Silverberg Bernstein Capital Management LLC

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Silverberg Bernstein Capital Management LLC
CRD #327151
SEC #801-128290
CIK #0002007880
AUM 283.0 M (2026-03-06)
Employees 3 (67% Investors, 67% Brokers)
Fees
Minimum
Phone203-820-9107
Address4 Miller Circle
Armonk, NY 10504
Source [IAPD] [EDGAR]
Total AUM ($M)
3002401801206002010201520212027
Fees and Compensation — Form ADV Part 2A (3/6/2026) [Brochure]
Item 5 – Fees and Compensation

A.     Fee Schedule
ASSET MANAGEMENT
SBCM offers asset management services to advisory Clients. SBCM charges an annual investment
advisory fee based on the total assets under management as follows:

              Assets Under Management                  Maximum Annual Fee (Negotiable)

                       All Assets                                      1.50%

Fees are billed quarterly in advance based on the amount of assets managed as of the close of
business on the last business day of the previous billing period. Lastly, please note that SBCM may
group certain related Client accounts, often known as “householding”, for the purposes of achieving
the minimum account size and determining the annualized fee.
FINANCIAL CONSULTING
SBCM charges an hourly fee for financial consulting. Prior to the consultation, the Client will be
provided an estimated fee which will be based on the complexity of the engagement. Generally,
services will be completed and delivered within ninety (90) days contingent upon timely delivery of
all required documentation, as needed by SBCM. SBCM reserves the right to waive the fee should
the Client implement the advice through SBCM. Hourly Fee Services are offered based on an hourly
fee of $500 per hour. Fees for financial consultations are billed upon completion.

B.     Payment of Fees
Asset Management Fees are deducted directly from the Client’s Account.

Financial Consulting Fees are generally invoiced directly to the Client but may also be deducted
from another account held with SBCM.

SBCM, in its sole discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated
future additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with Clients, etc.).

For all services, Clients may terminate their engagement with SBCM within five (5) business days
of signing an Agreement with no obligation and without penalty. After the initial (5) business days,
the Agreement may be terminated by SBCM with thirty (30) days written notice to Client and by the
Client at any time with written notice to SBCM. For accounts opened or closed mid-billing period,
fees will be prorated based on the days services are provided during the given period. In the case
of hourly engagements, fees will be prorated based on the work completed at the stated hourly
rate. All unpaid earned fees will be due to SBCM and all unearned fees will be refunded to the Client.
Any increase in fees will be acknowledged in writing by both parties before any increase in said fees
occurs.

C.      Additional Fees
Custodians may charge brokerage commissions, transaction fees, and other related costs on the
purchases or sales of mutual funds, equities, bonds, and exchange-traded funds. Mutual funds,
money market funds, and exchange-traded funds may also charge internal management fees,
which are disclosed in the fund’s prospectus. SBCM does not directly receive any compensation
from these fees. All of these fees are in addition to the management fee you pay to SBCM. For more
details on the brokerage practices, see Item 12 of this brochure.

D.     Prepayment of Fees
Asset Management fees are billed in advance.

E.       External Compensation for the Sale of Securities
Certain Investment Advisor Representatives of SBCM may also be registered as Registered
Representatives of a broker-dealer, which allows them to perform brokerage services for Clients by
executing security transactions. This practice represents a conflict of interest because the
Investment Advisor Representatives is able to choose between offering Client’s fee-based
programs and services (as is typical of an advisory relationship) and/or commission-based
products and services (as is typical of a brokerage relationship). While a Client generally pays a fee
to their Investment Advisor Representatives on an advisory account based on the value of account
assets and not the number of transactions, in their capacities as Registered Representatives, an
Investment Advisor Representative can offer securities and receive a commission, markup, or
markdown on each transaction. An example of this may be a transaction commission on a mutual
fund purchase, with additional compensation paid from an ongoing 12b-1 trailing commission
compensation directly from the mutual fund company during the period that the Client maintains
the mutual fund investment. Our Investment Advisor Representatives do not receive these 12b-1
fees in relation to managed investment advisory accounts in their role as Registered
Representatives. This conflict is mitigated by disclosures, procedures and SBCM’s fiduciary
obligation to place the best interest of the Client first. Moreover, Clients are not required to engage
the broker-dealer or it’s representatives if they do not wish to. More information on this can be
found in the respective Investment Advisor Representative’s Form U4 and ADV 2B.

Please be aware that representatives of SBMC will not offer any Clients accounts under their
brokerage relationship. Only legacy accounts will be maintained. All new accounts will be under
SBMC directly, on a fee-based schedule.
Account Minimums and Types of Clients — Form ADV Part 2A (3/6/2026) [Brochure]
Item 7 – Types of Clients & Account Minimums

SBCM’s Clients are generally individuals, small businesses, trusts, estates, high net-worth
individuals, pooled investment vehicles, and charities. Client relationships vary in scope and length
of service.

SBCM requires a minimum account size of $500,000 to enter into an Advisory Agreement.
However, SBCM retains the discretion to lower or waive said minimum.
Sector Form 13F Holdings Value ($M)
M/A-Com Technology Solutions Holdings Inc 45.5
PDF Solutions Inc 33.0
Harmonic Inc 21.4
Analog Devices Inc 14.3
Texas Instruments Inc 14.1
3D Systems Corp 8.4
Parametric Technology Corp 8.2
NVE Corp /New/ 7.2
New Media Investment Group Inc 6.8
CEVA Inc 6.6
View All
Holdings by Sector ($M)
3002401801206002024202520262027
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 98 3.0
(b) Individuals (high net worth individuals) 33 271.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 1 2.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 2 5.0
(h) Charitable organizations 1 2.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 128 283.0
By Discretionary
Discretionary 128 283.0
Non-Discretionary 0 0.0
Total 128 283.0
By Non-United States Persons
Non-United States Persons 9.0
United States Persons 274.0
Total 128 283.0
EDGAR Form CIK 2011 - 2026
13F-HR [0002007880]
SC 13G [0002007880]
Form 13D/13G Filer Form 13D/13G Subject Filed
Silverberg Bernstein Capital Management LLC Silverberg Bernstein Capital Management LLC [2024-11-20]
Firm Profile (Form ADV)
ServesRetail
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