A. Describe your advisory firm, including how long you have been in business. Identify your
principal owner(s).
Seven Bridges is a Delaware limited liability company formed on July 18, 2011.
Seven Bridges offers discretionary and non-discretionary investment management services for separate
accounts of high net-worth individuals and institutional clients such as charitable and not-for-profit
institutions, family offices and trusts (“Advisory Clients”). In addition, Seven Bridges serves as an
investment adviser to domestic and foreign pooled investment vehicles (“Fund Clients”) and as a sub-
advisor to SALI Fund Management, LLC (“SALI”) with respect to a number of pooled investment vehicles
formed as separate series of a multi-series domestic limited partnership (the “IDF Clients”, and together
with the Fund Clients and the Advisory Clients, “Clients”).
With respect to Advisory Clients, Seven Bridges has responsibility for making investment
recommendations, subject to the specific guidelines established for each such Advisory Client in
accordance with the Advisory Client’s needs, long-term goals and risk profile. In particular, Seven Bridges
makes recommendations with respect to customized asset allocations for its Advisory Clients, including
allocations to separately managed accounts (“Separately Managed Accounts”), mutual funds,
exchange-traded funds (“ETFs”) and pooled investment vehicles, including hedge funds and private equity
funds (“Investment Vehicles”), in each case, managed by unaffiliated professional investment managers
(“Managers”). In addition, Seven Bridges has recommended, and may in the future recommend, that an
Advisory Client invest in one or more of its Fund Clients.
Seven Bridges’ Fund Clients are organized either as domestic limited partnerships or Cayman Islands
companies. Fund Clients organized as Cayman Islands companies invest substantially all of their assets in
the domestic limited partnerships in “mini-master feeder” structures, with affiliates of Seven Bridges, Seven
Bridges GP LLC and Seven Bridges GP II LLC (“Seven Bridges GPs”), serving as the general partners of
these domestic limited partnerships and Seven Bridges serving as investment adviser to both the domestic
limited partnerships and the Cayman Islands companies. Seven Bridges, on a discretionary basis, allocates
the assets of its Fund Clients to Investment Vehicles and, on occasion, to Separately Managed Accounts.
Each of the IDF Clients is formed as a separate series of a multi-series domestic limited partnership (the
“SALI Partnership”). The series are offered only to insurance company investors on behalf of certain of
their segregated separate accounts that are funded by life insurance and variable annuity contracts issued to
policy owners by such investors. SALI is the investment advisor of the SALI Partnership and has engaged
Seven Bridges to serve as a sub-advisor with respect to investments made by the IDF Clients. On the basis
of discretionary investment recommendations made by Seven Bridges, SALI invests the assets of IDF
Clients in Investment Vehicles and, on occasion, Separately Managed Accounts.
The Fund Clients and the IDF Clients are neither registered under the Securities Act of 1933, as amended,
nor registered under the Investment Company Act of 1940, as amended. Accordingly, interests in Fund
Clients and IDF Clients are offered exclusively to investors satisfying the applicable eligibility and
suitability requirements either in private placement transactions within the United States or in non-U.S.
transactions. No offer to sell interests in the Fund Clients or the IDF Clients is made by the descriptions in
this Brochure. Please see Item 7 of this Brochure for more information with respect to Seven Bridges’
Clients.
Laurence W. Cohen and Matthew Ram Lee are the principal owners of Seven Bridges.
B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a
particular type of advisory service, such as financial planning, quantitative analysis, or market
timing, explain the nature of that service in greater detail. If you provide investment advice only
with respect to limited types of investments, explain the type of investment advice you offer, and
disclose that your advice is limited to those types of investments.
Seven Bridges is an investment advisor specializing in (i) making recommendations to its Advisory Clients
(on both a discretionary and non-discretionary basis) with respect to investments in Investment Vehicles,
Separately Managed Accounts managed
by Managers as well as mutual funds and ETFs and (ii) providing
discretionary investment management services to Fund Clients and, on a sub-advisory basis, to IDF Clients.
The Managers selected by Seven Bridges on behalf of its Clients pursue a variety of investment strategies,
focus on different geographic sectors and invest in a wide range of securities.
In connection with making recommendations to Advisory Clients, Seven Bridges typically creates a
customized asset allocation program for each Advisory Client which reflects that Advisory Client’s
individual risk tolerance, investment outlook and short-term and long-term goals. Seven Bridges does not
group its Advisory Clients into standardized allocation programs, but instead creates an individualized plan
for each Advisory Client. Capital preservation is an important aspect of Seven Bridges’ investment
approach. Seven Bridges generally does not provide investment advice to its Advisory Clients with respect
to specific securities (other than with respect to mutual funds, ETFs and the securities of pooled investment
vehicles in the fund of funds context) but may refer an Advisory Client to a Manager for such advice.
With regard to Fund Clients and IDF Clients, Seven Bridges makes or recommends investments, as the case
may be, in accordance with the investment program described in the governing documents of the Fund
Clients or the IDF Clients, as applicable.
Portfolios managed by Seven Bridges for its Clients will usually, but not always, provide for diversification
across investment strategies and Managers. Categories of investments typically include fixed income,
lower volatility non-equity correlated hedge funds, long/short equity hedge funds, multi-strategy hedge
funds, developed market equity managers, emerging market equity managers, private equity and real estate.
Seven Bridges uses a variety of tools, both qualitative and quantitative, to measure the potential risks of the
various asset classes it recommends and to evaluate the Managers investing in those asset classes. Seven
Bridges meets with existing Managers and potential new Managers on a regular basis and maintains
statistical data, including historical returns, various measures of volatility and capital loss, peer group
screening, gross and net exposures, geographic and sector exposures and liquidity. It also performs due
diligence on the Managers, including site visits, reference checks and operational due diligence.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of
clients. Explain whether clients may impose restrictions on investing in certain securities or types of
securities.
The advisory services provided by Seven Bridges to its Clients are tailored to the investment objectives,
investment strategy and investment restrictions set forth in the documents governing its Client relationships,
including Fund Client and IDF Client offering documents, Advisory Client investment advisory agreements
and Advisory Client investment guidelines. Recommendations that are made for each Advisory Client stay
within the confines of that Advisory Client’s stated risk tolerance, time horizon and strategy, and, if
applicable, are subject to restrictions applicable to the account.
With respect to Fund Clients and IDF Clients, Seven Bridges does not tailor its advisory services to the
individual needs of investors in such Clients; accordingly, Seven Bridges typically does not accept specific
investment restrictions imposed by such Fund Client or IDF Client investors.
D. If you participate in wrap fee programs by providing portfolio management services, (1) describe
the differences, if any, between how you manage wrap fee accounts and how you manage other
accounts, and (2) explain that you receive a portion of the wrap fee for your services.
Seven Bridges does not participate in “wrap fee arrangements,” whereby clients select Seven Bridges to
manage funds through an investment program presented to the clients by a third-party program sponsor.
E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis
and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of”
which you calculated the amounts.
As of March 1, 2024, Seven Bridges managed $4,615,639,992 in regulatory assets under management. Of
this amount, Seven Bridges managed $2,682,193,419 on a non-discretionary basis and $1,933,446,573 on
a discretionary basis.