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FIRM BROCHURE
(Part 2A of Form ADV)
Item 1 Cover Page
March 30, 2026
Three Bridge Wealth Advisors
CRD # 150460
240 Third Street
Suite 110
Los Altos, CA 94022
Phone: (650) 433-3500
www.threebridgewa.com
this Brochure, please
contact us at
Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and
business practices of Three Bridge Wealth Advisors. If you have any questions about the
(650) 433-3500 and/or
contents of
www.threebridgewa.com . The information in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Three Bridge Wealth Advisors is registered as an investment adviser with the Securities
and Exchange Commission; however, such registration does not imply a certain level of
skill or training and no inference to the contrary should be made.
Additional information about Three Bridge Wealth Advisors is also available on the SEC’s
website at www.adviserinfo.sec.gov.
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ITEM 2: MATERIAL CHANGES
Form ADV Part 2 requires registered investment advisers to amend their brochure when
information becomes materially inaccurate. If there are any material changes to an adviser's
disclosure brochure, the adviser is required to notify you and provide you with a description of
the material changes.
Since our last annual updating amendment dated, March 27, 2025, we have no material changes
to report.
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ITEM 3: TABLE OF CONTENTS
Item Number
Page
ITEM 4: ADVISORY BUSINESS
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ITEM 5: FEES AND COMPENSATION
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ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
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ITEM 7: TYPES OF CLIENTS
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ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
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ITEM 9: DISCIPLINARY INFORMATION
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ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
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ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
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ITEM 12: BROKERAGE PRACTICES
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ITEM 13: REVIEW OF ACCOUNTS
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ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
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ITEM 15: CUSTODY
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ITEM 16: INVESTMENT DISCRETION
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ITEM 17: VOTING CLIENT SECURITIES
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ITEM 18: FINANCIAL INFORMATION
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ITEM 19: ADDITIONAL INFORMATION
19
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Item 4: Advisory Business
Founded in 2009, Three Bridge Wealth Advisors is a Los Altos, California based registered
Investment Adviser, registered with the Securities and Exchange Commission (“SEC”) and
located at 240 Third Street, Suite 110, Los Altos, CA 94022. The principal owners of the firm are
Eric T. Thurber, and Brett Sharkey.
Types of Advisory Services Offered
Wealth Management
We emphasize continuous and regular account supervision. As part of our wealth management
service, we conduct at least one, but sometimes more than one meeting (in person, if possible,
otherwise via telephone conference) with clients in order to understand their current financial
situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we
propose an investment approach to the client. We will propose an investment portfolio, consisting
of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the
client’s agreement with the proposed investment plan, we work with the client to establish or
transfer investment accounts so that we can manage the client’s portfolio. Once the relevant
accounts are under our management, we review such accounts on a regular basis and at least
quarterly. We may periodically rebalance or adjust client accounts under our management. If the
client experiences any significant changes to his/her financial or personal circumstances, the client
must notify us so that we can consider such information in managing the client’s investments.
Financial planning services may be provided at no additional cost to our Wealth Management
clients.
Selection of Third-Party Investment Managers
Three Bridge Wealth Advisors works with Independent Money Managers to help meet the goals
of our clients. The Independent Money Managers may charge a fee separately in addition to the
fee Three Bridge Wealth Advisors charge. Both our firm and the Independent Money Manager
will separately deduct their/our respective advisory fees due from the client. Where applicable,
please refer to the contracts of the Independent Money Manager for more details. The client can
make additions to and withdrawals from his/her account at any time, subject to our right to
terminate an account. Before selecting other advisers, we make sure that the other advisers are
properly licensed or registered. We continue to provide services relative to the discretionary or
non-discretionary selection of the Independent Money Managers and will continue to design an
investment portfolio with certain Independent Managers. On an ongoing basis, we monitor the
performance of those accounts being managed by Independent Money Managers. We seek to
ensure the Independent Money Managers’ strategies and target allocations remain aligned with
the clients’ investment objectives and overall best interests.
Clients can withdraw account assets on notice to us, subject to the usual and customary securities
settlement procedures. In certain circumstances, you may not be able to withdraw funds invested
in illiquid investments prior to the investment’s dissolution and liquidation. We design a client’s
portfolio as long-term investments and assets withdrawals may impair the achievement of a
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client’s investment objectives. Additions may be in cash or securities provided that we reserve the
right to liquidate any transferred securities or decline to accept particular securities into a client’s
account. We may consult with our clients about the options and ramifications of transferring
securities. Clients are advised that when transferred securities are liquidated, they are subject to
transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge)
and/or tax ramifications. In the case of valuing non-liquid asset classes, our firm relies on
valuations provided in statements received directly from third party managers or the issuers. The
financial statements associated with certain illiquid securities are audited no less than annually,
and valuation adjustments resulting from the audits are reflected in subsequent fee invoices. In
connection with assets invested in private real estate funds, it may be the practice of the funds to
hold assets at their original cost until the point where there is an action causing them to adjust this
basis, such as an asset sale.
Financial Planning and Consulting Services
We provide a variety of financial planning and consulting services to individuals, families and
other clients regarding the management of their financial resources based upon an analysis of
clients’ current situation, goals, and objectives. Generally, such financial planning services will
involve preparing a financial plan or rendering a financial consultation for clients based on the
client’s financial goals and objectives. We will conduct one or more meetings (in person, if
possible, otherwise via telephone conference) with the client in order to understand the client’s
current financial situation, financial goals, specific issues or questions, and topics to be covered
by the financial plan. We may also request copies of relevant financial documents, such as
account statements, income tax returns, insurance policies, retirement plans, estate planning
documents, and business financial statements.
We typically incorporate our financial planning and consulting services for wealth
management clients with more of a holistic approach which may or may not include a
written financial plan.
Our plans and consultations may encompass one or more of the following areas: Investment
Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning,
Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate
Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and
Personal Financial Planning, Bill Pay and/or Bookkeeping Services. Our written financial plans
or financial consultations rendered to clients usually include general recommendations for a
course of activity or specific actions to be taken by the clients. For example, recommendations
may be made that the clients begin or revise investment programs, create or revise wills or trusts,
obtain or revise insurance coverage, commence or alter retirement savings, or establish education
or charitable giving programs. It should also be noted that we refer clients to an accountant,
attorney or other specialist, as necessary for non-advisory related services. For written financial
planning engagements, we provide our clients with a written summary of their financial situation,
observations, and recommendations. For financial consulting engagements, we usually do not
provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed
within six (6) months of the client signing a contract with us, assuming that all the information
and documents we request from the client are provided to us promptly. Implementation of the
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recommendations will be at the discretion of the client. Clients should be aware that we prepare
financial plans based on the information provided by the client and as of the date that the plan is
submitted to the client. We undertake no responsibility to update the financial plan unless we and
the client agree upon a subsequent financial planning engagement.
Prior to engaging Three Bridge Wealth Advisors to provide investment advisory services, the
client will be required to enter into one or more written agreements with Three Bridge Wealth
Advisors setting forth the terms and conditions under which Three Bridge Wealth Advisors shall
render its services (collectively the "Agreement").
In accordance with Rule 204-3 under the Investment Advisers Act of 1940, as amended
("Advisers Act"), Three Bridge Wealth Advisors will provide a brochure and one or more
brochure supplements to each client or prospective client prior to or contemporaneously with the
execution of an investment advisory agreement.
The Agreement between Three Bridge Wealth Advisors and the client will continue in effect until
terminated by either party pursuant to the terms of the Agreement. Three Bridge Wealth Advisors’
annual fee shall be prorated through the date of termination as defined in the Agreement and any
remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner.
Three Bridge Wealth Advisors does not offer Wrap Fee Program accounts.
As of December 31, 2025, the following represents the amount of client assets under
management by Three Bridge Wealth Advisors on a discretionary and non-discretionary basis:
Type of Account
Assets Under Management
("AUM")
Discretionary
Non-Discretionary
Total:
$ 1,045,756,051
$0
$ 1,045,756,051
ITEM 5: FEES AND COMPENSATION
Wealth Management
The maximum annual fee charged by Three Bridge Wealth Advisors will not exceed 1.00%. Our
firm usually requires a minimum annual fee of $25,000 for all types of advisory relationships.
Clients with Assets Under Management of less than $2,500,000 may exceed our typical
maximum fee of 1% when our minimum account fee is applied. The exact percentage charged
will be specified on the client’s advisory contract when he/she becomes one of our clients. Our
firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based upon the average
daily balance of the assets in the previous quarter. Fees will be adjusted for deposits and
withdrawals made during the quarter. Fees are generally negotiable and will be deducted from
your managed account. As part of this process, you understand and acknowledge the following:
a) Your independent custodian sends statements at least quarterly to you showing the
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market values for each security included in the Assets and all disbursements in your account
including the amount of the advisory fees paid to us; b) You provide authorization permitting us
to be directly paid by these terms. We send our invoice directly to the custodian; and c) If we send
a copy of our invoice to you, we recommend that you compare information provided in our
statement with those from the qualified custodian.
Selection of Third-Party Investment Managers
Three Bridge Wealth Advisors work with Independent Money Managers to help meet the goals of
our clients. The Independent Money Managers can charge a fee separately in addition to the fee
Three Bridge Wealth Advisors charge. Both our firm and the Independent Money Manager will
separately deduct their/our respective advisory fees due from the client. Please refer to the
contracts and/or disclosure documents of the Independent Money Manager for more details. The
client may make additions to and withdrawals from his/her account at any time, subject to our
right to terminate an account.
Clients may withdraw account assets on notice to us, subject to the usual and customary securities
settlement procedures. In certain circumstances, you may not be able to withdraw funds invested
in illiquid investments prior to the investment’s dissolution and liquidation. We design a client’s
portfolio as long-term investments and assets withdrawals may impair the achievement of a
client’s investment objectives. Additions may be in cash or securities provided that we reserve the
right to liquidate any transferred securities or decline to accept particular securities into a client’s
account. We may consult with our clients about the options and ramifications of transferring
securities. Clients are advised that when transferred securities are liquidated, they are subject to
transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge)
and/or tax ramifications.
In the case of valuing non-liquid asset classes, our firm relies on valuations provided in statements
received directly from third party managers. The financial statements associated with certain
illiquid securities are audited no less than annually, and valuation adjustments resulting from the
audits are reflected in subsequent fee invoices. Because valuations may only be provided
periodically (including monthly, quarterly or even annually), we can be billing on a valuation that
would be different if updated. That valuation can be higher or lower depending on the increase or
decrease in value of the private investment. In connection with assets invested in private real estate
funds, it may be the practice of the funds to hold assets at their original cost until the point where
there is an action causing them to adjust this basis, such as an asset sale.
Financial Planning and Consulting Services
We charge on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity
of our engagement with you. Our hourly fee ranges between $350-500. Flat fees generally range
from $2,500 - $50,000. Fees are generally negotiable, and we reserve the right to waive the
financial planning and consulting fees for wealth management clients. We require a retainer of
fifty percent (50%) of the ultimate financial planning or consulting fee with the remainder of the
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fee directly billed to you and due to us within thirty (30) days of your financial plan being
delivered or consultation rendered to you. In all cases, we will not require a retainer exceeding
$1,200 when services cannot be rendered within 6 (six) months.
Terminations and Refunds
We charge our advisory fees quarterly in arrears. In the event that you wish to terminate our
services, you will need to contact us in writing and state that you wish to terminate our services.
Upon receipt of your letter of termination, we will proceed to calculate a pro-rated final fee and
proceed to close out your account. We will notify the custodian of your assets of the termination
and we will no longer provide advice or any other services to the account. It is your responsibility
to manage the assets or hire a new advisor.
We charge our financial planning and financial consulting fees on an individual basis. In the event
that you wish to terminate our services, we will refund the unearned portion of our advisory fee
to you. You need to contact us in writing and state that you wish to terminate our services. Upon
receipt of your letter of termination, we will proceed and process a pro-rata refund of any
unearned advisory fees. In the event that we are compensated through a flat fee and you terminate
the financial planning agreement prior to completion of the work specified in client agreement,
you shall be billed for the actual hours spent prior to termination times our hourly rate.
Other Investment Products
Some persons providing investment advice on behalf of Three Bridge Wealth Advisors are
licensed registered representatives of Purshe Kaplan Sterling, Inc. (“PKS”), member
FINRA/SIPC. This practice presents a conflict of interest because persons providing investment
advice on behalf of Three Bridge Wealth Advisors, who are registered representatives of PKS,
have an incentive to recommend other investment products to you for the purpose of generating
commissions rather than solely based on your needs. You are under no obligation, contractually,
or otherwise, to purchase investment products through any person affiliated with Three Bridge
Wealth Advisors. Although our supervised persons may accept compensation for the sale of
securities or other investment products, including distribution or service (“trail”) fees from the
sale of mutual funds, you should be aware that it is the policy of Three Bridge Wealth Advisors
to not engage in commissionable sales with advisory clients.
In addition, some persons providing investment advice on behalf of Three Bridge Wealth
Advisors are licensed as independent insurance agents. These persons will earn commission-
based compensation for selling insurance products, including insurance products they sell to you.
Insurance commissions earned by these persons are separate and in addition to our advisory fees.
This practice presents a conflict of interest because persons providing investment advice on
behalf of Three Bridge Wealth Advisors who are insurance agents have an incentive to
recommend insurance products to you for the purpose of generating commissions rather than
solely based on your needs. You should be aware that it is the policy of Three Bridge Wealth
Advisors not to engage in commissionable sales with advisory clients. You are under no
obligation, contractually or otherwise, to purchase insurance products through any person
affiliated with Three Bridge Wealth Advisors.
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ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Our firm does not charge performance fees. Clients, however, may be subject to performance-
imposed by a third-party fund manager in connection with investment
based fees
recommendations.
ITEM 7: TYPES OF CLIENTS
We have the following types of clients:
Individuals;
•
• High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, limited liability companies and/or other business types.
We generally impose a minimum portfolio size of $2,000,000. In addition, our firm usually
requires a minimum annual fee of $25,000 for all types of advisory relationships. We can waive
this minimum at our discretion.
If and when we utilize certain Independent Manager(s), these Independent Manager(s) may
impose more restrictive account requirements and varying billing practices than ours. In such
instances, we may alter corresponding account requirements and/or billing practices to
accommodate those of the Independent Manager(s) or wrap fee program sponsor.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis
• Charting;
• Fundamental;
• Technical
We can recommend to clients that are “accredited investors” as defined under Rule 501 of the
Securities Act of 1933, as amended, invest in private placement securities, which may include
debt, equity, and/or pooled investment vehicles when it is consistent to do so with the client’s
investment objectives. When we recommend that the client invest in private placement securities,
we shall receive no additional compensation but shall continue to receive applicable investment
advisory fees on the private placement securities that are under management.
Investment Strategies
• Long Term Purchases (Securities Held at Least a Year);
• Private Funds;
• Real Estate Investment Trusts (“REIT”);
• Short Term Purchases (Securities Sold Within a Year).
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A private fund is an investment vehicle that pools capital from a number of investors and invests
in securities and other instruments. In almost all cases, a private fund is a private investment
vehicle that is typically not registered under federal or state securities laws. So that private funds
do not have to register under these laws, issuers make the funds available only to certain
sophisticated or accredited investors. Private funds are generally smaller than mutual funds
because they are often limited to a small number of investors and have a more limited number of
eligible investors. Many but not all private funds use leverage as part of their investment
strategies. Private funds management fees typically include a base management fee along with a
performance component. In many cases, the fund’s managers may become “partners” with their
clients by making personal investments of their own assets in the fund. Most private funds offer
their securities by providing an offering memorandum or private placement memorandum
(“PPM”). The PPM covers important information for investors and investors should review this
document carefully and should consider conducting additional due diligence before investing in
the private fund. The primary risks of private funds include the following: (1) Private funds do
not sell publicly and are therefore illiquid. An investor may not be able to exit a private fund or
sell its interests in the fund before the fund closes; and (2) Private funds are subject to various
other risks, including risks associated with the types of securities that the private fund invests in
or the type of business issuing the private placement.
REITs primarily invest in real estate or real estate-related loans. Equity REITs own real estate
properties, while mortgage REITs hold construction, development and/or long-term mortgage
loans. Changes in the value of the underlying property of the trusts, the creditworthiness of the
issuer, property taxes, interest rates, tax laws, and regulatory requirements, such as those relating
to the environment all can affect the values of REITs. Both types of REITs are dependent upon
management skill, the cash flows generated by their holdings, the real estate market in general,
and the possibility of failing to qualify for any applicable pass-through tax treatment or failing to
maintain any applicable exempt status afforded under relevant laws.
As previously discussed above, we can recommend that clients authorize the active discretionary
management of a portion of their assets by and/or among certain Independent Manager(s), based
upon the stated investment objectives of the client. We shall continue to render services to the
client relative to the discretionary and/or non-discretionary selection of Independent Manager(s)
as well as monitoring and reviewing account performance and client investment objectives. When
we select an Independent Manager for a client, we shall review information about the
Independent Manager(s). For example, we review the Independent Manager(s) investment
strategies, past performance and risk results to the extent available.
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation
of the risks involved with respect to our investment management activities. Investing in securities
involves risk of loss that clients should be prepared to bear. While the stock market may increase
and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and
your account(s) could suffer a loss.
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Prior to entering into an agreement with Three Bridge Wealth Advisors, a client should carefully
consider that volatility from investing in the stock and bond market can occur and that over time
the client's assets can or will fluctuate and at any time be worth more or less than the amount
invested. It is important that you understand the risks associated with investing in the stock
market, are appropriately diversified in your investments, and ask us any questions you may have.
Clients should consult with their legal, tax, and other advisors before engaging the Firm to
provide investment management services on their behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be
guided accordingly. The profitability of a significant portion of Three Bridge recommendations
and/or investment decisions may depend to a great extent upon correctly assessing the future
course of price movements of stocks, bonds and other asset classes. In addition, investments
may be adversely affected by financial markets and economic conditions throughout the world.
There can be no assurance that Three Bridge will be able to predict these price movements
accurately or capitalize on any such assumptions.
Private Investments
For private investments, the PPM covers important information and as such investors should
review this document carefully, including the risk factors, and should consider conducting
additional due diligence before investing. The primary risks of private funds include illiquidity
and the risks associated with the underlying investments.
Cash Management Risks
We may invest some of a client’s assets temporarily in money market funds or other similar types
of investments, during which time an advisory account may be prevented from achieving its
investment objective. We generally invest client’s cash balances in money market funds, FDIC
Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt
instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through
relatively low-risk conservative investments. In most cases, at least a partial cash balance will be
maintained in a money market account so that our firm may debit advisory fees for our services
related to comprehensive portfolio management, wealth management service and portfolio
monitoring, as applicable.
ITEM 9: DISCIPLINARY INFORMATION
Registered investment advisers such as Three Bridge Wealth Advisors are required to disclose all
material facts regarding any legal or disciplinary events that would be material to a client's or
prospective client’s evaluation of Three Bridge Wealth Advisors or the integrity of its
management. On September 27, 2019, we settled a matter with the SEC involving two instances
in 2015 in which we voted client proxies without authority to do so and related inaccuracies in
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our brochure disclosures regarding proxy voting authority. The SEC’s order stated that this
constituted a violation of Section 206(2) of the Advisers Act. We paid a civil monetary penalty
of $60,000 on September 30, 2019, and were ordered to cease and desist from future violations
of Section 206(2).
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Some persons providing investment advice on behalf of Three Bridge Wealth Advisors are
licensed registered representatives of Purshe Kaplan Sterling, Inc. (“PKS”), member
FINRA/SIPC. This practice presents a conflict of interest because persons providing investment
advice on behalf of Three Bridge Wealth Advisors, who are registered representatives of PKS,
have an incentive to recommend other investment products to you for the purpose of generating
commissions rather than solely based on your needs. You are under no obligation, contractually,
or otherwise, to purchase investment products through any person affiliated with Three Bridge
Wealth Advisors. Although our supervised persons may accept compensation for the sale of
securities or other investment products, including distribution or service (“trail”) fees from the
sale of mutual funds, you should be aware that it is the policy of Three Bridge Wealth Advisors
to not engage in commissionable sales with advisory clients.
Some persons providing investment advice on behalf of Three Bridge Wealth Advisors are
licensed as independent insurance agents. These persons will earn commission-based
compensation for selling insurance products, including insurance products they sell to you.
Insurance commissions earned by these persons are separate and in addition to our advisory fees.
This practice presents a conflict of interest because persons providing investment advice on behalf
of Three Bridge Wealth Advisors who are insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than solely based on
your needs. You should be aware that it is the policy of Three Bridge Wealth Advisors not to
engage in commissionable sales with advisory clients. You are under no obligation, contractually
or otherwise, to purchase insurance products through any person affiliated with Three Bridge
Wealth Advisors.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore,
our Code of Ethics includes guidelines for professional standards of conduct for persons
associated with our firm. Our goal is to protect your interests at all times and to demonstrate our
commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons
associated with our firm are expected to adhere strictly to these guidelines. Persons associated
with our firm are also required to report any violations of our Code of Ethics.
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Additionally, we maintain and enforce written policies reasonably designed to prevent the
misuse or dissemination of material, non-public information about you or your account holdings
by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm have any material financial interest in
client transactions beyond the provision of investment advisory services as disclosed in this
brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell securities for you at the same time
we or persons associated with our firm buy or sell such securities for our own account. A conflict
of interest exists in such cases because we have the ability to trade ahead of you and potentially
receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our
policy that neither our firm nor persons that are deemed “access persons” under the code of
ethics rule shall have priority over your account in the purchase or sale of securities, nor are they
allowed to trade prior to our transactions in your accounts.
Compliance with Department of Labor Fiduciary Rule
The DOL adopted Prohibited Transaction Exemption 2020‐02 (“PTE 2020‐ 02”) which expands
the definition of advice covered under ERISA law to include recommendations about retirement
plan rollovers and Individual Retirement Accounts (“IRAs”). Generally, we do not provide
solicited recommendations that you withdraw the assets from your employer's retirement plan
and roll the assets over to an individual retirement account ("IRA") that we manage on your
behalf. Nevertheless, we are aware of the due diligence requirements when determining whether
to complete the rollover to an IRA, to include various options that would be available to a client
with an emphasis on the costs and benefits of each option.
ITEM 12: BROKERAGE PRACTICES
The Custodian & Brokers We Use
Our firm does not maintain physical custody of your assets (although we may be deemed to have
custody of your assets (see Item 15 Custody, below). Your assets must be maintained in an
account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our
clients use Charles Schwab & Co., Inc. or TD Ameritrade Clearing, Inc (both referred to as
“Clearing Firm” or “Clearing Firms”) FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. We are independently owned and operated and not affiliated with either
Clearing Firm. Clearing Firms will hold your assets in a brokerage account and buy and sell
securities when we instruct them to.
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While we recommend that you use the Clearing Firms as custodian/broker, you will decide
whether to do so and open your account with a Clearing Firm by entering into an account
agreement directly with them. We do not open the account for you.
Even though your account is maintained at a Clearing Firm, we can still use other brokers to
execute trades for your account, as described in the next paragraph.
How We Select Brokers/Custodians to Recommend
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
• capability to execute, clear and settle trades (buy and sell securities for your account)
• capabilities to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• availability of investment research and tools that assist us in making investment decisions
quality of services
• competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
their prior service to us and our other clients
•
•
• availability of other products and services that benefit us, as discussed below (see
“Products and Services Available to us from Schwab”)
Your Custody & Brokerage Costs
For our clients’ accounts it maintains, Clearing Firms generally does not charge you separately
for custody services but is compensated by charging you commissions or other fees on trades that
it executes or that settle into your Clearing Firm account. For some accounts, the Clearing Firms
may charge you a percentage of the dollar amount of assets in the account in lieu of commissions.
The Clearing Firm’s commission rates and/or asset-based fees applicable to our client accounts
were negotiated based on our commitment to maintain a minimum threshold of our clients’ assets
statement equity in accounts at the Clearing Firms. This commitment benefits you because the
overall commission rates and/or asset-based fees you pay are lower than they would be if we had
not made the commitment. In addition to commissions or asset-based fees the Clearing Firms
charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we
have executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your Clearing Firm account. These fees are in addition
to the commissions or other compensation you pay the executing broker-dealer.
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Because of this, in order to minimize your trading costs, we have the Clearing Firm execute most
trades for your account.
Products and Services Available to us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business unit
serving independent investment advisory firms such as Three Bridge Wealth Advisors. They
provide us and our clients with access to its institutional brokerage – trading, custody, reporting
and related services – many of which are not typically available to Schwab retail customers.
Schwab also makes available various support services. Some of those services help us manage
or administer our clients’ accounts while others help us manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (we don’t have to request them)
and at no charge to us as long as we keep a total of at least $10 million of our clients’ assets in
accounts at Schwab. If we have less than $10 million in client assets at Schwab, it may charge us
quarterly service fees. Here is a more detailed description of Schwab’s support services:
Services that Benefit You
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products
available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s
services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or some substantial number of our clients’
accounts, including accounts not maintained at Schwab. In addition to investment research,
Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
•
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;
facilitate payment of our fees from our clients’ accounts; and
• provide pricing and other market data;
•
• assist with back-office functions, recordkeeping and client reporting
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Services that Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
•
access to employee benefits providers, human capital consultants and insurance
providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of
these services or pay all or a part of a third party’s fees. Schwab may also provide us with other
benefits such as occasional business entertainment of our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance your
experience, help you reach your goals and put your interests before that of our firm or its
associated persons.
Our Interest in Charles Schwab’s and TD Ameritrade’s Services
The availability of these services from the Clearing Firms benefits us because we do not have to
produce or purchase them. We don’t have to pay for the Clearing Firm’s services so long as we
keep a total of at least $10 million of client assets in accounts at the Clearing Firms. Beyond that,
these services are not contingent upon us committing any specific amount of business to the
Clearing Firms in trading commissions or assets in custody. The $10 million minimum may give
us an incentive to recommend that you maintain your account with the Clearing Firms based on
our interest in receiving services that benefit our business rather than based on your interest in
receiving the best value in custody services and the most favorable execution of your
transactions. This is a potential conflict of interest. We believe, however, that our selection of
both Clearing Firms as custodian and broker is in the best interests of our clients. It is primarily
supported by the scope, quality and price of both Clearing Firm’s services (based on the factors
discussed above – see “How We Select Brokers/Custodians to Recommend”) and not the
Clearing Firm’s services that benefit only us. We have over $400 million in client assets under
management, and do not believe that maintaining at least $10 million of those assets at the
Clearing Firms in order to avoid paying quarterly service fees presents a material conflict of
interest.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the
position it should have been in had the trading error not occurred. Depending on the
circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or
reimbursing the account. If a trade error results in a profit, the trade error will be corrected in the
trade error account of the executing broker-dealer, and you will keep the profit.
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ITEM 13: REVIEW OF ACCOUNTS
We review accounts on at least a quarterly basis for our Wealth Management clients. The nature
of these reviews is to learn whether clients’ accounts are in line with their investment objectives,
appropriately positioned based on market conditions, and investment policies, if applicable. Only
our Financial Advisors will conduct reviews. We do not provide written reports to clients, unless
asked to do so. Verbal reports to clients take place on at least an annual basis when we contact
clients. Financial Planning/Financial Consulting clients do not receive reviews or updates to their
written plans unless they take action to schedule a financial consultation with us. We do not
provide ongoing services to financial planning clients, but are willing to meet with such clients
upon their request to discuss updates to their plans, changes in their circumstances, etc. We may
review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
We may receive an economic benefit from the Clearing Firms in the form of the support products
and services it makes available to us and other independent investment advisors that have their
clients maintain accounts at the Clearing Firms. These products and services, how they benefit
us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices).
The availability to us of products and services is not based on us giving particular investment
advice, such as buying particular securities for our clients. We may pay referral fees (non-
commission based) to independent promoters (non-registered representatives) for the referral of
their clients to our firm. Such referral fee represents a share of our investment advisory fee
charged to our clients. This arrangement will not result in higher costs for you.
ITEM 15: CUSTODY
Payment of Advisory Fees
We are deemed to have custody of client funds and securities because we are given the ability to
debit client accounts for payment of our fees. As such, client funds and securities are maintained
at one or more financial institutions that serve as the qualified custodian with respect to such
assets. Such qualified custodians will send account statements to clients at least once per calendar
quarter that detail any transactions in such account for the relevant period.
If you have a question regarding your account statement, or if you did not receive a statement
from your custodian, please contact us immediately at the telephone number on the cover page
of this brochure.
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Wire Transfers and/or Check-Writing Authority and/or Standing Letters of Authorization
Our firm, or persons associated with our firm, may effect wire transfers from client accounts to
one or more third parties designated, in writing, by the client without obtaining written client
consent for each separate, individual transaction, or we may have signatory and check writing
authority also referred to “bill paying services” for client accounts, as long as the client has
provided us with written authorization to do so. Such written authorization is known as a Standing
Letter of Authorization (“SLOA”). An adviser with authority to conduct such third-party wire
transfers or provides bill payments on a client's behalf has access to the client's assets and
therefore has custody of the client's assets in any related accounts.
However, we do not have to obtain a surprise annual audit, as we otherwise would be required to
by reason of having custody, as long as we meet the following criteria:
1. You provide a written, signed instruction to the qualified custodian that includes the third
party’s name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified
schedule or from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides
a transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at
the same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction
and an annual notice reconfirming the instruction.
In addition, we are deemed to have custody over clients’ cash, bank accounts or securities (for
reasons other than those discussed above), and we have engaged an independent accounting firm
to perform a surprise annual examination of those assets and accounts over which we maintain
custody for reasons other than debiting our fees or being given SLOAs. Any related opinions
issued by an independent accounting firm are filed with the SEC and are publicly available on
the SEC’s Investment Adviser Public Disclosure website.
ITEM 16: INVESTMENT DISCRETION
We accept discretionary authority to manage securities accounts on behalf of clients. Our clients
need to sign a discretionary investment advisory agreement with our firm for the management of
their account. This type of agreement only applies to our Wealth Management clients.
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ITEM 17: VOTING CLIENT SECURITIES
Without exception, we will not vote proxies on behalf of your advisory accounts. At your request,
we may offer you advice regarding corporate actions and the exercise of your proxy voting
rights. If you own shares of applicable securities, you are responsible for exercising your right
to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However,
in the event we were to receive any written or electronic proxy materials, we would forward
them directly to you by mail, unless you have authorized our firm to contact you by electronic
mail, in which case, we would forward any electronic solicitation to vote proxies.
ITEM 18: FINANCIAL INFORMATION
We do not require nor do we solicit prepayment of more than $1,200 in fees per client, six months
or more in advance. As such, we have not included a balance sheet for our most recent fiscal year.
Three Bridge Wealth Advisors has not been the subject of a bankruptcy petition.
ITEM 19: ADDITIONAL INFORMATION
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure. We do not disclose any nonpublic personal information about
you to any nonaffiliated third parties, except as permitted by law. In the course of servicing your
account, we may share some information with our service providers, such as transfer agents,
custodians, broker-dealers, accountants, consultants, and attorneys.
We restrict internal access to nonpublic personal information about you to employees who need
that information in order to provide products or services to you. We maintain physical and
procedural safeguards that comply with regulatory standards to guard your nonpublic personal
information and to ensure our integrity and confidentiality. We will not sell information about
you or your accounts to anyone. We do not share your information unless it is required to process
a transaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory
agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice
to you on an annual basis. Please contact our main office at the telephone number on the cover
page of this brochure if you have any questions regarding this policy.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether
you are eligible to participate in class action settlements or litigation nor do we initiate or
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participate in litigation to recover damages on your behalf for injuries as a result of actions,
misconduct, or negligence by issuers of securities held by you.
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