A. Firm Information
Point Bridge Capital, LLC (“Point Bridge” or the “Advisor”), which is organized as a limited liability company
(“LLC”) under the laws of the State of Delaware, is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). Point Bridge was founded in October, 2013, and is owned and operated by Hal
A. Lambert (Managing Member and Chief Compliance Officer). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Point Bridge.
B. Advisory Services Offered
Point Bridge offers investment advisory services to, high-net-worth individuals, trusts, estates, charitable
organizations, corporations, business entities, pooled investment vehicles and registered investment companies
(each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Point Bridge’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Advisory Services
Point Bridge provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and/or non-discretionary
investment advisory and related advisory services. Point Bridge 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. Point Bridge will then construct a portfolio, consisting of low-cost, diversified mutual funds and/or
exchange-traded funds (“ETFs”), to achieve the Client’s investment goals. The Advisor may also utilize individual
stocks, individual bonds, real estate investment trusts (“REITs”), options contracts and/or alternative investments,
to meet the needs of its Clients. In addition, Point Bridge may also recommend that Clients who qualify as
accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in affiliated and unaffiliated
privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g.,
hedge funds). Where appropriate, the Advisor may also provide advice about any type of legacy position or other
investment held in client portfolios. The Advisor may retain certain legacy investments based on portfolio fit
and/or tax considerations.
Point Bridge’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Point Bridge will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Point Bridge evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Point Bridge may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. Point Bridge may recommend specific positions to increase sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. Point Bridge
may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
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Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the
Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices.
Use of Independent Managers
Point Bridge may recommend that Clients utilize one or more unaffiliated money managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. Additionally, as discussed in Item 10 – Other Financial Industry
Activities and
Affiliations, Point Bridge utilizes the Dynasty Financial Partners, LLC (“Dynasty”) turnkey asset management
program (“TAMP”) services. Independent Managers may be sourced directly or accessed through the TAMP. In
such instances, the Client will be required to authorize and enter into an investment advisory agreement with an
Independent Manager that defines the terms in which the Independent Manager will provide its services. Point
Bridge serves as the Client’s primary advisor and relationship manager. However, the Independent Manager will
assume discretionary authority for the day-to-day investment management of those assets placed in their control.
Point Bridge will assist and advise the Client in establishing investment objectives for their account[s], the
selection of the Independent Manager, and defining any restrictions on the account[s]. Point Bridge will continue
to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of the Independent
Manager[s]. The Independent Manager will implement the selected investment strategies based on their
investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts,
subject to the acceptance of these third parties. Point Bridge does not receive any compensation from these
Independent Managers, other than its investment advisory fee as described in Item 5 – Fees and Compensation.
Private Fund Advisor
Point Bridge also serves as an investment advisor to various pooled investment vehicles (each a “Private Fund”
and collectively “Private Funds”) and PBC General Partner, LLC, an affiliate under common ownership and
control (“General Partner”), serves as the general partner to the Private Funds. These services are detailed in the
offering documents for each Private Fund, which include as applicable, operating agreements, private placement
memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all
amendments thereto (“Offering Documents”).
The Advisor manages each Private Fund based on the investment objectives, policies and guidelines as set forth
in the respective Offering Documents and not in accordance with the individual needs or objectives of any
particular investor therein. Each prospective investor interested in investing in a Private Fund is required to
complete a subscription agreement in which the prospective investor attests as to whether or not such
prospective investor meets the qualifications to invest in the Private Fund and further acknowledges and accepts
the various risk factors associated with such an investment.
For more detailed information on investment objectives, policies and guidelines, please refer to the
respective Private Fund’s Offering Documents.
Point Bridge American First ETF
Point Bridge is the investment advisor to the Point Bridge American First ETF, an open-end registered
investment management company, subject to the Investment Company Act of 1940 (the “Fund”). Point Bridge
also provides investment advisory services to the Fund. Subject to general supervision by the Board of Trustees
of U.S. Bancorp Fund Services, LLC (herein the “Board” or “U.S. Bancorp”), and in accordance with the
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investment objectives, policies and restrictions of the Fund, the Advisor provides the Fund with ongoing
investment management and administrative oversight. In addition, Point Bridge has retained Vident Investment
Advisory, LLC (“VIA”) to serve as the Sub-Advisor to the Fund.
The Fund is part of the investment concepts developed by Point Bridge called Politically Responsible Investing
and Political Beta. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for a
detailed description of the Fund.
Additionally, a full description of the services provided by the Advisor for managing the Fund are
available in the current prospectus and statement of additional information (“SAI”) of the Fund. The
prospectus and statement of additional information are available from the SEC website (www.SEC.gov)
or by contacting the Advisor at (817) 529-4600.
C. Client Account Management
Prior to engaging Point Bridge to provide investment advisory services, each Client is required to enter into an
advisory agreement that defines the terms, conditions, authority and responsibilities of the Advisor and the Client.
These services may include:
• Establishing an Investment Strategy – Point Bridge, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Point Bridge 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 – Point Bridge will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Point Bridge will provide investment management and
ongoing oversight of the Client’s investment portfolio.
Point Bridge America First ETF
Shares of the Fund are only issued through U.S. Bancorp. Subscription details are provided in the Fund’s
prospectus.
D. Wrap Fee Programs
Point Bridge does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Point Bridge.
E. Assets Under Management
As of December 31, 2023, Point Bridge manages $293,685,105 in Client assets, $144,863,140 of which is on a
discretionary basis and $148,821,965 on a non-discretionary basis. Clients may request more current information
at any time by contacting the Advisor.