Firm Disclosures

Belle Haven Investments, LP (“Belle Haven”, the “Firm”), is defined as a fixed income manager of separately managed and subadvised 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 Belle Haven Investments, LP. Belle Haven's investment philosophy seeks to capitalize on structural inefficiencies in the fixed income market through a bottom-up approach; identifying undervalued securities due to transaction size, optionality, and/or credit, among other characteristics.

The information contained herein is obtained from sources believed to be reliable, but its accuracy or completeness is not guaranteed. All opinions expressed in this document are subject to change without notice. Nothing in this report should be considered tax or legal advice and investors should contact their tax professional for information regarding their tax situation.  The contents of this document are intended for educational purposes only and are not intended to be relied upon as a forecast, research or investment advice nor should it be considered a recommendation, offer or solicitation for the purchase or sale of any security or to adopt a specific investment strategy. 

There may be less public information available on municipal fixed income securities than found on public corporations. Municipal bonds may be less liquid that corporate bonds or other securities. A portion of the income may be taxable by state or local taxing authorities. Municipal bond holders may also be subject to capital gains taxes and interest income may be subject to alternative minimum tax. Bonds are subject to credit, interest rate and inflation risks. In addition, bonds incur ongoing fees and expenses.

Material is not directed to, or intended for distribution to or use by, any person or entity if Belle Haven Investments, LP is prohibited or restricted by any legislation or regulation in any jurisdiction from making it available to such person or entity. This report may not be reproduced, re-distributed or passed to any other person or published in whole or in part for any purpose without the prior consent of Belle Haven Investments, LP.  There is a risk of loss inherent in an investment, past performance is not a guarantee of future results.

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 Platforms”), is obtained from sources believed to be reliable, but its accuracy or completeness is not guaranteed. All opinions expressed in this document are subject to change without notice. Nothing in this report should be considered tax or legal advice and investors should contact their tax professional for information regarding their tax situation. There may be less public information available on municipal fixed income securities than found on public corporations. Municipal bonds may be less liquid than corporate bonds. A portion of the income may be taxable by state or local taxing authorities. Municipal bond holders may also be subject to capital gains taxes and interest income may be subject to alternative minimum tax. Bonds are subject to credit, interest rate inflation risks. In addition, bonds incur ongoing fees and expenses.  There is a risk of loss inherent in any investment, past performances do not guarantee future results. Investors should seek such professional advice for their particular circumstances.         

Any securities identified and/or 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. There should be no assumption that an investment in the securities identified on any Belle Haven Social Media Platform, was, or will be profitable in the future.  Belle Haven may or may not currently hold, or plan to hold securities discussed on Belle Haven Social Media Platforms.                                                   

Belle Haven is a registered investment adviser with the U.S. Securities and Exchange Commission (the “SEC”).  Prospective clients will be required to execute an Investment Management Agreement and/or related account opening documents (collectively, “Agreements”), with Belle Haven and/or a Registered Investment Advisor, operating under their own agreement with Belle Haven, before any investment management services are provided.  Should any information or opinion expressed on any Belle Haven Social Media Platform be inconsistent with the terms warranted in the Agreements, such Agreements shall take precedence.                                                                                    

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 be superseded at any time without notice, and are 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 not directed to, or intended for distribution to or use by, any person or entity if Belle Haven is prohibited or restricted by any legislation or regulation in any jurisdiction from making it available to such person or entity. This report may not be reproduced, re-distributed or passed to any other person or published in whole or in part for any purpose without the prior consent of Belle Haven Investments, LP.                                           

Third-party content published, contributed, or posted on Belle Haven Social Media Platforms is solely the view of the contributing third party, and not that of 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 responsible for any unauthorized or copyrighted materials contributed by a third party on any Belle Haven Social Media Platform. In using any of the links embedded within a Belle Haven Social Media Platform, you acknowledge that they are solely for your convenience, and do not imply any affiliations, sponsorships, endorsements, or representations by Belle Haven regarding the third-party web site(s). Belle Haven is not responsible for the content, accuracy or privacy 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 or edit, any third-party content published, contributed, or posted on Belle Haven Social Media Platforms.                                                                                                                                   

Awards and recognition referenced in this piece are produced by firms other than Belle Haven. Criteria used to determine these awards may vary depending on the organization presenting the award. Criteria used by firms mentioned on this page are outlined below. 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, 2017 through December 31, 2017. 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

Pursuant to the Securities and Exchange Commission (“SEC”) Rule 606, Belle Haven Investments, LP (“Belle Haven”) is obligated to disclose, on a quarterly basis, certain statistical information regarding its order routing practices.  Belle Haven routes customer orders in equity and option securities to its clearing firm, Pershing, LLC, for execution.  

Belle Haven Investments, LP strives to achieve the best possible execution price for its clients at all times. For further details regarding how your order was routed, please contact us, in writing, with the details of your trade inquiry.   We will be happy to provide that information.  

Also, specific information regarding our order routing is available at the website of our clearing broker Pershing, LLC: http://www.orderroutingdisclosure.com

Business Continuity Plan

Belle Haven Investments - Business Continuity Disclosure Statement 

Belle Haven Investments, LP has developed a Business Continuity Plan to define how it plans to respond to events that could significantly disrupt business operations. Since the timing and impact of catastrophes or disruptions are unpredictable, the Firm remains flexible in responding to actual events as they occur. With that in mind, the Firm discloses the Business Continuity Plan and objective below. 

Contacting Belle Haven 

If after a significant business disruption, you cannot contact the Firm as you usually do at 914-816-4633, you are advised to call the Firm’s alternative number of 914-816-4622. If you cannot access the Firm through either of those means, you should contact the clearing firm, Pershing LLC, directly at 201-413-2000 or access their website, www.pershing.com, for instructions on prompt access to funds and securities, or other account related transactions. The specific procedures and requirements for sending transaction requests to Pershing are listed on their website under Business Continuity & Other Disclosures.

Belle Haven’s Business Continuity Plan 

The Firm’s plan to quickly recover and resume business operations after a significant business disruption is of upmost importance, by safeguarding personnel and property, making a financial and operational assessment, protecting the firm's books and records, it will aid in the effort to continue business transactions. The Firm’s Business Continuity Plan is designed to enable the firm to resume business operations as quickly as possible, given the scope and severity of the SBD. The Firm’s Business Continuity Plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, personnel, and regulators; alternate physical location of personnel; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our clients prompt access to their funds and securities in the event the Firm is unable to continue critical business operations. The clearing firm, Pershing LLC will back up the Firm’s imperative records within 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, Belle Haven has been advised by the clearing firms that their objective is to restore their operations and be able to complete existing transactions, accept new transactions and payments within four (4) hours. Orders and requests for funds and securities could be delayed during this period. 

Varying Disruptions 

Significant business disruptions can vary in their scope, the business district where the Firm is located, the city where the Firm is located, or the affected 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, Belle Haven will transfer operations to a local site if needed, and expect to recover and resume business within four (4) hours. In a disruption affecting the Firm’s business district, city, or region, the Firm will transfer operations to a site outside of the affected area, and recover and resume business within four (4) hours. In either situation, the Firm intends to continue its business, transfer operations to the clearing firm, if necessary, and notify clients through the web site www.bellehaven.com or the client emergency number, 914-763-6193, on how to contact the Firm. If there is significant business disruption that is so severe that it prevents the Firm from remaining in business, Belle Haven will assure clients prompt access to their funds and securities.

Privacy Policy

As part of our compliance with the provisions of certain privacy regulations issued by the United States federal government, we are required to provide you with notice of our policies and practices relating to the use and sharing of your personal information.

This policy describes the steps we have taken to safeguard your information and what client information we may share with others.

We collect the following types of nonpublic personal information about you:

•Information we receive from you to open an account or provide investment advice to you (such as information on applications); and

•Information about your transactions with us, our affiliates, or others that we may receive from third parties (such as trade memoranda, account statements and confirmations).

We restrict access to nonpublic personal information about you to our employees, affiliates and service providers who need to know that information to provide products and services to you.

We maintain physical, electronic and procedural safeguards that we believe are reasonably designed to guard your nonpublic personal information while it is within our control.

We have not and will not sell your nonpublic personal information to anyone, even if our formal relationship ends.

We do not disclose any nonpublic personal information about our Clients or former Clients to anyone, except to our employees, affiliates and services providers and as permitted by law and in accordance with any applicable investment management agreements or subscription agreements.

Categories of Information which may be disclosed to third parties:

•Information from the consumer;

•Information about the consumer's transactions with you or your affiliates;

•Information about the consumer's transactions with nonaffiliated third parties; and

•Information from a consumer-reporting agency.

For additional questions concerning our Privacy Policy, please contact us by:

Phone:   914-816-4633

E-Mail:  service@bellehaven.com