Disclosures

CLIENT RELATIONSHIP SUMMARY

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is a dually registered broker-dealer and investment advisor specializing in fixed income investment strategies. The Firm manages taxable and tax-sensitive investment advisory accounts which invest in U.S. municipal, corporate, government, and treasury securities.  Belle Haven is registered with the Securities and Exchange Commission (“SEC”), and is a member of both the Financial Industry Regulatory Authority (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”). 

 

Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. 

 

Free and simple tools are available to research firms and financial professionals at www.investor.gov/CRS   which also provides educational materials about broker-dealers, investment advisors and investing.  For additional information about Belle Haven, the Firm’s Form ADV 2A can be found at https://adviserinfo.sec.gov/firm/summary/29278.

 

Belle Haven Investments, L.P. Form CRS Relationship Summary - July 2024

Belle Haven Investments, L.P. Disclosure Brochure - July 2024

 

FORM ADV PART 2A

This brochure provides information about the qualifications and business practices of Belle Haven Investments, L.P. (“Belle Haven”).  If you have any questions about the contents of this brochure, please contact us at (914) 816-4633 and/or by email at compliance@bellehaven.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.

 

Belle Haven is a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).  Registration of an investment adviser does not imply any level of skill or training. 

 

Additional information about Belle Haven is also available on the SEC’s website at www.adviserinfo.sec.gov.

 

Belle Haven Investments, L.P. - Form ADV Part 2A - July 2024

 

PRIVACY NOTICE

At Belle Haven, we recognize that protecting the privacy and security of the confidential personal information we collect about you is an important responsibility. This Notice was designed to help you understand the Firm’s Privacy Policy, how we collect, share and protect your personal information, as required or permitted by law, in order to help us serve your financial needs.

 

For additional questions or comments about this Notice or other privacy-related matters, or to request a copy of our Privacy Policy, please contact us (914) 816-4633 and/or by email at compliance@bellehaven.com. 

 

Belle Haven Investments, L.P. - Privacy Notice July 2024

 

ERISA 408(b)(2) DISCLOSURE STATEMENT

This Disclosure Statement is intended to satisfy Belle Haven Investments, L.P.’s (“Belle Haven”, or the “Firm”) fee disclosure requirements as a Covered Service Provider under Section 408(b)(2) of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended.  A Covered Service Provider is a service provider that enters into an agreement or arrangement with a covered plan (the “Plan”) under ERISA, and who expects to receive compensation, directly or indirectly in connection with providing services to the Plan.

 

This Disclosure Statement is intended to be read in conjunction with Belle Haven’s current Form ADV Part 2A, and if applicable, the Investment Management Agreement between Belle Haven and the Plan, which provides detailed information regarding our investment advisory services, our management fees, financial industry affiliates, and potential conflicts of interest.

 

This Disclosure Statement is only for use with Plan Administrators; if you are not a Plan Administrator, please contact us to obtain the proper Disclosure Statement.

 

Belle Haven Investments L.P. ERISA 408(B)(2) Disclosure Statement March 2024

 

BUSINESS CONTINUITY PLAN

Belle Haven 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.

 

The Firm has adopted Pandemic Mitigation and Airborne Infectious Disease Prevention Guidance and Procedures in addition to the Firm’s Business Continuity Plan and Procedure to address the steps the Firm has taken, and will continue to take, in mitigating the potential impact to business operations in response to COVID-19, or any other highly contagious airborne infectious disease, designated as such by the New York State Department of Health. Belle Haven is committed to providing authoritative information about the nature and spread of any such pandemic, including symptoms and signs to monitor for, as well as the required steps to be taken in the event of illness or outbreak in the office. The health, safety, and well-being of Belle Haven’s employees and clients are the Firm’s top priority.

 

Belle Haven Investments, L.P. - Business Continuity Plan Disclosure Statement

Belle Haven Investments, L.P. - Business Continuity Plan - Pandemic Mitigation and Airborne Infectious Disease Exposure Prevention Plan Statement

 

INVESTOR EDUCATION AND RESOURCES

SECURITIES INVESTOR PROTECTION CORPORATION (“SIPC”) INFORMATION
Belle Haven Investments, L.P. is a member of SIPC. Information regarding SIPC, including a SIPC brochure, may be obtained by contacting SIPC via its website at www.sipc.org or by telephone at (202) 371-8300.

 

FINANCIAL INDUSTRY REGULATORY AUTHORITY (“FINRA”) INVESTOR EDUCATION AND PROTECTION
Belle Haven Investments, L.P. is a member of FINRA. BrokerCheck is a free tool from FINRA that can help you research the professional background of brokers and firms. A brochure that includes information describing FINRA BrokerCheck and Public Disclosure Program may be obtained from FINRA at www.finra.org. The FINRA BrokerCheck hotline number is (800) 289-9999.

 

MUNICIPAL SECURITIES RULEMAKING BOARD (“MSRB”) RULE G-10 INVESTOR AND MUNICIPAL ADVISORY CLIENT EDUCATION AND PROTECTION
Belle Haven Investments, L.P. is registered with the Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (”FINRA”) and Municipal Securities Rulemaking Board (“MSRB”). An investor brochure that describes the protections available under MSRB rules, and instructions on how to file a complaint with an appropriate regulatory authority can be found on the MSRB website at www.msrb.org.

 

GENERAL INVESTMENT RISKS

Each specific investment strategy will have its own set of specific risks.  Please refer to our Form ADV Part 2A for more information about the specific risks associated with fixed income investing.

 

Risk is inherent in all investing.  Investing in securities involves risk of loss that clients should be prepared to bear. Risks factors may vary based on the investment strategy and the specific securities held in a client’s account. Clients should be prepared for this possibility and understand the risks.  

 

Belle Haven does not provide tax or legal advice. Each individual investor tax and financial situation is unique, and investment decisions should be made based on an investor’s objective and circumstances, and in consultation with their professional tax, financial and/or legal advisor.

 

All decisions regarding the tax implications of your investment(s) should be made in consultation with your independent tax advisor. Any material prepared or distributed to you by Belle Haven, at the request of you or your primary investment advisor, is solely for information purposes, and does not replace or supersede information on your custodial account statement and/or trade confirmations, which are to be your official record of holdings, balances, and security values for your account. We urge you to compare the information that appears on this statement to the information that appears on the statement you receive from your custodian.

 

INVESTMENT DEFINITIONS

Alpha represents the risk-adjusted excess return of an investment relative to its benchmark index.

Beta assesses an investment’s volatility in relation to the broader market.

R2 measures the proportion of an investment’s price movements attributed to the movements of its benchmark index.

Sharpe Ratio evaluates the return of an investment relative to its risk.

Up Capture Ratio measures the percentage of market gains an investment captures in a rising market.

Down Capture Ratio measures the percentage of market losses an investment endures in a declining market.

Standard Deviation measures the extent to which returns on an investment deviate from its average return.

Duration measures the sensitivity of an investment’s price to changes in interest rate.

 

FIRM AND WEBSITE DISCLOSURES

Belle Haven Investments, L.P., (“Belle Haven” or the “Firm”) is defined as a fixed income manager of separately managed and sub-advised portfolios. The Firm 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, L.P. Belle Haven Investments, L.P.’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 material contained on the Firm’s website (including any attachments or links) is for educational purposes only and is 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 contained herein is obtained from sources believed to be reliable, but its accuracy or completeness is not guaranteed. All opinions expressed are subject to change without notice. Investment decisions should be made based on an investor’s objective and circumstances, and in consultation with their professional tax, financial or legal advisor.

 

The material contained on the Firm’s website (including any attachments or links) should not be considered tax or legal advice and investors should contact their tax professional for information regarding their tax situation. Investing in municipal bonds for the purpose of generating tax-exempt income may not be appropriate for investors in all tax brackets or for all account types. 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. In addition, bonds incur ongoing fees and expenses. An investment in a portfolio involves various risks, including the risk that an investor can lose money. Investing in the bond market is subject to certain risks, including market, interest rate, issuer, credit, inflation, and liquidity risk. While the Manager strives to attain the investment objective of the strategy through research and portfolio management skills, there is no guarantee of successful performance, that the objective can be reached or that a positive return can be achieved. Past performance is no guarantee of future results.

 

Any awards or recognition referenced are produced by firms other than Belle Haven Investments, L.P. Criteria used to determine these awards may vary depending on the organization presenting the award. Belle Haven Investments, L.P. cannot guarantee the accuracy of any other firm’s ranking or ranking methodology. For further information on obtaining a list of such criteria and/or additional information on our strategies or awards, please contact service@bellehaven.com.           

 

This material is not directed to, or intended for distribution or to use by, any person or entity if Belle Haven Investments, L.P. 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, L.P.

 

Belle Haven Investments, L.P. is registered with the Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (”FINRA”) and Municipal Securities Rulemaking Board (“MSRB”).  Additional information about Belle Haven Investments is also available on the SEC’s website at www.adviserinfo.sec.gov. 

 

Belle Haven claims compliance with the Global Investment Performance Standards (“GIPS®”). GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein. To receive additional information regarding Belle Haven, including GIPS-compliant performance information for Belle Havens' strategies and products, contact service@bellehaven.com.

 

© Copyright Belle Haven Investments, L.P. 2024. 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, LinkedIn, Spotify and iTunes (“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 current as of the date of publication (or such earlier date as referenced), and is subject to change without notice. Nothing published or otherwise disseminated on Belle Haven Social Media Platforms should 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. Investment decisions should be made based on an investor’s objective and circumstances, and in consultation with their professional tax, financial or legal advisor.

 

All content published or otherwise disseminated on Belle Haven Social Media Platforms (including any attachments or links), should not be considered tax or legal advice and investors should contact their tax professional for information regarding their tax situation. Investing in municipal bonds for the purpose of generating tax-exempt income may not be appropriate for investors in all tax brackets or for all account types. 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. In addition, bonds incur ongoing fees and expenses. An investment in a portfolio involves various risks, including the risk that an investor can lose money. Investing in the bond market is subject to certain risks, including market, interest rate, issuer, credit, inflation, and liquidity risk. While the Manager strives to attain the investment objective of the strategy through research and portfolio management skills, there is no guarantee of successful performance, that the objective can be reached or that a positive return can be achieved. Past performance is no guarantee of future results.

 

Any securities identified and/or described on any Belle Haven Social Media Platforms, 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 Platforms, 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 advisor 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 their 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 or otherwise disseminated on Belle Haven Social Media Platforms are 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 Platforms. In using any of the links embedded within a Belle Haven Social Media Platforms, 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 terms of use 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. If Belle Haven does not remove a third-party post, it is not an endorsement of the content.

 

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, L.P.   

 

AWARDS AND RECOGNITION

Any awards or recognitions referenced are produced by firms other than Belle Haven Investments, L.P. Criteria used to determine these awards may vary depending on the organization presenting the award. Belle Haven Investments, L.P. cannot guarantee the accuracy of any other firm’s ranking or ranking methodology. For further information on obtaining a list of such criteria and/or additional information on our strategies or awards, please contact service@bellehaven.com.           

 

Lipper Criteria

Lipper Best Money Manager Rankings:  Lipper MarketPlace Rankings are based upon past performance which does not guarantee future results. Lipper MarketPlace is an investment manager database that serves as a third-party supplier of information. Lipper MarketPlace’s Best Money Manager ranking is a survey of institutional money manager performance. To be eligible for inclusion as a Lipper Best Money Manager, performance must be calculated on an asset size which is at least $10 million in size for traditional U.S. asset classes or $1 million for international and alternative investments. Classifications must fall into one of the categories that Lipper ranks (minimum of 20 contenders).   Lipper MarketPlace rankings reflect strategies’ historical total return performance, excluding sales charges, as applicable, relative to peers as of the above quarter end date. Performance data must be calculated in U.S. dollars and net of fees. Rankings are relative to a peer group and do not necessarily mean that the fund had high total returns. Strategies are placed into peer groups by Lipper MarketPlace, based upon information submitted by portfolio managers. Lipper MarketPlace does not guarantee the accuracy of this information. See www.lippermarketplace.com for more information on categories and performance rankings. For recent performance information on any Belle Haven strategy, please contact service@bellehaven.com.

 

Here are the minimum criteria for inclusion in Best Money Managers:

1. Performance must be calculated "net” of all fees and brokerage commissions. This means after all fees have been deducted. This standard is somewhat controversial, as the SEC requires that only "net” of fees numbers be presented publicly, while GIPS (Global Investment Performance Standards) prefers that "gross” numbers be presented along with a fee schedule. Since the SEC is a regulatory authority, and since complete fee schedule presentation would be impractical in this "ranking" format, we require "net” numbers.
2. Performance must be calculated inclusive of all cash reserves. To explain, any given investment portfolio will hold some level of cash over a particular reporting period. Even equity portfolios which specifically seek to be fully invested in the market at all times will temporarily have dividend payments and other ordinary cash flows which cannot instantaneously be invested in the market. These cash holdings obviously will have an effect on the performance of the overall portfolio – negative when cash returns are low relative to returns of the asset class, and positive if the opposite is true. While presentation of "equity-only” (for example) returns may provide a valuable insight into the security selection skills of the manager, we require for comparability's sake that performance results be inclusive of cash reserves for consideration in the rankings.
3. Performance results must be calculated in U.S. dollars, that is, from the perspective of a U.S.-based investor. Currency holdings can have a very significant impact on the performance of a portfolio with international holdings. While this will always be the case (as we do not make distinctions between hedged and unhedged portfolios), we require that performance must be translated into U.S. dollars to ensure comparability to the point where these are all returns that would be seen by a U.S.-based investor.
4. Performance results must be calculated on an asset base which is at least $10 million in size for "traditional” U.S. asset classes (equity, fixed income, and balanced accounts) or at least $1 million in the case of international and "alternative” U.S. asset classes. This minimum ensures that the firm and product are somewhat established. The goal is to not taint the rankings with "flashes in the pan” while also not excluding promising emerging managers. The minimum asset base requirement, therefore, is set at a level which balances these objectives.
5. The classification of the product must fall into one of the categories which we rank. We only publish rankings for categories/time period combinations for which we have at least 20 contenders

 

PSN Top Guns Criteria

PSN Informa Top Gun Awards: Managers eligible for the Top Gun Awards are categorized into one of six “star” categories; within those categories, managers are ranking according to the below criteria. All Belle Haven Strategies are currently classified as 2 star and above and subject to the below analysis. For more information on other categories or rankings, please see http://psn.informais.com/topguns/topguns.asp:

 

Criteria: The PSN universes were created using the information collected through the PSN investment manager questionnaire and use only gross of fee returns. Mutual fund and commingled fund products are not included in the universe. PSN Top Guns investment managers must claim that they are GIPS compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for a five-year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. At this point, the top ten performers for the latest 3-year period become the 4 STAR TOP GUNS. Products are then selected which have a standard deviation for the five-year period equal or less than the median standard deviation for the peer group. The top ten performers for the latest 3-year period become the 5 STAR TOP GUNS. The top ten information ratios for the latest five-year period ending then become the 6 STAR TOP GUNS.

 

1 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on current quarter returns.

2 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the one-year period.

3 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the three-year period.

4 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the recent five-year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. The top ten returns for the latest three-year period then become the TOP GUNS.

5 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five-year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five-year period equal or less than the median standard deviation for the peer group. The top ten returns for the latest three-year period then become the TOP GUNS.

6 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five-year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five-year period equal or less than the median standard deviation for the peer group. The top ten information ratios for the latest five-year period then become the TOP GUNS.

 

Top Guns of The Decade Criteria

The PSN universes were created using the information collected through the PSN investment manager questionnaire and use only gross of fee returns. Mutual fund and commingled fund products are not included in the universe. PSN Top Guns investment managers must claim that they are GIPS compliant. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the ten-year period. Moreover, products must have returns greater than the style benchmark for the ten-year period and also standard deviation less than the style benchmark for the ten-year period. At this point, the top ten performers for the latest ten-year period become the PSN Top Guns Manager of the Decade.

 

The content of PSN Top Guns is intended for use by qualified investment professionals. Please consult with an investment professional before making any investment decisions using content or implied content from PSN Top Guns. Due to the short-term nature of a one quarter performance benchmark, please be advised that the 1 Star PSN Top Guns rating is intended for informational purposes only and should be used only in a one-on-one and face-to-face presentation where an investment professional is present. Any other usage of the 1 Star PSN Top Guns is strictly prohibited, not advised, and not permitted by Informa Financial Intelligence.

 

All Rights Reserved. PSN Top Guns is powered by PSN. PSN is an investment manager database and is a division of Informa Financial Intelligence (IFI). No part of PSN Top Guns may be reproduced in any form or by any means, electronic, mechanical, photocopying, or otherwise without the prior written permission of Informa Financial Intelligence

 

Because of the possibility of human or mechanical error by IFI sources or others, IFI does not guarantee the accuracy, adequacy, completeness, or availability of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. THERE ARE NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall IFI be liable for any indirect, special or consequential damages in connection with use of any information or derived using information based on PSN Top Guns results.

 

ORDER ROUTING

Disclosure Pursuant to SEC Rule 606 - Order Routing

Pursuant to the Securities and Exchange Commission (“SEC”) Rule 606, Belle Haven Investments, L.P. (“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 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, at https://www.orderroutingdisclosure.com.

 

ANTI-MONEY LAUNDERING: CUSTOMER IDENTIFICATION PROGRAM

Important Information You Need to Know About Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, financial organizations are required by federal law to obtain, verify, and record information that identifies each individual or entity that opens an account.  

 

This notice answers some questions about Belle Haven’s Customer Identification Program.

 

What types of information will I need to provide?

What this means for individuals: When an individual opens a direct account with us, we will ask for that individual’s name, residence address, date of birth, tax identification number (social security number) and other information that allows us to identify them. We may also ask for a driver’s license, passport, or other identifying documents.

What this means for legal entities: When a corporation, partnership, trust, or other legal entity opens a direct account with us, we will ask for the entity’s name, physical address, tax identification number, government-issued business license and other information that will allow us to identify the entity. If applicable, the same information will be collected about the beneficial owner(s) of the entity. We may also ask for certain identifying documents, such as certified articles of incorporation, partnership agreements or a trust instrument. 

 

The U.S. Department of the Treasury, Securities and Exchange Commission (“SEC”), and the Financial Industry Regulatory Authority (“FINRA”) rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.

 

What happens if I don't provide the information requested or my identity can't be verified?

Belle Haven may not be able to open an account or carry out transactions for you. If Belle Haven has already opened an account for you, we may have to close it.

 

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) administers and enforces economic sanctions programs implemented by the government.  Belle Haven is required to comply with all OFAC sanctions.  This may include blocking or rejecting transactions or funds of certain individuals and entities if it reasonably believes violates any of the OFAC sanctions programs.