SEVENTWO LLC

I T E M 1 – C O V E R P A G E SevenTwo LLC 100 Fillmore Street, 5th Floor Denver, CO 80206 Phone: (720) 477-7274 | Website: https://www.7Two.co Form ADV Part 2A Brochure June 2, 2025 This brochure provides information about the qualifications and business practices of SevenTwo LLC (“7Two”). If you have any questions about the contents of this brochure, please contact us at 720-477-7274. 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. 7Two is a Registered Investment Adviser. Registration as an Investment Adviser with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about 7Two is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD number. The IARD number for 7Two is CRD #328900. 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  I T E M 2 – M A T E R I A L C H A N G E S MATERIAL CHANGES SINCE THE LAST ANNUAL UPDATE SevenTwo LLC was established as a new Registered Investment Adviser in July 2024 with the Securities and Exchange Commission (“SEC”), under the rules and regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act"). 7Two will provide updates to this document annually within 120 days of the close of the fiscal year, or more frequently in the event of material changes. The following material changes have been made to this Disclosure Brochure since our annual amendment filed on January 15, 2025 with the SEC: • The Adviser is the sponsor of special purpose investment vehicles, which may be offered to Clients. Please see Item 10 below. • The Adviser has been engaged as a Promoter through an agreement with a third party registered investment adviser. Please see Item 14 below. ANNUAL UPDATE The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at 720-477-7274. 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  I T E M 3 – T A B L E O F C O N T E N T S Item 1 – Cover Page ........................................................................................................................................................................................................................ 1 Item 2 – Material Changes ....................................................................................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................................................................................... 3 Item 4 – Advisory Business ...................................................................................................................................................................................................... 4 Item 5 – Fees and Compensation ...................................................................................................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................................................... 12 Item 7 – Types of Clients ......................................................................................................................................................................................................... 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................................... 13 Item 9 – Disciplinary Information ...................................................................................................................................................................................... 18 Item 10 – Other Financial Industry Activities and Affiliations.................................................................................................................... 18 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 20 Item 12 – Brokerage Practices ......................................................................................................................................................................................... 21 Item 13 – Review of Accounts ........................................................................................................................................................................................23 Item 14 – Client Referrals and Other Compensation ......................................................................................................................... 24 Item 15 – Custody..................................................................................................................................................................................................................... 25 Item 16 - Discretion ................................................................................................................................................................................................................ 26 Item 17 – Voting Client Securities ............................................................................................................................................................................27 Item 18 – Financial Information ...................................................................................................................................................................................27 3 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  I T E M 4 – A D V I S O R Y B U S I N E S S SevenTwo LLC (“7Two” or the “Adviser”) is a registered investment Adviser with the U.S. Securities and Exchange Commission (“SEC”). We are organized as a Limited Liability Company (“LLC”) under the laws of the State of Colorado. 7Two was founded in December 2023 and is owned by Harbour Partners LLC, Seven Two Partners LLC, MoyBridge, LLC, and Black Sage Holdings, LLC. The Principal Officers of the Adviser are Andrew N. Macken (Managing Partner), Nicholas J. Rotello (Managing Partner), Ryan P. Ritchie (Managing Partner), Marc S. Bathgate (Managing Partner) and Vicki M. Denhoffer (Chief Operating Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by 7Two. For information regarding this Disclosure Brochure, please contact Vicki M. Denhoffer (Chief Operating Officer and Chief Compliance Officer) at (720) 477-7274. Prior to engaging 7Two to provide investment advisory services, each Client is required to enter into one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities of the Adviser and the Client. These services may include: • Establishing an Investment Strategy – 7Two, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – 7Two will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – 7Two will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Advisory and Supervision – 7Two will provide investment Advisory and ongoing oversight of the Client’s investment portfolio. INVESTMENT ADVISORY SERVICES 7Two provides investment advisory solutions for its Clients. 7Two works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. 7Two will then construct an investment portfolio, consisting of low-cost, diversified mutual funds, exchange-traded funds (“ETFs”), and alternative investments to achieve the Client’s investment goals. The Adviser may also utilize individual stocks, bonds, or options contracts to meet the needs of its Clients. The Adviser may utilize private investments created by affiliates of the Adviser and may also utilize SPVs to make loans, investment directly into companies, and/or invest in limited partnership interests of certain pooled investment vehicles or private funds. The Adviser may retain certain legacy investments based on portfolio fit and/or tax considerations. In personal discussions with Clients, 7Two determines their objectives, time horizons, risk tolerance and liquidity and income needs. As appropriate, 7Two may also review their prior investment history, as well as family composition and background. Based on client needs, 7Two develops the Client’s personal investment portfolio. It is the Client’s obligation to notify 7Two immediately in writing if their circumstances have changed with respect to their risk tolerance, liquidity needs, investment preferences, and goals. As determined through 7Two’s initial due diligence with the client, 7Two will determine if clients are seeking an actively managed investment strategy for their account(s). 7Two will provide ongoing investment review and management services. This approach requires 7Two to periodically review client portfolios. 4 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  7Two manages advisory accounts on a discretionary basis. For discretionary accounts, once 7Two determine a Client’s profile, income need, and investment plan, 7Two executes the day-to-day transactions without prior consent. Account supervision is guided by the client’s objectives, time horizons, risk tolerance, liquidity and income needs. 7Two may accept accounts with certain restrictions if circumstances warrant. 7Two primarily allocate client assets among various mutual funds, exchange- traded funds (“ETFs”), alternative investments, interval funds, cash, individual debt (bonds) and equity securities in accordance with their stated investment objectives. With the discretionary relationship, 7Two will make changes to the portfolio, as appropriate, to meet the Clients’ financial objectives. 7Two trades these portfolios based on the combination of 7Two’s market views and Clients’ objectives, using 7Two’s investment philosophy and strategies as described in Item 8 of this Brochure. 7Two tailors the advisory services to meet the needs of the Clients and seek to ensure that Client portfolios are managed in a manner consistent with those needs and objectives. Clients will have the ability to leave standing instructions with 7Two in writing to refrain from investing in particular industries or invest in limited amounts of securities. Where appropriate, 7Two may utilize interval funds in client portfolios. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Certain Traded Interval Funds can be purchased by 7Two directly with the Client’s custodian without any prior authorization from the client. In these cases, 7Two will purchase these interval funds on a discretionary basis only when it deems the investments to be suitable for the Client. In other cases, certain Non-Traded Interval Funds require the Client to execute fund documents in order to invest. In these situations, 7Two will not be able to purchase the Non-Traded Interval Funds on a discretionary basis. Both Traded and Non-Traded Interval Funds are subject to all of the risks and limitations outlined in Item 8 below. In certain cases, 7Two can recommend that a portion of the Client’s assets be invested in certain private investment funds, also known as private placements. Such funds are described as hedge funds, real estate funds, private equity funds, venture capital funds, and other types of private pooled investment vehicles (collectively “Private Funds”). Depending on the type of fund, the Private Funds will invest in various types of investments, many of which are not exchange traded. When determining which Clients should receive a recommendation to invest in a Private Fund, 7Two considers many factors, including, but not limited to, the Client’s investment sophistication, risk tolerances and qualifications, investment objectives, liquidity needs, and the amount of available assets in the Client's account(s). 7Two’s goal is to allocate in a fair and balanced manner; however, given these differing factors, the allocation of investment opportunities in Private Funds to Clients is mainly subjective, and not all qualifying Clients will be provided a particular private investment opportunity. For those Clients that receive a recommendation to invest in Private Funds, it is important to read each offering document (e.g., private placement memorandum) prior to investing to fully understand the risks and potential conflicts of interest pertaining to the Private Fund investment. (Please refer to Item 12 for further information on the allocation of Private Fund investments). Notably, some of the Private Funds, mutual funds and ETFs selected by 7Two will employ alternative or riskier strategies (e.g., the use of leverage or derivatives). Leverage is the use of debt to finance an activity. A private fund facilitating the purchase of a company using a line of credit or a hedge fund using proceeds from shorting to make more investments are examples of leverage. Derivatives can, in certain instances, be riskier than other types of investments because they can be more sensitive to changes in economic or market conditions than other types of investments. Derivatives also typically have a limited duration, 5 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  unlike owning a company’s shares directly. In certain situations, derivatives can result in losses that exceed the original investment. The use of derivatives, leverage, or other alternative strategies may not be successful, resulting in investment losses, and the cost of such strategies can reduce investment returns. Hedging, on the other hand, occurs when an investment is made in order to reduce the risk of adverse price movements in a security. For example, an investor could hedge a long position by shorting the same or similar security. Clients should review these, and other, considerations carefully prior to investing. Clients should also refer to Item 8 for detailed information regarding the 7Two’s methods of analysis and the risks surrounding such investments. There may be times when a Client decides to use margin in their account. Use of margin in an investment advisory account can increase a Client’s asset-based advisory fee. If margin is used to purchase additional securities, for instance, the total value of eligible account assets (to which the 7Two advisory fee is applied) will also increase. Notably, the opportunity to increase assets via margin debt presents a potential conflict of interest for 7Two. 7Two recognizes that margin debt is not suitable for all investors. It is 7Two’s practice to recommend that clients not utilize such financing, or if they decide to do so, to employ it in a prudent manner. Buying securities on margin also subjects Clients to additional costs and risks that should be carefully considered before opening a margin account. For further information, Clients should refer to Item 8. Clients are advised and are expected to understand that 7Two’s past performance is not a guarantee of future results. Certain market and economic risks exist that can adversely affect an account’s performance. This could result in capital losses in Clients’ account(s). USE OF INDEPENDENT THIRD-PARTY INVESTMENT ADVISER 7Two firm may determine that engaging the expertise of an independent third-party investment Adviser (“Manager”) is best suited for Clients’ account(s). 7Two will have the discretion to utilize a Manager to aid in the implementation of investment strategies for a Client’s portfolio. In certain circumstances, 7Two may allocate a portion of a portfolio to a Manager for separate account management based upon Clients’ individual circumstances and objectives, including, but not limited to, Client account size and tax circumstances. An example of this would be using an outside separately managed account manager to implement a direct indexing investment strategy or a separately managed individual bond strategy. Upon the recognition of such situations, 7Two will hire a Manager for the management of those assets. These Advisers shall assist 7Two in managing the day‐to‐day investment operations of the various allocations, shall determine the composition of the investments comprising the allocation, shall determine what securities and other assets of the allocation will be acquired, held, disposed of or loaned in conformity with the investment objectives, policies and restrictions, and other circumstances of each Client comprising the allocation, or as instructed by 7Two. 7Two reviews Managers selected for Clients’ investments based on various quantitative and qualitative information. Among the criteria that may be considered are the Manager’s experience, assets under management, performance record, standard deviation of returns, alpha, beta, sharpe ratios, technical profile, client retention, the level of client services provided, investment style, buy and sell disciplines, capitalization level, and the general investment process. Clients are advised and should understand that: ● A Manager’s past performance is no guarantee of future results; ● There is a certain market and/or interest rate risk which may adversely affect any Manager’s objectives and strategies, and could cause a loss in a Clients’ account(s); and 6 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  ● Client risk parameters or comparative index selections provided to 7Two are guidelines only and there is no guarantee that they will be met or not be exceeded. Managers may take discretionary authority to determine the securities to be purchased and sold for the Client. As stated in the discretionary advisory agreement, 7Two and its associated persons will have discretionary authority to hire and fire the Manager. 7Two will work with the Manager to communicate any trading restrictions or standing instructions to refrain from a particular industry requested by the Client. In all cases, trading restrictions will depend on the Manager and their ability to accommodate such restrictions. All performance reporting will be the responsibility of the respective Manager. Such performance reports will be provided directly to Clients and 7Two. Disclosures will indicate what firm is providing the reporting. 7Two reviews the performance of Managers on at least a quarterly basis. More frequent reviews may be triggered by changes in Manager’s management, performance or geopolitical and macroeconomic specific events. 7Two only enters into a select number of relationships with Managers. As agreed upon between the Client, Manager, and 7Two and outlined in the agreements with each party, the Client will pay an advisory fee to the Manager directly from the Client account with the Manager. In either case, these fees are disclosed on the Client account statement from the Manager. FINANCIAL PLANNING SERVICES 7Two may provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services may involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client, may include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. 7Two may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, 7Two may provide a written summary of the Client’s financial situation, observations, and recommendations. Financial planning and consulting recommendations pose a conflict between the interests of the Adviser and the interests of the Client. For example, 7Two has an incentive to recommend that Clients engage 7Two for investment advisory services or to increase their level of investment assets with 7Two, as it may increase the amount of advisory fees paid to the Adviser. Clients are not obligated to implement any recommendations made by 7Two or maintain an ongoing relationship with 7Two. If the Client elects to act on any of the recommendations made, the Client is under no obligation to implement the transaction through 7Two. 7 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS When a client or prospect leaves an employer, they typically have five options regarding their existing retirement plan: (i) leave the money in the former employer’s plan, if permitted; (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted; (iii) rollover to a brokerage (self- directed) Individual Retirement Account (“IRA”); (iv) roll over the assets to an advisory IRA; or (v) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). Clients contemplating rolling over retirement funds to an IRA for 7Two to manage are encouraged to first speak with their CPA or tax attorney. There may be an inherent financial incentive for 7Two to recommend that Clients roll over assets into one or more accounts, because the enrollment may generate compensation based on the increase in 7Two’s total assets under management. 7Two addresses these financial compensation conflicts by including the disclosure of the conflicts in this brochure and recommending investment advisory programs, investment securities, and services that are in the best interest of each Client based upon the Client’s investment objectives, risk tolerance, financial situation, and cost. As fiduciaries of the Investment Advisers Act of 1940, 7Two has to act in the Clients’ best interest and not put 7Two’s interest ahead of the Clients’. At the same time, the way 7Two makes money creates some conflicts with your interests. Clients are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if the Client does complete the rollover, the Client is under no obligation to have the assets in an account managed by 7Two. CONSULTING SERVICES 7Two provides non-discretionary investment consulting services for ultra-high net worth clients, including family offices and endowments. 7Two provides non-discretionary investment advice, including: research; due diligence; monitoring; search and recommendations with respect to managers and other Advisers; risk assessments; asset allocation; portfolio modeling; rebalancing; investment policy design and monitoring; ongoing investment recommendations; and/or other such investment consulting services which the Client may reasonably request 7Two to perform. POOLED INVESTMENT VEHICLE 7Two acts as an adviser to a pooled investment vehicle (special purpose vehicle) operating as private fund (each a “Client” or “Fund”). Interests in the Funds are offered to Reg D qualified purchasers – certain sophisticated, qualified investors, including high net worth individuals, retirement plans, trusts, partnerships, corporations, or other businesses. 7Two’s primary investment objective is to generate positive risk-adjusted returns. 7Two employs an opportunistic, value-oriented investment strategy supported by an analytical, fundamental research approach to identifying and assessing intrinsic value. However, 7Two may tailor specific advisory services with respect to each special purpose vehicle (i.e. the Client) based on the particular investment objectives and strategies described in the applicable Client’s (i) confidential offering memorandum or separate account agreement and (ii) governing documents (referred to collectively as “Offering Documents”). The goal is to create an offering (the SPV) that has a unique position and profile in the marketplace, exposed to skilled fund management, and with a strategy that is poised for upside given the underwritten risks. The Fund is not registered as an investment company under the Investment Company Act of 1940 and only offers interests in a private placement. Further, such interests in private placements are only offered to qualified purchasers (as defined in Section 2(a)(51) of the Investment Company Act). Investors who reside in certain states are required to meet standards different from or in addition to those described above. Investors will be required to represent in writing that they meet any such standards that may be applicable to them. The Managing Member of the Fund can, without the consent of the existing Members, 8 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  admit new Members to the Fund. The Managing Member may reject a subscription for an Interest for any reason in its sole and absolute discretion. If a subscription is rejected, the payment remitted by the Investor will be returned without interest. It is important clients refer to Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss below for important information about the risks associated with private placements. 7Two will recommend the Fund to certain advisory clients when deemed appropriate. It is important clients refer to Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss below for important information about the risks associated with private placements. Employees of 7Two may invest alongside other investors and advisory Clients in the Fund. It is important Clients refer to Item 10 for disclosure of the firm’s affiliates and the related conflicts. WRAP FEE PROGRAM 7Two does not offer a Wrap Program. ASSETS As of the date of this Disclosure Brochure, 7Two manages $142,280,777 in discretionary assets and $0 in non-discretionary assets. Total assets under management are $142,280,777. Additionally, our Firm advises on a total of $964,345,182.74 in assets under advisement. Clients may request more current information at any time by contacting the Adviser. I T E M 5 – F E E S A N D C O M P E N S A T I O N INVESTMENT ADVISORY Investment advisory fees are paid quarterly, at the end of each calendar quarter pursuant to the terms of the investment advisory agreement. Investment advisory fees range from a flat fee to a percentage of assets under mangement and advisement based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with 7Two. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. Investment advisory fees do not exceed 1.5% annually. The investment advisory fee in the first quarter of service may be prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at 7Two’s sole discretion. All securities held in accounts managed by 7Two will be independently valued by the Custodians. 7Two’s fee is exclusive of, and in addition to, any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5 below, which may be incurred by the Client. However, 7Two does not receive any portion of these commissions, fees, and costs. When invested in a particular strategy, there is typically a small percentage of cash as part of most investment strategies. That “cash” will be included in the AUM fee, unless otherwise negotiated. Unmanaged Assets (refer to language below in Item 5) are “not” included in the assets under management for billing purposes. If a Client has a margin account, 7Two’s fees will be based on the full gross value of the assets under management without regard to the amount of margin debt on the account. Clients need to be aware that buying investments using margin may increase the amount of fees paid to 7Two. 7Two may aggregate asset amounts in Clients’ household accounts to determine the advisory fee for all Clients’ accounts. 7Two may do this, for example, where 7Two also services accounts on behalf of minor 9 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow the Client the benefit of an increased asset total, which could potentially cause Clients’ account(s) to be assessed a lower advisory fee based on the asset levels under management with 7Two. The independent qualified custodian holding Client funds and securities may debit Clients’ accounts directly for the advisory fee and pay that fee to 7Two, or if elected by the client, 7Two may bill Clients directly via an invoice. In the event the Client elects to have the advisory fee (s) deducted from the Custodial account(s), the Client will provide written authorization permitting the fees to be paid directly from the account held by the qualified Custodian or bank. Further, the qualified Custodian agrees to deliver an account statement at least quarterly directly to the Client indicating all the amounts deducted from the account including our advisory fees. Refer to Item 15 for details. Clients are encouraged to review account statements for accuracy. Either 7Two or the Client may terminate the advisory agreement immediately upon written notice to the other party. The advisory fee may be pro-rated to the date of termination.. Upon termination, the client is responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. FINANCIAL PLANNING SERVICES Financial planning services are included in the investment advisory fees as outlined above. CONSULTING Consulting fees are determined on a case-by-case basis with each Client based on their needs and complexity. Fees will vary based on investment portfolio, assets under advisement, and specific consulting services requested. Considerations that factor into fees include the professional time needed to perform services, number of meetings, complexity of investment research, costs associated with research, level of expertise/experience needed to provide services, and unique customizations. Fees are either a flat fee or calculated as a percentage of the assets under advisement. 7Two and the Client may agree on alternative billing methodologies. 7Two does not have the authority to deduct its consulting fee from the Client’s account[s]. Fees are generally due upon receipt of the invoice. Either party may terminate the consulting agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the consulting agreement within five (5) business days of signing 7Two’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide consulting services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, 7Two will promptly refund any unearned, prepaid fees from the effective date of termination. The Client’s consulting agreement with us is non-transferable without the Client’s prior consent. ADMINISTRATIVE SERVICES 7Two has contracted with non-affiliated, third-party entities to utilize their technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, payable reports, web site administration, investment strategies, trading platforms, and other functions related to the administrative tasks of managing Client accounts. Due to this arrangement, these third-party entities will have access to information on the Client accounts but will not serve as an investment adviser to 7Two Clients. 7Two and the third-party entities are non-affiliated companies. The third-party entities may charge our 7Two a fee for their services, and 0 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  in some cases for each account administered by each third-party entity. Please note that advisory fee charged to the Client will not increase due to the fee 7Two pays to the third-party entity. The fee is paid from the portion of the advisory or consulting fee retained by 7Two. OTHER ADDITIONAL FEES Private Funds: Clients invested in Private Funds are subject to certain fees, such as a management, performance or incentive fee and other fees and expenses, which are outlined in the fund’s Offering Documents. It is important for Clients to review the fund’s Offering Documents to fully understand all the fees associated with the Fund. All the above fees are in addition to the fees charged by 7Two. It is important for Clients to know all the fees associated with their accounts; therefore, Clients should review the fees charged by: (i) certain investments, such as private funds and mutual funds, and (ii) third parties, such as custodians, brokers and advisers, along with the fees charged by 7Two, to fully understand the total amount of fees affecting the account. Commissions for securities transactions: 7Two does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also registered representatives of Silver Leaf Partners LLC (“Silver Leaf”), a registered broker-dealer and member FINRA, SIPC. In an Advisory Person’s separate capacity as a Registered Representative, the Advisory Person may implement securities transactions and maintain accounts under Silver Leaf and not through 7Two. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative of Silver Leaf is separate and in addition to the Adviser’s fees. This practice presents a conflict of interest as the Advisory Person who is a Registered Representative may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the needs of the Client. Clients are not obligated to implement any recommendation provided by an Advisory Person in such capacity. Neither the Adviser nor its Advisory Persons will earn ongoing commission-based compensation in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 below. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal fee and expense structures. 7Two endeavors to identify and utilize the share class with the lowest internal fee and expense structure for each mutual fund. However, instances occur in which the lowest cost share class is not used. These instances include but are not limited to: • • • Instances in which a certain custodian has a share class available that has a lower internal fee and expense structure than is available for the same mutual fund at other custodians. In such instances, 7Two will select the lowest cost share class available at the custodian that holds Clients’ account even though a lower cost share class is available at another custodian. Instances in which the custodian that holds Clients’ account offers others a share class with a lower internal fee and expense structure than what is available to 7Two at the same custodian. In such instances, 7Two will select the lowest cost share class that the custodian makes available. This situation sometimes occurs because the custodian places conditions on the availability of the lower cost share class that 7Two has determined are not appropriate to accept due to additional costs imposed by said conditions. Instances in which a share class with a lower internal fee and expense structure becomes available after the share class the Client holds was purchased. 7Two periodically monitors this 1 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  • circumstance. However, a share class with a lower internal fee may become available between the time of the Clients’ purchase and 7Two’s next review. Instances in which a share class with a lower internal fee and expense structure than the share class Clients currently hold is available at Clients’ custodian, but where 7Two is prevented by either the custodian or the fund sponsor from converting to the lower cost share class. Additionally, 7Two does not convert to a share class with a lower internal fee and expense structure if the conversion will cause a taxable event or other expense/cost to Clients that negates the advantage of the lower cost share class. • Non-Transaction Fee (NTF) Mutual Funds When selecting investments for Clients’ portfolios, 7Two might choose mutual funds on Clients’ account custodian’s Non-Transaction Fee (NTF) list. This means that Clients’ account custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in Clients’ custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund including Clients of 7Two. When 7Two decides whether to choose a fund from Clients’ custodian’s NTF list or not, 7Two consider the expected holding period of the fund, the position size and the expense ratio of the fund versus alternative funds. Depending on 7Two’s analysis and future events, NTF funds might not always be in the Clients’ best interest. Unmanaged Assets From time to time, a Client may decide to hold certain securities or other property for which 7Two does not provide investment advisory services ("Unmanaged Assets") in the account(s) held at the Custodian or outside the Custodian. Unmanaged assets will be shown on 7Two reports as unmanaged assets. It is the Client’s sole responsibility to verify the accuracy of the Unmanaged status of any and all investments in their accounts and to notify 7Two in writing of any corrections or adjustments that need to be made. 7Two will have no duty, responsibility or liability whatsoever with respect to these assets, and therefore, 7Two will not charge an investment advisory fee. However, if a Client has an account that solely contains Unmanaged Assets, the Custodian may charge an account maintenance fee as disclosed in the Custodian account paperwork executed by the Client. In all cases, it is the Client’s sole responsibility to monitor, manage, and transact all Unmanaged Assets (securities and/or accounts). Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on Client accounts for sell transactions, and a FINRA fee is assessed on Client accounts for sell transactions, for certain covered securities. This fee is not charged by 7Two but is accessed and collected by the Custodian. The Custodians that 7Two uses are FINRA member firms. These fees recover the costs incurred by the SEC and FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA fees, Client should visit their websites: www.sec.gov/fast- answers/answerssec31htm.html and www.finra.org/industry/trading-activity-fee. I T E M 6 – P E R F O R M A N C E - B A S E D F E E S A N D S I D E - B Y - S I D E M A N A G E M E N T 7Two does not charge performance-based fees for its investment advisory services. The fees charged by 7Two are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. 2 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  I T E M 7 – T Y P E S O F C L I E N T S 7Two offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, family offices, special purpose vehicles (SPVs) and other institutional clients (each referred to as a “Client”). 7Two generally does not impose a minimum relationship size. I N V E S T M E N T I T E M 8 – M E T H O D S O F A N A L Y S I S , S T R A T E G I E S A N D R I S K O F L O S S 7Two primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from 7Two are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps 7Two in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. 7Two monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on 7Two’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to Clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that 7Two will be able to accurately predict such a reoccurrence. 7Two generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. 7Two will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, 7Two may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. METHODS OF ANALYSIS While there may be some similarities in the portfolios created by 7Two, 7Two understands that every Client has their own unique planning needs. 7Two has the ability and flexibility to create portfolios to help Clients achieve their goals. 7Two may utilize the following forms of analysis: Asset Allocation: 7Two believes that each Client’s portfolio design should start with an asset allocation decision. 7Two attempts to identify an appropriate mix of asset class weightings suitable to the Client’s investment goals and risk tolerance. A risk of asset allocation is that the Client may not participate in sharp increases in every security, industry, market sector or asset class. Another risk is that the mix of asset class weightings will change over time due to market 3 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  movements and, if not corrected, could no longer be appropriate for the Client’s goals. For this reason, from time-to-time 7Two will rebalance Client portfolios to better align with Client risk tolerance and goals. Fundamental Analysis: 7Two attempts to measure the attractiveness of an investment by looking at economic and financial factors (including the overall economy, industry conditions, and the financial conditions, past performance, manager tenure, and parent company stability) to determine if the investment is appropriate for a Client’s portfolio. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the investment. Quantitative Analysis: 7Two uses mathematical ratios such as alpha, beta, standard deviation, Sharpe ratio, and other performance appraisal methods to obtain more comprehensive measurements of a manager’s investment acumen, idea generation, consistency of purpose, and overall ability to deliver attractive risk adjusted returns throughout a full market cycle. Additionally, 7Two performs periodic measurements to assess the investment results. A risk in using quantitative analysis is that the information used may be based on assumptions that prove to be incorrect. Technical Analysis: 7Two uses this method of evaluating investments or assets classes by analyzing statistics generated by market activity, such as investment trends. Technical analysis does not attempt to measure a security's intrinsic value. Technical analysis is done through observation of various market sentiment readings, many of which are quantitative. BORROWING AGAINST ASSETS/RISKS A Client who has a need to borrow money could determine to do so by using: • Margin – The account custodian or broker-dealer can sometimes lend money to the Client. The custodian charges the Client interest for the right to borrow money, and uses the assets in the Client’s brokerage account as collateral; and/or, • Pledged Assets Loan – In consideration for a lender (i.e., a bank, etc.) to make a loan to the Client, the Client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally used because they may provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the Client’s investment assets. The lender (i.e., custodian, bank, etc.) typically charges a floating interest rate, and will have recourse against the Client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, 7Two does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). 7Two does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the Client were to utilize margin or a pledged assets loan, the following economic benefits would inure to 7Two: • by taking the loan rather than liquidating assets in the Client’s account, 7Two continues to earn a • fee on such account assets; and, if the Client invests any portion of the loan proceeds in an account 7Two manages, 7Two will receive an advisory fee on the invested amount; and, 4 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  • if 7Two’s advisory fee is based upon the higher margined account value, 7Two will earn a correspondingly higher advisory fee. This could provide 7Two with a disincentive to encourage the Client to discontinue the use of margin. The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. 7Two may require Clients using margin to do so by opening an aggregate margin account whereby the margin balances are held in a separate account which is not managed by 7Two but uses the accounts managed by 7Two as collateral for the loan. RISK OF LOSS A Client’s investment portfolio is affected by general economic cycles and market conditions, such as interest rates, availability of credit, inflation rates, economic conditions, changes in laws, and national and international political circumstances. Investing involves certain risks. Investments may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. 7Two will assist Clients in determining an appropriate strategy based on their tolerance for risk. Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk, and other factors to develop an appropriate strategy for managing a Client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account(s). 7Two will rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform 7Two of any changes in financial condition, goals or other factors that may affect this analysis. Our methods rely on the assumption that the underlying companies within our security allocations are accurately reviewed by the rating agencies and that other publicly available sources of information about these securities are providing accurate and unbiased data. While 7Two is alert to indications that data may be incorrect, there is always a risk that 7Two’s analysis may be compromised by inaccurate or misleading information. Investors should be aware that accounts are subject to the following risks: MARKET RISK – Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that Clients will lose money and investments may be worth more or less upon liquidation. FOREIGN SECURITIES AND CURRENCY RISK – Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets, reduced regulation, and the potential for higher political instability. CAPITALIZATION RISK – Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services. These stocks have historically been more volatile than the stocks of larger, more established companies. INTEREST RATE RISK – In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. 5 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  CREDIT RISK – The issuer of an investment may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and thus impact a fund’s or bond’s performance. LIQUIDITY RISK – There may be limited buyers for a security when an investor wants to sell. Typically, this results in a discounted sale price in order to attract a buyer. Certain non-liquid alternative investment funds may also have the ability, at the fund sponsor’s sole discretion, to limit or stop its investors’ ability to withdraw investments in the fund. DEFAULT RISK – A default occurs when an issuer fails to make a principal or interest payment. EVENT RISK – Unpredictable events occur which may impact an investment outcome, including natural disasters such as earthquakes or hurricanes, as well as changes in circumstance from regulators or political bodies. POLITICAL RISK – Laws of a country may change, regimes change, and other geopolitical events occur that may may negatively impact an investment. Particular political events such as a government’s change in policy could restrict the flow of capital. DURATION RISK –The duration of a bond is determined by its maturity date, coupon rate, and call feature. Duration is a method to compare how different bonds will react to interest rate changes. For example, if a bond has a duration of five (5) years, it means that the value of that security is estimated to decline by approximately five percent (5%) for every one percent (1%) increase in interest rates, all else equal. REINVESTMENT RISK – Future interest and principal payments may be reinvested at lower yields due to declining interest rates. TAX RISK – Depending on the Client’s state of residence, the interest earned on certain municipal bonds may not be tax-exempt at the state level. Also, changes in federal tax policy may impact the tax treatment of interest and capital gains of an investment. REGULATORY RISK – Market participants are subject to rules and regulations imposed by one or more regulators. Changes to these rules and regulations could have an adverse effect on the value of an investment. CONCENTRATION RISK – Amplified losses may occur from having a large portion of holdings in a particular investment, asset class, or market segment relative to the overall portfolio. SECURITIES LENDING RISK – A fund or a hypothecated account may lose money because a borrower fails to return securities in a timely manner or at all. A fund or Client could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences. EXCHANGE-TRADED FUND (“ETF”) AND MUTUAL FUND RISK – Investments in ETFs and mutual funds have unique characteristics, including, but not limited to, the ETF or mutual fund’s expense structure. Investors of ETFs and mutual funds held within 7Two Client accounts bear both their 7Two portfolio’s advisory expenses and the ETF’s or mutual fund’s expenses. Because the expenses and costs of an underlying ETF or mutual fund are shared by its investors, redemptions by other investors in the ETF or mutual fund could result in decreased economies of scale and increased operating expenses for such ETF or mutual fund. Additionally, the ETF or mutual fund may not achieve its investment objective. Actively managed ETFs or mutual funds may experience significant drift from their stated benchmark. 6 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  CYBERSECURITY RISK – In addition to the Material Investment Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at 7Two or one of the third-party counterparties or service providers that may result in a loss of data, result in the unauthorized release or other misuse of confidential information, and generally compromise 7Two’s ability to conduct business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to Clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. 7Two has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because 7Two does not directly control the cybersecurity systems of third-party service providers. There is also a risk that cybersecurity breaches may not be detected. COMMODITIES RISK – Exposure to commodities in Client accounts is typically in non-physical form, such as ETFs or mutual funds. There are risks associated with the movement in commodity prices and the ability of the fund or trust manager to respond or deal with those price movements. There also may be initial charges as well as annual management fees associated with the fund or trust. OPTION RISK – Transactions in options carry a high degree of risk. Purchasers and sellers of options should familiarize themselves with the type of option (i.e., put or call) which they contemplate trading and the associated risks. Traders of options should calculate the extent to which the value of the options must increase for the position to become profitable, taking into account the premium and all transaction costs. • The purchaser of options may offset or exercise the options or allow the options to expire. The exercise of an option results either in a cash settlement or in the purchaser acquiring or delivering the underlying interest. If the option is on a future, the purchaser may acquire a futures position with associated liabilities for margin (see the section on Futures below). If the purchased options expire worthless, the purchaser will suffer a total loss of the investment. In purchasing deep out-of-the- money options, the purchaser should be aware that the chance of such options becoming profitable ordinarily is remote. • Selling ("writing" or "granting") an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will be liable for additional margin to maintain the position if the market moves unfavorably. The seller will also be exposed to the risk of the purchaser exercising the option and the seller being obligated to either settle the option in cash or to acquire or deliver the underlying interest. If the option is on a future, the seller may acquire or be short a position in a future with associated liabilities for margin (see the section on Futures below). If the option is "covered" by the seller holding a corresponding position in the underlying interest or a future or another option, the risk may be reduced. If the option is not covered, the risk of loss can be unlimited. • Certain exchanges in some jurisdictions permit deferred payment of the option premium, exposing the purchaser to liability for margin payments not exceeding the amount of the premium. The purchaser is still subject to the risk of losing the premium and transaction costs. When the option is exercised or expires, the purchaser is responsible for any unpaid premium outstanding at that time. ALTERNATIVE INVESTMENTS – Alternative investments are speculative, risking the loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and 7 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  resulting higher risk due to concentration of trading authority with a single Adviser; absence of information regarding valuations and pricing; potential for delays in tax reporting; and less regulation and typically higher fees than other investment options such as mutual funds. NON-TRANSFERABILITY – Certain investments used by 7Two may not be transferrable to other custodians. Additionally, if they are transferrable, other Advisers may be restricted to only sell the positions and not be allowed to buy more. This could include certain institutional share class mutual funds, mutual funds closed to new investors, investments available only to approved firms like 7Two, alternative investments, structured notes, and interval funds. ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING – Certain service providers utilized by 7Two to service client accounts have artificial intelligence components. Due to the rapid advancement of machine learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our clients, 7Two performs periodic due diligence of our service providers for assurance that the service providers have appropriate controls in place to protect Clients’ information and to limit data inaccuracies when artificial intelligence is used by the service provider. I T E M 9 – D I S C I P L I N A R Y I N F O R M A T I O N personnel have no reportable disciplinary events to We are required to disclose any legal or disciplinary events that are material to a Client's or prospective Client's evaluation of our advisory business or the integrity of our management. Our Firm and our disclose. Visit management http://www.adviserinfo.sec.gov to review each investment Advisers’ individual disclosures or 7Two’s disclosures. I T E M 1 0 – O T H E R F I N A N C I A L I N D U S T R Y A C T I V I T I E S A N D A F F I L I A T I O N S BROKER-DEALER AFFILIATION As noted in Item 5, certain Advisory Persons are also Registered Representatives of Silver Leaf. In one’s separate capacity as a Registered Representative of Silver Leaf, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of 7Two in their capacity as a Registered Representative. Neither the Adviser nor its Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered Representative. Silver Leaf provides private placement to select Nonliquid Alternative Investment funds and investment banking services to companies. To mitigate any incentive to generate broker-dealer fees for the placement of potential clients into a Silver Leaf-placed fund or for the sale of public or private securities into a 7Two private fund, Silver Leaf has agreed to forego any direct fee compensation for the placement of 7Two clients into such a fund as well as any fees which could be earned through the sale of securities to a 7Two private fund. Silver Leaf has some legacy placement fees which, in lieu of being forfeited, will be disclosed to 7Two clients. Silver Leaf may be engaged as a placement agent by managers of Nonliquid Alternative Investments recommended by 7Two, or by underlying portfolio companies. In such a situation, Silver Leaf may have 8 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  an incentive to direct non-Clients to a private fund or advise an underlying portfolio company to transact in a way that may not align with 7Two Clients’ interests. It should be noted that neither 7Two or Silver Leaf will be general partners of any fund or controlling equity holders of any portfolio companies, and any fees charged by Silver Leaf will be negotiated at arm’s length between a fund’s manager or a portfolio company and Silver Leaf. Silver Leaf will ensure that their fee arrangements are at rates customarily charged by Silver Leaf for such services, and not inconsistent with general industry practices. While placement fees are generally paid by fund managers and not directly by a Nonliquid Alternative Investment fund, Clients should be aware that such fees or investment banking fees for underlying portfolio companies may negatively affect the overall performance of an investment. FAWKES V LTD. Mr. Bathgate and Mr. Macken are owners and/or Managers of Fawkes V Ltd., a special purpose investment vehicle. Clients of the Adviser have or may be offered interests in Fawkes V Ltd. This business activity represents less than 5% of business time for Mr. Bathgate and Mr. Macken. RHF IV HOLDING COMPANY LLC Mr. Bathgate is a Managing Director of RHF IV Holding Company LLC, a single purpose investment vehicle that invests in Revelation Healthcare Partners IV, LP, a private fund. Clients of the Advisor have or may be offered interests in RHF IV Holding Company LLC. Mr. Bathgate was previously compensated for the placement of interests into Revelation Healthcare Partners IV, LP as a Registered Representative of Silver Leaf Partners. There is no compensation from advisory clients. This outside business activity represents less than 5% of Mr. Bathgate’s time during business hours. INVESTMENT ADVISER AFFILIATION Nicholas Rotello, indirect owner of the Firm, is also an indirect owner of a Colorado registered investment adviser, Seven Two Partners LLC (#297575). For a brief transition period, these two firms will remain under common control and ownership. Clients should be aware of this other affiliation. We do not consider our investment advisory affiliation with this firm to create a material conflict of interest for our clients and address this conflict of interest by disclosing it to you in this brochure. DISCLOSURE OF CONFLICTS OF INTEREST 7Two does not have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. Neither 7Two nor any of its management persons are registered or have an application pending to register as a broker-dealer. 7Two’s management personnel and investment Adviser representatives may engage in outside business activities. As such, these individuals will not receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of investment advisory Clients. Clients are not under any obligation to engage these individuals when considering the implementation of these outside recommendations. The implementation of any or all recommendations is solely at the discretion of the Client. Clients should be aware that the ability to receive additional compensation by 7Two and its management persons or employees creates inherent conflicts of interest in 7Two’s objectivity and these individuals when making advisory recommendations. 7Two endeavors at all times to put the interest of 9 1 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  Clients first as part of the fiduciary duty as a registered investment adviser. 7Two takes the following steps, among others to address this conflict: • 7Two discloses to Clients the existence of all material conflicts of interest, including the potential for 7Two, investment Advisers, and employees to earn compensation from advisory Clients in addition to advisory fees. • 7Two discloses to Clients that they have the right to decide to purchase recommended investment products from 7Two’s employees. • 7Two collects and maintains Client background information, including the Client’s financial goals, objectives, and liquidity needs. to verify • 7Two conducts regular reviews of each Client advisory account that all recommendations made to a Client are in the best interest of the Client’s needs and circumstances. • 7Two requires that investment Advisers and employees seek prior approval of any outside employment activity so that 7Two may ensure that any conflicts of interests in such activities are properly addressed. • 7Two periodically review these outside employment activities of the investment Adviser to verify that any conflicts of interest continue to be properly disclosed by the investment Adviser; and • 7Two educates investment Advisers regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. P A R T I C I P A T I O N O R I T E M 1 1 – C O D E O F E T H I C S , I N T E R E S T I N C L I E N T T R A N S A C T I O N S A N D P E R S O N A L T R A D I N G 7Two has adopted a Code of Ethics which sets forth high ethical standards of business conduct that 7Two requires of its investment Advisers and employees, including compliance with applicable federal securities laws. 7Two and its investment Advisers owe a duty of loyalty, fairness and good faith towards Clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. 7Two’s Code of Ethics includes policies and procedures for the reporting and review of personal securities transactions reports by 7Two’s investment Advisers and employees. In addition, 7Two’s Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. 7Two’s Code of Ethics also provides for oversight, enforcement, and recordkeeping provisions. 7Two’s Code of Ethics further includes a policy prohibiting the use of material non-public information. While 7Two does not believe that it has any access to non-public information, all investment Advisers are reminded that such information may not be used in a personal or professional capacity. 7Two and its investment Advisers are prohibited from engaging in principal transactions and agency cross transactions. 7Two’s Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of its investment Advisers will not interfere with (i) making decisions in the best interest of Clients and (ii) implementing such decisions while, at the same time, allowing investment Advisers to invest for their own accounts. 7Two and/or investment Advisers or employees may buy or sell for their personal accounts securities that are identical to or different from those recommended to Clients. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a Client. It is the expressed policy of 7Two that no investment Adviser may purchase or sell any security prior to a transaction(s) being implemented for an advisory 0 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  account, thereby preventing such investment Adviser(s) from benefiting from transactions placed on behalf of advisory accounts. A copy of 7Two’s Code of Ethics is available to Clients and prospective Clients. Clients may request a copy by calling 720-477-7274. I T E M 1 2 – B R O K E R A G E P R A C T I C E S THE CUSTODIAN AND BROKERS WE USE Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or bank. 7Two Clients typically choose to work with Charles Schwab & Co., Inc. (“Schwab” “the Custodian”), which is a Member FINRA/SIPC, registered broker-dealer, and qualified custodian. 7Two is independently owned and operated, and unaffiliated with Schwab. The Custodian will hold Client assets in a brokerage account and buy and sell securities when 7Two instructs them to. Clients must decide whether to use Schwab by entering into account agreements directly with Schwab. The accounts will always be held in the name of the client and never in 7Two’s name. Even though Clients maintain accounts at Schwab, 7Two can still use other brokers to execute trades for Client accounts (see Client Brokerage and Custody Costs, below). HOW 7Two SELECTS BROKERS/CUSTODIANS It is generally advisable for investors to select a custodian/broker who will hold Client assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. 7Two recommends they consider a wide range of factors, including: 1. Combination of transaction execution services and asset custody services (generally without a separate fee for custody) 2. Capability to buy and sell securities for Client accounts 3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) 4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) 5. Availability of investment research and tools that assist us in making investment decisions 6. Quality of services 7. Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices 8. Reputation, financial strength, and stability 9. Prior service to 7Two and our other Clients 10. Availability of other products and services that benefit 7Two, as discussed below (see Products and Services Available to 7Two from Schwab) CLIENT BROKERAGE AND CUSTODY COSTS For Client accounts that the Custodian maintains, the Custodian generally does not charge separately for custody services. However, the Custodian receives compensation by charging transaction fees or other fees on trades that it executes or that settle into Clients’ Custodian accounts. In addition to commissions, the Custodian may charge a flat dollar amount as a “prime broker” or “trade away” fee for each trade that 7Two has executed by a different custodian but where the securities bought or the funds from the securities sold are deposited (settled) into a Client’s Custodian account. These fees are in addition to the transaction fees or other compensation the Client pays the executing custodian. To minimize these trading costs, 7Two has the Custodian execute most trades for Client accounts. 7Two has determined 1 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  that having the Custodian execute most trades is consistent with 7Two’s duty to seek “best execution” of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How 7Two Selects Brokers/Custodian” section above). PRODUCTS AND SERVICES AVAILABLE TO 7Two FROM CUSTODIAN The Custodian will provide 7Two and its clients with access to institutional brokerage, trading, custody, reporting, and related services. The Custodian also makes available various support services which helps 7Two manage or administer Clients’ accounts and helps manage and grow business. Schwab’s support services generally are available on an unsolicited basis (7Two does not have to request them) and at no charge to 7Two. Following is a more detailed description of Schwab’s support services: 7Two’S INTEREST IN SCHWAB’S SERVICES The availability of these services from the Custodian benefits 7Two because 7Two does not have to produce or purchase them. These services are not contingent upon 7Two committing any specific amount of business to Schwab. 7Two believes that the selection of the Custodian as Custodian and brokers is in the best interest of Clients. Some of the products, services and other benefits provided by the Custodian benefit 7Two and may not benefit Client accounts. 7Two’s recommendation or requirement that Clients place assets in Schwab's custody may be based in part on benefits Custodian provides to 7Two, or 7Two’s agreement to maintain certain Assets Under Management at Schwab, and not solely on the nature, cost or quality of custody and execution services provided by Schwab. BROKERAGE FOR CLIENT REFERRALS 7Two does not receive client referrals from any custodian or third party in exchange for using that custodian or third party. AGGREGATION AND ALLOCATION OF TRANSACTIONS The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. 7Two will execute its transactions through the Custodian as authorized by the Client. 7Two may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. TRADE ERRORS 7Two has implemented procedures designed to prevent trade errors; however, trade errors in Client accounts cannot always be avoided. Consistent with 7Two’s fiduciary duty, it is 7Two’s policy to correct trade errors in a manner that is in the best interest of the Client. In cases where the Client causes a 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 7Two will absorb any loss resulting from the trade error if the error was caused by 7Two. If the error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. 7Two will never benefit or profit from trade errors. 2 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  DIRECTED BROKERAGE All Clients are serviced on a “directed brokerage basis”, where 7Two will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. 7Two will not engage in any principal transactions (i.e., trade of any security from or to 7Two’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). 7Two will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. PRIVATE FUNDS In most cases, Private Funds are available only to a limited number of sophisticated investors who meet the definitions of an “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”) and “qualified client” under the Investment Advisers Act of 1940, or “qualified purchaser” under the Investment Company Act of 1940. Private Funds are considered “limited offerings” since they only accept a limited amount of funds for investment. When determining which Clients should receive a recommendation to invest in a Private Fund, 7Two takes into account a number of factors, including but not limited to, a Client’s sophistication, risk tolerances and qualifications, investment objectives, liquidity needs, and the amount of available investable assets. 7Two’s goal is to allocate in a fair and balanced manner; however, given these differing factors, the allocation of investment opportunities in Private Funds to Clients is mainly subjective, and not all qualifying Clients will be provided an investment opportunity. Additionally, there are times when one or more of 7Two’s employees invest in certain Private Funds that are recommended to Clients. When this occurs, a potential conflict exists and to address the potential conflict employees are required to receive prior written approval by the Chief Compliance Officer. It is important that qualifying Clients receiving a recommendation to invest in a Private Fund read the offering or private placement memorandum prior to investing to fully understand the risks and potential conflicts pertaining to the Private Fund investment. See Item 11 for further information. The SPV has an account at First Citizens Bank, the custodian, through which investor funds are called to be deposited for the SPV and then aggregated for investment into the private placement in which the SPV is investing. The SPVs have engaged a third-party administrator and accountant to prepare investor statements and to calculate and determine the value of the SPV. Further, each of the SPVs are subject to an annual audit by an accounting firm registered with the Public Company Accounting Oversight Board (PCAOB). I T E M 1 3 – R E V I E W O F A C C O U N T S ACCOUNT REVIEWS AND REVIEWERS 7Two’s Investment Adviser Representatives will monitor Client accounts on a regular basis and perform annual reviews with each Client. All accounts are reviewed for consistency with Client investment strategy, asset allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews may be triggered by changes in a Client’s personal, tax, or financial status. Geopolitical and macroeconomic specific events may also trigger reviews. Clients are urged to notify 7Two of any changes in personal circumstances. 3 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning Clients unless otherwise contracted for. STATEMENTS AND REPORTS Performance reports from 7Two are generated for Clients during annual reviews or as requested. The Custodian for the individual Client’s account will also provide Clients with an account statement at least quarterly. Clients are urged to compare the reports provided by 7Two against the account statements the Clients receive directly from the Custodian. POOLED INVESTMENT VECHICLE 7Two will review any pooled investment vehicles, periodically conduct due diligence on the investments, review the status, financials, and progress of development of the investment, and continue communications with owners, officers, and directors of the investment. As deemed necessary, 7Two will provide communications to investors about the status of the pooled investment vehicle. Additionally, investors will be provided audited annual financial statements. I T E M 1 4 – C L I E N T R E F E R R A L S A N D O T H E R C O M P E N S A T I O N At times, 7Two will receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by investment sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which investment sponsors will underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. This may create a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of Clients. 7Two attempts to control this conflict by always basing investment decisions on the individual needs of Clients. 7Two and its supervised persons do not accept or receive compensation based on the sale of securities. Supervised people can be compensated for obtaining prospective clients through marketing initiatives. 7Two may be asked to recommend a financial professional, such as an attorney, accountant or mortgage broker. In such cases, 7Two does not receive any direct compensation in return for any referrals made to individuals or firms in its professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and Clients have the right to choose any financial professional to conduct business. Individuals and firms in 7Two’s financial professional network may refer clients to 7Two. Again, 7Two does not pay any direct compensation in return for any referrals. 7Two does recognize the fiduciary responsibility to place Client interests first and have established policies in this regard to mitigate any conflicts of interest. The Firm has been engaged as a promoter through an agreement with a third party independent registered investment adviser. In such instance, our Firm or its representatives acts as a promoter and receives a portion of the fee paid to this unaffiliated advisor. This does not raise the fee paid by the client and the client receives all required disclosure forms disclosing the terms of the promoter relationship at the time the referral is made. 4 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  PARTICIPATION IN INSTITUTIONAL ADVISOR PLATFORM 7Two has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like 7Two. As a registered investment Adviser participating on the Schwab Advisor Services platform, 7Two receives access to software and related support without cost because 7Two renders investment advisory services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit 7Two and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, 7Two endeavors at all times to put the interests of Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the adviser's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the adviser may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the adviser may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisers with access to technology, research, discounts and other services. In addition, the adviser receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the adviser in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Adviser – Schwab also offers other services and financial support to 7Two that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the adviser to recommend Schwab, which results in a potential conflict of interest. 7Two believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. I T E M 1 5 – C U S T O D Y 7Two does not have physical custody of any client funds and/or securities and does not take physical custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. DEDUCTION OF ADVISORY FEES 7Two is deemed to have limited custody of Client funds and securities whenever 7Two is given the authority to have fees deducted directly from client accounts. It should be noted that authorization to trade in Client accounts is not deemed by regulators to be custody. 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 from 7Two. When the Client has questions about their account statements, the Client should contact 7Two or the qualified custodian preparing the statement. STANDING LETTERS OF AUTHORIZATION TO 3RD PARTIES 7Two employs standing letters of authorization to direct Client requests for wire transfer of funds for first- party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the 5 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an Adviser who has the power to disburse Client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, 7Two has adopted the following safeguards in conjunction with its custodians. The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Private Fund Vehicles 7Two is deemed, under Rule 206(4)-2 of the Investment Advisers Act to have custody of the securities in our client Private Funds by virtue of the common control of 7Two and the General Partner of the Fund (or its equivalent). Investors will be provided with annual financial statements audited by an independent public accounting firm registered with the Public Company Accounting Oversight Board (PCAOB). Investors are urged to carefully review these statements. I T E M 1 6 – D I S C R E T I O N Before 7Two buys or sells securities on a Client’s behalf, a Client must first sign 7Two’s discretionary advisory agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, Clients may grant 7Two discretion over the selection and number of investments to be purchased or sold for their account(s) without obtaining the Client’s consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain investments or types of investments (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the Client by notifying 7Two in writing. Limitations on discretionary authority are required to be provided to the Investment Adviser Representative in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary advisory services. 7Two exercises discretion in managing the investments of the Private Funds based on the Funds’ investment objectives, policies, and strategies disclosed in the Offering Documents. 7Two generally contractually assumes discretionary authority over the assets of the Funds under investment advisory agreements entered into among 7Two and the Fund. 6 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P  I T E M 1 7 – V O T I N G C L I E N T S E C U R I T I E S 7Two recognizes its fiduciary responsibility to vote proxies solely in the client’s best interests. 7Two has adopted a Proxy Voting Policy as a means reasonably designed to ensure that 7Two votes any shares owned by clients, which have delegated discretionary proxy voting authority to 7Two, in the best interest of the clients considering all relevant factors and without regard to the interests of 7Two or other related parties. For purposes of 7Two’s Proxy Voting Policy, the “best interests of clients” means (unless with respect to a particular client, such client has otherwise specified) the clients’ best economic interests over the long term – that is, the common interest that all clients share in seeing the value of a common investment increase over time. 7Two will vote proxies in the best interests of the client and in accordance with its established policies and procedures. Our firm will retain all proxy-voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, and a copy of each written client request for information on how the adviser voted the proxies. Clients may obtain a copy of our complete proxy voting policy and procedure or information on how proxies for his/her shares were voted by contacting our office. Contact information found on the first page of this document 7Two will accept directions from a client to vote the client’s proxies in a manner that could result in its proxies being voted differently than 7Two might vote proxies of other clients over which 7Two has full discretionary proxy voting authority. 7Two believes such client directions are client selected guidelines and 7Two’s Proxy Voting Policy does not generally apply to customized proxy voting guidelines. Of course, clients can choose to vote their own proxies or to have a firm other than 7Two vote their proxies for them. 7Two has retained Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to provide proxy voting services. Broadridge is responsible for ensuring that all proxy ballots received for securities held in 7Two client accounts are submitted in a timely manner. 7Two can choose not to vote proxies if the effect on the client’s economic interests or the value of the portfolio holding is indeterminable or insignificant; if the cost of voting the proxy outweighs the possible benefit; or if a jurisdiction whose laws or regulations govern the voting of proxies with respect to the portfolio holding impose share blocking restrictions which prevent 7Two from exercising its voting authority. Administrative matters beyond 7Two’s control can at times prevent 7Twofrom voting proxies. I T E M 1 8 – F I N A N C I A L I N F O R M A T I O N As an advisory firm that maintains discretionary authority for Client accounts, 7Two is also required to disclose any financial condition that is reasonably likely to impair its ability to meet its contractual obligations. 7Two has no such financial circumstances to report. Under no circumstances does 7Two require or solicit payment of fees in excess of $1,200 per Client more than six (6) months in advance of services rendered. Therefore, 7Two is not required to include a financial statement. 7Two has not been the subject of a bankruptcy petition at any time during the past ten (10) years. 7 2 SevenTwo LLC Part 2A Brochure - June 2025 e g a P