7TWELVE ADVISORS, LLC


A. Firm Information
7Twelve Advisors, LLC (“7Twelve” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Tennessee. 7Twelve was founded in 2008 and is operated by its President, Andrew D. Martin. The firm is owned by Andrew D. Martin, Steven J. Eisen and Craig L. Israelson. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by 7Twelve to institutional clients of the 7Twelve Balanced Portfolio and future public markets investment products.
B. Advisory Services Offered
7Twelve primarily provides investment advisory services to an open-end registered investment management company, a unit investment trust and other investment advisors (each referred to as a “Client”).

7Twelve Balanced Portfolio 7Twelve provides investment management services to the 7Twelve Balanced Portfolio (the “Fund”), an open-end registered investment management company. Subject to general supervision by the Board of Trustees of the Northern Lights Variable Trust (herein the “Board”) and in accordance with the investment objectives, policies and restrictions of the Fund, the Advisor provides the Fund with ongoing investment management and administrative oversight. The Advisor has discretion to determine which securities or other investments to purchase or sell, and what portion of the Fund’s assets will be held in various securities, cash or other investment instruments, consistent with the Fund’s investment objective and guidelines as set forth in the current prospectus.

7Twelve seeks to achieve the Fund's investment objective by allocating assets among securities that represent 7 broad asset classes and 12 subcategories using the Advisor's 7Twelve asset allocation model (the "7Twelve Model™"). The adviser usually does not select individual stocks and bonds, but instead selects exchange-traded funds ("ETFs") or no load indexed mutual funds that each invests primarily in securities representing one of the 12 subcategories of assets selected under the 7Twelve Model™. The Fund may invest in ETFs that hold securities from issuers of any market capitalization, credit quality, maturity, country, or trading currency. However, bond credit quality will be primarily investment grade (that is, rated Baa3 or higher by Moody's Investors Service, or equivalently rated by another nationally recognized statistical rating organization). The Fund may also buy ETFs that invest in foreign securities traded on exchanges outside the U.S. and through American depositary receipts ("ADRs"). Under normal market conditions, the Fund invests at least 65% of its assets in equity securities (common stocks) and at least 35% of its assets in bonds. For purposes of meeting these allocations, the Fund defines equity securities to include ETFs that invest primarily in equity securities and defines bonds to include ETFs that invest primarily in bonds and other fixed income securities.

7Twelve Balanced Portfolio Series 7Twelve provides investment consulting services to the 7Twelve Balanced Portfolio Series (the “Trust”), a unit investment trust. The Trust is a series trust created by First Trust Portfolios L.P. (the “Sponsor”). Subject to the investment objectives, policies and restrictions of the Trust, the Advisor provides the Trust with ongoing investment consultation and administrative oversight. The Advisor provides the Sponsor, in connection with its sponsorship of the Trust, a list of securities for deposit into the Trust

7Twelve’s investment consultation seeks to achieve the Trust’s investment objective of above-average capital appreciation. The Trust is a unit investment trust that invests in ETFs that are diversified among multiple asset classes. Unlike a traditional two-asset 60% equities/40% fixed income portfolio, the Trust invests in seven core asset groups, which are subdivided into 12 equal asset classes, in an effort to enhance performance and reduce risk. This investing approach attempts to generate equity-like returns with bond-like risk. Each investment asset adds an important dimension to the portfolio because of the historically low correlation and behavior between them. Approximately 65% of the portfolio is invested in equities and diversifying assets and approximately 35% of the portfolio is invested in fixed income and cash equivalents. A full description of the services provided by the Advisor for managing the Fund or consulting to the Trust are available in the current prospectus and statement of additional information (“SAI”) of the Fund or Trust. The
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prospectus and statement of additional information are available from the SEC website (www.SEC.gov) or by contacting the Advisor at (615) 341-0712. Model Management 7Twelve offers Model Management services via Folio Investments, Inc. an internet-based broker-dealer platform and other institutions ((herein “Platform”). 7Twelve has developed two proprietary models, 7Twelve and 3Twelve Models (herein “Models”), both of which are managed in accordance to the Model’s investment style and objective, and are available on the Platform to other investment advisors (“Third-Party Advisors”). The 3Twelve Total Bond is an equally weighted, passive strategy that invests in each major taxable bond category. The twelve major asset categories in the global bond universe are the model for the equally-weighted 3Twelve Total Bond strategy.

7Twelve does not have the authority to buy or sell securities for, or otherwise manage, client account[s] managed by a Third-Party Advisor utilizing the Platform (“Third-Party Clients”). The Advisor will not be in direct communication with Third-Party Clients. Any decision to trade, as well as the responsibility for the trade orders, remains exclusively with the Third-Party Advisor and the Third-Party Client. 7Twelve relies exclusively on Third- Party Advisors for (i) making suitability decisions, and (ii) for providing “ongoing investment supervisory services,” based on the needs and circumstances of the Third-Party Clients.
C. Client Account Management
7Twelve Balanced Portfolio Fund Shares of the Fund are only issued through insurance company intermediaries for variable insurance policies. An investor cannot invest directly in the Fund. Subscription details are provided in the Fund’s prospectus and other disclosure documents provided by various insurance companies.

7Twelve Balanced Portfolio Series Units of the Trust are only issued through the Sponsor. Subscription details are provided in the Trust’s prospectus and other disclosure documents provided by the Clients selected Custodian.

D. Wrap Fee Programs
7Twelve does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by 7Twelve.

E. Assets Under Management
As of December 31, 2019, 7Twelve manages $60,000,000 in discretionary assets, all of which are managed within the 7Twelve balanced portfolio. Clients may request more current information at any time by contacting the Advisor. please register to get more info

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