of Seneca Financial Advisors and ultimately responsible for
supervising activities and services provided by the Firm. Investment accounts and investment programs
are reviewed as frequently as weekly. Mr. Darcy is responsible for monitoring investment accounts under
his control but actively seeks the assistance of other Seneca Financial Advisors investment advisor
representatives when needed.
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