Firm Disclosures

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 2019. 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.                     

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.                                           

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.                                                                                                                                   

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. 

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 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.

Business Continuity Plan

Belle Haven Investments - Business Continuity Disclosure Statement 

Belle Haven Investments, LP (“Belle Haven”, or the “Firm”) 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 (“SBD”), you are unable to contact the Firm 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 Firm has implemented a Business Continuity Plan outlining how the Firm plans to quickly recover and resume business operations after an SBD, by safeguarding Firm personnel and its property, making a financial and operational assessment of such SBD, and protecting the Firm's books and records, while maintaining the ability to conduct business to the best of our capability.  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 how it currently mitigates for both internal and external SBD’s, its data backup and recovery procedures; financial and operational assessment objectives; identified mission critical systems; alternative means of communication with customers, Firm personnel, and regulators; alternate physical location plan for Firm personnel; and assuring our clients prompt access to their funds and securities in the event the Firm is unable to continue critical business operations. The Firm’s clearing firm, Pershing, LLC, will back-up the Firm’s imperative records within a geographically separate area. 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. For accounts not held at Pershing, you are advised to contact the custodian where your account is held for information regarding their Business Continuity Plan.

Varying Disruptions 

Significant business disruptions can vary in their scope, location, business type, and the region affected. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption that is only affecting our Firm, Belle Haven will transfer its business operations to a local site, if needed, and expect to recover and resume business within four (4) hours. In a disruption that 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 operations to the Firm’s clearing firm, Pershing, LLC, and communicate with clients by all alternative means available through accessing the Firm’s website www.bellehaven.com, or the Firm’s alternative telephone number, 914-816-4622, for a status on the Firm’s operating procedures. 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

At Belle Haven Investments, LP (“Belle Haven”, or the “Firm”), 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 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 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).

Identity Verification

In certain cases, we will verify your identity against third-party sources using the information you provide us. Should a problem with your identity verification arise, we may require you provide us with further verification 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 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 Firm’s privacy policies and practices.

Confidentiality and Security Procedures 

We greatly appreciate the trust that you have placed in us, and we take great measures to safeguard your information. We restrict access to your personal account information to only those Firm 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.

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

Phone:   914-816-4633; or

E-Mail:  service@bellehaven.com