BCP – Pandemic Statement of Preparation

During this period of uncertainty surrounding COVID-19, we want to emphasize our commitment to providing clients the services and support we here at Belle Haven pride ourselves on.  As we closely monitor, assess, and respond to the everchanging market and economic conditions, we thank you for your continued trust and confidence in us. Honoring that responsibility, through any environment, is our primary focus.  We want to make sure you can focus on the health of you and your family, and are prepared to service your needs through these uncertain times.  If you have questions regarding your portfolio, please contact a member of our team.  

Additionally, we would like to share with you the precautionary steps that Belle Haven has taken to ensure continued support to our clients.

Belle Haven Investments, LP (“Belle Haven” or the “Firm”) has adopted a Statement of Preparation in addition to the Firm’s Business Continuity Plan to address the steps the Firm has taken in mitigating the potential impact to business operations in response to COVID-19.  The health, safety and well-being of Belle Haven’s employees and clients are the Firm’s top priority.  

Planning Approach

The Firm maintains a Business Continuity Plan designed to respond to any and all significant business disruptions, addressing how the Firm currently mitigates for both internal and external disruptions by making financial and operational assessments of such potential disruptions, being able to quickly recover and resume business operations, and protect the Firm's books and records.  In the event such outbreak should result in office closure, Belle Haven maintains contingency plans that enable the Firm to continue to provide uninterrupted service. Firm employees will be instructed to remain at their home residence and operate remotely from that location. Employees have the ability to access both VPN and cloud-based functionality to effectuate necessary business functions. All mission critical systems necessary for the Firm to continue business operations are tested remotely on a regular basis.  

A pandemic occurs when there is a widespread disease outbreak. While a pandemic may vary in severity and duration, in accordance with industry best practices, Belle Haven has implemented many strategic actions as part of its Business Continuity Plan including, but not limited to: 

•Separation of key personnel;

•Increased remote work capabilities;

•Elimination of in-person group meetings;

•Elimination of visitor access to the building;

•Enhanced use of remote meeting and conference call capabilities;

•Implementation of social distancing;

•Distribution of hand sanitizers, masks, gloves and hygiene products;

•Increased sanitizing and disinfecting of facilities;

•Increased use of communication channels to disseminate important health and safety information, including protocols for illness or high-risk personnel; and

•Implementation of travel restrictions and quarantines based on federal, state, local and CDC recommendations.

Belle Haven continues to provide clients with real-time market commentaries and analysis on these everchanging conditions, and remains confident that it will continue to be responsive to all needs throughout any potential shutdowns or quarantines that may be required. Belle Haven will continue to be available by telephone and email even in the event of an office closure.

Business Continuity Plan (“BCP”)

Belle Haven Investments, LP - Business Continuity Disclosure Statement 

Belle Haven Investments, LP (“Belle Haven”, or the “Firm”) has developed a Business Continuity Plan and Procedure (“BCP”) to define how it plans to respond to events that could significantly disrupt business operations. Since the timing and impact of catastrophes, pandemics or other significant business 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 are unable to contact the Belle Haven using the main telephone number, 914-816-4633, you are advised to call the Firm’s alternative number of 914-816-4622. If you are unable to access the Firm through either of those means, you are advised to contact the Firm’s clearing firm, Pershing, LLC (“Pershing”), directly at 201-413-2000, or access their website, www.pershing.com, or contact the custodian where your account is held for instructions on prompt access to funds and securities, or for other account related inquiries. For accounts held at Pershing, the specific procedures and requirements for trade related transactions, cash disbursements and security transfers are listed on Pershing’s website under Business Continuity & Other Disclosures. 

Belle Haven’s Business Continuity Plan 

The goal of Belle Haven’s Business Continuity Plan and Procedure (“BCP”) is to respond to any and all significant business disruptions by safeguarding employees' lives and the Firm’s property, while maintaining the ability to conduct business to the best of our capability. This is accomplished by making a financial and operational assessment of such business disruption, quickly recovering and resuming operations, and protecting the Firm's book and records. The Firm’s Business Continuity Plan and Procedure is designed to enable the Firm to resume business operations as quickly as possible, given the scope and severity of the disruption to business operations. 

The Firm’s BCP addresses how it currently mitigates for both internal and external significant business disruptions by outlining data backup and recovery procedures; listing financial and operational assessment objectives; identifying mission critical systems; providing alternative means of communication with customers, Firm personnel, and regulators; providing  an alternate physical location plan for Firm personnel in the event of an office closure; and assuring Firm clients’ prompt access to their funds and securities in the event the Firm is unable to continue critical business operations. While every emergency situation poses its own unique problems based on internal and/or external factors, such as time of day and the severity of the disruption, for accounts held at Pershing, Belle Haven has been advised by Pershing that their objective is to restore their operations, be able to complete existing transactions, and accept new transactions and payments within four (4) hours. Orders and requests for funds and securities could be delayed during this period.  Pershing will back-up the Firm’s imperative records within a geographically separate area. For accounts not held at Pershing, clients are advised to contact the custodian where their account is held for information regarding their Business Continuity Plan.

Varying Disruptions 

Belle Haven is located at 800 Westchester Avenue, Suite N607, Rye Brook, NY 10573.  The Firm’s main telephone number is 914-816-4633.  

Significant business disruptions can vary in their scope, location, business type, and the region affected. This can vary from an internal disruption, such as a network outage or loss of phone service, to external disruptions that take place out of the control of Belle Haven such as a health pandemic, a terrorist attack, a city flood or other wide-scale regional disruption affecting the operation of the financial markets.  Within each of these areas, the severity of the disruption can also vary from minimal to severe. In the event of a disruption that is only affecting Belle Haven, the Firm will transfer its business operations to a local site, if needed, and expect to recover and resume business within four (4) hours. In the event a disruption is affecting the Firm’s location, 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 operations to the best of its capabilities. If deemed necessary, the Firm will transfer business operations to the Firm’s clearing firm, Pershing, LLC, and communicate with clients by all alternative means available for information on the Firm’s operating procedures.  Such alternative means include, but are not limited to, accessing the Firm’s website, www.bellehaven.com, or utilizing the Firm’s alternative telephone number, 914-816-4622. 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.

Summary

On an annual basis, the Firm’s Business Continuity Plan and Procedure is reviewed and tested to ensure that it can be implemented in the event of a significant business disruption.  Such testing is used to validate the Firm’s incident response capabilities of mitigating real-world events having the potential to disrupt business operations.  Belle Haven is confident that it will continue to be responsive to all needs throughout any potential disruption to its business operations.  

Privacy Notice

At Belle Haven Investments, LP (“Belle Haven”, or the “Firm”), we recognize that protecting the privacy and security of the confidential, Nonpublic Personal Information we collect about you is an important responsibility. The following information will help you understand the Firm’s Privacy Policy, and the disclosure of Nonpublic Personal Information. 

We do not sell Nonpublic Personal Information to anyone, and only share such information with other affiliated and non-affiliated third-party service providers, and regulators as stated in this Notice. “Nonpublic Personal Information” is personally identifiable financial information that a customer provides to a financial institution that 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 Nonpublic Personal Information to help us serve your financial needs and fulfill legal and regulatory requirements. The types of information the Firm may collect include, but are not limited to, such account opening documentation, e.g., name, address, social security number, current assets and liabilities, and income; information about your current relationship with the Firm, if applicable, e.g., transactions that include products purchased, account balances and payment history; and information we receive from other third-party service providers, e.g., consumer reports, credit relationships, financial reports, and credit history.

Identity Verification

In instances where it is necessary for the Firm to verify your identity from the information provided to us, the Firm will do so against such third-party sources as described above. If the Firm is unable to verify your identity, we may require additional information from you for verification purposes before transactions in your account can be processed. 

Information We Disclose in Servicing Your Account

In the course of servicing your account, we may disclose or share your Nonpublic Personal Information to affiliated or non-affiliated third-parties that perform accounting, recordkeeping, or administrative services related to your account; to a regulatory authority upon request; to others pursuant to a subpoena; or as otherwise permitted by law.  The Firm does not sell your Nonpublic Personal Information.  Should this change, the Firm will provide you with an Opt-Out Notice prior to disclosing your Nonpublic Personal Information, in accordance with Regulation S-P.  Should you decide to close your account, or such account becomes inactive, the Firm will continue to adhere to the privacy policies and practices described herein.

Confidentiality and Security Procedures 

Belle Haven greatly appreciate the trust that you have placed in us, and we take great measures to safeguard your information. We restrict access to your Nonpublic Personal Information to only those Firm employees who need to know such information to provide investment management services to you. We emphasize the importance of confidentiality through training, maintaining robust internal controls, and requiring strict adherence to the Firm’s Privacy Policy. In accordance with Regulation S-P Belle Haven has implemented written policies and procedures that address administrative, technical, and physical safeguards for the protection of customer records and Nonpublic Personal Information. The Firm maintains physical, electronic, and procedural safeguards that comply with applicable federal standards to guard your Nonpublic Personal Information, and to mitigate 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.

For additional questions, or a copy of our Privacy Policy, please contact us by:

Phone:   914-816-4633; or

E-Mail:  service@bellehaven.com

Firm and Website Disclosures

Belle Haven Investments, LP (“Belle Haven” or 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, LP.  The Firm’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.

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, 2019. The verification report is available upon request.  Verification assesses whether (1) the Firm has complied with all the composite construction requirements of the GIPS® standards on a Firm-wide basis and (2) the Firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS® standards.  Verification does not ensure the accuracy of any specific composite presentation. 

These contents 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 as a recommendation, offer, or solicitation, for the purchase or sale of any security, or to adopt a specific investment strategy. 

The information is obtained from sources believed to be reliable, but its accuracy or completeness is not guaranteed. All opinions expressed within such contents are subject to change without notice. Nothing within such contents 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 and inflation risks. In addition, the management of bond portfolios incur ongoing fees and expenses. 

Such 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. No such material 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. © Copyright Belle Haven Investments 2020. All rights reserved. 

Social Media Disclosures

All content published or otherwise disseminated by Belle Haven Investments, L.P. (“Belle Haven”, or the “Firm”) 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 on Belle Haven Social Media Platforms are subject to change without notice. Nothing published or otherwise disseminated on Belle Haven Social Media Platform should be considered tax or legal advice, or a recommendation of any investment strategy 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.                                                                                    

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 website(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. 

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. These contents 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.                                                                                                                                                                  

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. Criteria used by firms may be mentioned and outlined for reference purposes only. 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 . 

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 Investments, LP 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.