Firm Disclosures

Disclosure: Belle Haven Investments, the “firm,” is defined as a fixed income manager of separately managed and sub-advised portfolios. Belle Haven manages taxable and tax-sensitive accounts which invest in U.S. municipal, corporate, government and treasury securities. Not included in the “firm” is the broker/dealer group of Belle Haven Investments. Belle Haven’s investment philosophy seeks to capitalize on structural inefficiencies in the fixed income markets through a bottom-up approach; identifying undervalued securities due to transaction size, optionality, and/or credit, among other characteristics. For composite and compliance purposes “the firm” is defined as all separately managed and sub-advised fully discretionary portfolios. Non-discretionary portfolios are not included.

Account returns are calculated using a time-weighted return methodology. Composite returns are calculated using asset-weighted account returns. All returns and valuations are calculated using U.S. Dollars and are based on trade date accounting. All accounts in the composite are fee paying. Gross of fees returns are calculated gross of management fees and net of custodial fees and transaction costs. Net of fees returns are calculated net of management fees, custodial fees and transaction costs.

Quarterly management fees are billed in arrears in the month following the end of the calendar quarter. Significant changes in assets under management will not result in an appropriate matching of assets under management and management fees attributable to that particular period.

Actual Performance results may differ from composite returns, depending on the size of the account, investment guidelines and/or restrictions, inception date and other factors. Past performance is not indicative of future results. Performance results for the accounts included in the Composite include the reinvestment of dividends and other earnings. As with any investment vehicle, there is always the potential for gains as well as the possibility of losses. For a complete list of Belle Haven Investments composites and/or for additional information regarding policies for calculating and reporting returns please contact Brian Steeves at steevesb@bellehaven.com

This presentation is for educational purposes only. It is not an offer or solicitation for the purchase or sale of any security or an official confirmation of any transaction.

Social Media Disclosures

All content published or otherwise disseminated by Belle Haven Investments, L.P. (“Belle Haven”) on any social media platform, including but not limited to Twitter and LinkedIn (“Belle Haven Social Media Platform”), is for informational and educational purposes only and should not be construed as investment, tax, financial, accounting or legal advice, or a recommendation to invest in any particular security, strategy or investment product. Investors should seek such professional advice for their particular circumstances.         

Belle Haven is a registered investment adviser with the U.S. Securities and Exchange Commission (the “SEC”). Any prospective investor will be required to execute an Investment Management Agreement and/or related account opening documents (collectively, “Agreements”) with Belle Haven and/or an Investment Advisor operating under their own agreement with Belle Haven before any services are provided by Belle Haven. If any of the descriptions or terms contained on any Belle Haven Social Media Platform are inconsistent with the terms of the Agreements, such Agreements shall control.                      

Each reader of information contained on any Belle Haven Social Media Platform should make his or her own investigation and evaluation of any investments or investment strategies described or referred to therein, including the merits and risks thereof. Each reader should inform himself or herself as to the tax consequences of the investments and services described on any Belle Haven Social Media Platform. Belle Haven reserves the right to modify any of the terms described herein. Any securities identified and described on any Belle Haven Social Media Platform do not represent all of the securities purchased, sold or recommended for client accounts by Belle Haven. Readers should not assume that an investment in the securities identified on any Belle Haven Social Media Platform was or will be profitable.  Belle Haven Investments may currently hold or plan to purchase in managed client accounts, securities issued by states discussed on Belle Haven Social Media Platforms. 

No assurance can be given that the investment objectives will be achieved or that investors will receive a return of any capital. Prior performance does not guarantee nor is it indicative of future results. Performance includes the reinvestment of all income. Therefore, no current or prospective client should assume that the future performance of any specific investment or investment strategy or objective (including those undertaken or recommended by Belle Haven) will be profitable or that returns will equal to corresponding indicated performance levels or produce a return of capital.                

The analysis contained in any publication published or otherwise disseminated by Belle Haven on Belle Haven Social Media Platforms is based on the data available at the time of publication which may become outdated or otherwise superseded at any time without notice, and the opinions of Belle Haven. Certain information contained on Belle Haven Social Media Platforms is based upon third party sources, which Belle Haven believes to be reliable, but is not guaranteed for accuracy or completeness. Neither the SEC nor any other federal or state agency or non-U.S. commission has confirmed the accuracy or determined the adequacy of information published or disseminated by Belle Haven on any Belle Haven Social Media Platform. Any publication or dissemination of information to the contrary is unlawful. Each reader acknowledges the contents published or otherwise disseminated by Belle Haven on Belle Haven Social Media Platforms is the sole property of Belle Haven and any reproduction or distribution of such information, in whole or in part, other than for its intended purpose with credit provided to Belle Haven, is prohibited.        

Third-party content published, contributed, or posted on Belle Haven Social Media Platforms is solely the view of the contributing third party and not Belle Haven. Belle Haven cannot guarantee the appropriateness, accuracy or usefulness of any third party content or of any third party hyper-link, nor is Belle Haven responsible for any unauthorized or copyrighted materials contributed by a third party on any Belle Haven Social Media Platform. By clicking on any of the links within a Belle Haven Social Media Platform, you acknowledge that they are solely for your convenience, and do not necessarily imply any affiliations, sponsorships, endorsements or representations whatsoever by us regarding third-party Web sites. We are not responsible for the content, availability or privacy policies of these sites, and shall not be responsible or liable for any information, opinions, advice, products or services available on or through them. Belle Haven reserves the right to remove, alter, edit, or adapt any third party content published, contributed, or posted on Belle Haven Social Media Platforms.   

Awards and recognition referenced on Belle Haven Social Media Platforms are produced by firms other than Belle Haven. Criteria used to determine these awards may vary depending on the organization presenting the award. Belle Haven cannot guarantee the accuracy of any other firm’s ranking or ranking methodology. For further information on our strategies or awards, please contact service@bellehaven.com.                                                                                                              

Belle Haven claims compliance with the Global Investment Performance Standards (GIPS®) and  has been independently verified for the periods January 1, 2004 through December 31, 2015. For any further questions or to obtain a compliant presentation, please contact service@bellehaven.com. 

 

Order Routing

Disclosure Pursuant to SEC Rule 606 - Order Routing

Belle Haven Investments, L.P. routes customer orders in equity and option securities and is obligated to provide statistical information regarding our routing practices. Belle Haven Investments, L.P. strives to achieve the best possible execution price for its customers at all times. If you desire specific details regarding the destinations to which your order was routed please contact us with the details of your trade in writing. We will be happy to provide that information. Also, specific information regarding our order routing is available at the website of our clearing broker: http://www.orderroutingdisclosure.com Disclosure Pursuant to SEC Rule 605 - Execution Quality Disclosure For Execution Quality Disclosure please go to our clearing broker’s website located at: http://www.marketsystems. com/msi/public1_5.htm

 

Business Continuity Plan

Belle Haven Investments, L.P. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

If after a significant business disruption you cannot contact us as you usually do at 914-816-4633, you should call our alternative number 914-763-6193 or go to our emergency web site at, www.bellehaveninvestments.blogspot. com If you cannot access us through either of those means, you should contact our clearing firm, Pershing LLC, at 201-413-2572 and web site, www.pershing.com, for instructions on how it may provide prompt access to funds and securities, enter closing security transactions and process any other trade or account related transactions. The specific procedures and requirements for sending transaction requests to Pershing are listed on their web site under Business Continuity/Customer Support.

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Pershing, LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within four (4) hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within four (4) hours. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our emergency information web site www.bellehaveninvestments.blogspot.com or our customer emergency number, 914-763-6193 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

 

Customer Privacy Policy

At Belle Haven Investments, LP, we recognize that protecting the privacy and security of the confidential personal information we collect about you is an important responsibility. The following information will help you understand our privacy policy and the disclosure of customer information. We do not sell Nonpublic Personal Information to anyone and only share information with others as stated in this Notice.

“Nonpublic Personal Information” is personally identifiable financial information that a customer provides to a financial institution results from a transaction with a customer; or is otherwise obtained by the financial institution. As an example, nonpublic personal information includes information regarding your account value and investment history.

Information We Collect

We collect personal information to help us serve your financial needs and fulfill legal and regulatory requirements. The types of information we collect include:

  • Account opening documentation and applications (such as name, address, social security number, assets and income);
  • Information about your transactions and relationships with us (such as products purchased, account balances and payment history); and
  • Information we receive from third parties (such as consumer reports, credit relationships, financial reports, and history).

Information We Disclose in Servicing Your Account

In the course of servicing your account we may disclose your Nonpublic Personal Information to Affiliated or Non- affiliated Third Parties that perform accounting, record keeping or administrative services related to your account; to securities regulators upon request; to others pursuant to subpoena; or as otherwise permitted by law. Even if you decide to close your account or it becomes inactive, we will continue to adhere to the privacy policies and practices.

Confidentiality and Security Procedures

We greatly appreciate the trust that you have placed in us and we take steps to safeguard your information. We restrict access to your personal and account information to only those employees who need to know that information to provide products or services to you. We emphasize the importance of confidentiality through employee training, operating procedures, and our privacy policy. We maintain physical, electronic and procedural safeguards that comply with applicable federal standards to guard your Nonpublic Personal Information and to assist us in preventing unauthorized access to your records.

We will update our policy and procedures where necessary to ensure that your privacy is maintained and that we conduct our business in a way that fulfills our commitment to you.