7 Streets Financial, LLC, (hereinafter “7 Streets” or “firm” or “we”), is a state-registered investment adviser with its principal place of business located in California. 7 Streets began conducting business in 2016 as a DBA for our associated persons’ brokerage activity with LPL Financial and began conducting business as an independent investment adviser in May 1 2016. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Travis Lewis, Chief Executive Officer & President
• Joe Duca, Chief Compliance Officer & Vice President We offer the following advisory services to our clients: MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. Income with Capital Preservation: This model is appropriate for conservative investors with a low tolerance for risk, little need for growth, a need for current income, and/or a relatively short investment time horizon. It employs an asset allocation of 30% equity and 70% fixed income. Investments include mutual funds, stocks, and exchange traded funds and notes. Income with Moderate Growth: This model is appropriate for moderately conservative investors with a low risk tolerance, a small desire for growth, a preference for current income, and/or a short/intermediate investment time horizon. It employs an asset allocation of 45% equity and 55% fixed income. Investments include stocks, options, mutual funds, and exchange traded funds and notes. Growth with Income: This model is appropriate for moderate investors with adequate tolerance for risk, an equal desire for growth and current income, and/or an intermediate investment time horizon. It employs an asset allocation of 60% equity and 40% fixed income. Investments include stocks, options, mutual funds, and exchange traded funds and notes. Growth: This model is appropriate for moderately aggressive investors with a high tolerance for risk, a focus on growth of assets, little need for current income, and/or an intermediate/long investment time horizon. It employs an asset allocation of 75% equity and 25% fixed income. Investments include stocks, options, mutual funds, and exchange traded funds and notes. Aggressive Growth: This model is appropriate for aggressive investors with the highest risk tolerance, a desire for aggressive growth of assets, no need for current income, and/or a long investment time horizon. It employs an asset allocation of 100% equity. Investments include stocks, options, mutual funds, and exchange traded funds and notes. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Through personal discussions with the client in which the client’s goals and objectives are established, we determine if the model portfolio is suitable to the client’s circumstances. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio’s goal, rather than on each client’s individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in the account. Clients retain individual ownership of all securities.. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include, but are not limited to, advice regarding the following securities:
• Open-End Mutual Funds
• Individual Stocks
• Exchange Traded Funds
• Individual Bonds
• Unit Investment Trusts
• Closed-End Funds
• Traded and Non-Traded Business Development Companies
• Traded and Non-Traded Real Estate Investment Trusts
• Private Placements
• Hedge Funds
• Funds of Funds
• Exchange Traded Options
• Limited Partnerships
• Master Limited Partnerships (MLPs)
• Variable Annuities
• Managed Futures Funds
• Equipment Leasing Funds
• Oil & Gas Partnerships Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client’s financial circumstances, we will: 1. Send annual written reminders to each client requesting any updated information regarding changes in the client’s financial situation and investment objectives; 2. At least annually, contact each participating client to determine whether there

have been any changes in the client’s financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. Be reasonably available to consult with the client; and 4. Maintain client suitability information in each client’s file. WRAP FEE PROGRAM In addition to the portfolio management service described above, we have also developed and sponsor the 7 Streets Wrap program. Only our investment adviser representatives are able to open accounts for clients through the 7 Streets Wrap program. Therefore, participants in the 7 Streets Wrap program must be advisory clients of 7 Streets. All clients must execute a Wrap Fee Program Client Agreement prior to establishing an account(s) through the 7 Streets Wrap program. Under the 7 Streets Wrap program, we provide investment supervisory services defined as giving continuous investment advice to a client and making investments for the client based on the individual needs of the client. Through this service, we offer a customized and individualized investment program for clients. There are no differences between the management styles of a wrap fee portfolio or one that is not. There is a difference between the fees. Our wrap fee (the fee we charge) covers all trading costs associated with the trade of a stock. The accounts that are not wrap-fee accounts are charged our fee as well as the cost to make the trade. As the sponsor of a wrap fee program, 7 Streets receives a portion of the wrap fee for our services. Various investment strategies are provided under the 7 Streets Wrap program; however, a specific investment strategy is crafted to focus on the specific client’s goals and objectives. Depending on the client’s individual needs, investment recommendations will be made in, but not necessarily limited to, no- load mutual funds, equity positions, and fixed income positions. This section is intended as a brief summary of the 7 Streets Wrap program. Clients contracting for the 7 Streets Wrap program will receive our Wrap Fee Program Brochure (Part 2A Appendix 1 of Form ADV) which provides detailed information regarding the 7 Streets Wrap program. FINANCIAL PLANNING We provide both comprehensive and hourly consulting financial planning services. Financial planning is a comprehensive as well as limited evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service may receive a written report which provides the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. In general, the financial plan can address some or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. For comprehensive plans, we gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes toward risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. Typically the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. All recommendations are of a generic nature. AMOUNT OF MANAGED ASSETS As of January 1, 2024 we manage assets of $88,400,000 on a discretionary basis.