Firm Compliance & Disclosures
Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is a dually registered broker-dealer and investment advisor specializing in the trading and management of separately managed fixed income investment strategies. The Firm manages taxable and tax-sensitive portfolios 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”).
CLIENT RELATIONSHIP SUMMARY
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 - March 2025
Belle Haven Investments, L.P. Disclosure Brochure - March 2025
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 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 - March 2025
PRIVACY NOTICE
At Belle Haven, we understand the importance of safeguarding the privacy and security of the nonpublic personal information we collect about you. This Privacy Notice is designed to provide you with a clear understanding of the Firm's Privacy Policy, including the types of information we collect, how we share it, and the measures we take to protect your nonpublic personal information, as required or permitted by law, to help us serve your financial needs.
For any questions or concerns regarding this Notice or other privacy-related matters, or to request a copy of our Privacy Policy, please contact us (914) 816-4633 or compliance@bellehaven.com.
Belle Haven Investments, L.P. - Privacy Notice March 2025
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 2025
BUSINESS CONTINUITY PLAN
Belle Haven has developed a Business Continuity Plan and Procedure (“BCP”) to define how the Firm will respond to events that could significantly disrupt its business operations. Given the unpredictable nature of the timing and impact of catastrophes, pandemics, and other significant business disruptions, the Firm remains adaptable in its approach to handling such events. Below, the Firm outlines the Business Continuity Plan and objectives.
CONTACTING BELLE HAVEN
Belle Haven is located at 800 Westchester Avenue, Suite N607, Rye Brook, NY 10573. The Firm’s main telephone number is (914) 816-4633. In the event of a significant business disruption where you are unable to reach Belle Haven using the main telephone number, you are encouraged to contact the Firm’s alternative number of (914) 816-4622. Additionally, you may visit the Firm’s website at bellehaven.com for further information. If access to the Firm remains unavailable through these channels, please contact our clearing firm, Pershing, LLC (“Pershing”), directly at (201) 413-3333, or visit their website, pershing.com. You may also reach out to the custodian where your account is held for guidance regarding prompt access to your funds, securities, or other account-related inquiries.
BUSINESS CONTINUITY PLAN SUMMARY
The Firm’s BCP is structured to ensure that business operations can resume as quickly as possible, given the scale and severity of any disruption. The BCP outlines the Firm’s protocols for mitigating both internal and external disruptions, including data backup and recovery procedures, financial and operational assessments, identification of mission-critical systems, and alternative communication channels for clients, employees, and regulators. The BCP also provides contingency measures for relocating employees in the event of an office closure, while ensuring clients can promptly access their funds and securities should the Firm be unable to continue critical business operations.
For accounts held at Pershing, the Firm’s critical business service recovery time objective is four (4) hours or less, depending on the availability of external resources. This objective includes the restoration of operations, processing of existing transactions, and acceptance of new transactions and payments. Please note that orders and requests for funds and securities may experience delays during this recovery period. For clients with accounts not held at Pershing, we advise you to contact your custodian for details regarding their specific Business Continuity Plan.
PANDEMIC MITIGATION AND AIRBORNE INFECTIOUS DISEASE SUMMARY
Belle Haven has taken comprehensive measures to ensure the continuity of critical business functions during a global pandemic, such as COVID-19. The Firm has adopted specific Pandemic Mitigation and Airborne Infectious Disease Prevention Procedures in addition to its Business Continuity Plan to address potential impacts arising from highly contagious airborne infectious diseases, designated as such by the New York State Department of Health. The health, safety, and well-being of Belle Haven’s employees and clients remain the Firm’s top priority. Belle Haven is committed to staying informed and prepared, following the guidance of health experts and local and state authorities to ensure that best practices are followed. In the event of an airborne infectious disease outbreak, the Firm will adapt its protocols as necessary in accordance with available guidance.
VARYING DISRUPTIONS
Business disruptions can vary significantly in scope, location, and impact. Disruptions may be internal, such as a network outage, or external, such as a global pandemic, terrorist attack, or regional natural disaster. The severity of these disruptions can range from minimal to catastrophic.
In the event of a localized disruption affecting Belle Haven, the Firm will transfer its operations to a local site, with the expectation of recovery and resumption of business operations within four (4) hours. In the case of disruptions affecting the Firm’s location or region, operations will be moved to an alternate site outside the affected area, and recovery will occur within the same timeframe. During such disruptions, the Firm will continue to conduct operations to the best of its ability and may transfer specific operations to its clearing firm, Pershing, LLC. Communication with clients will occur through all available channels to provide updates on business continuity procedures. If a disruption is severe enough to prevent the Firm from continuing operations, Belle Haven will ensure clients have prompt access to their funds and securities.
SUMMARY
Belle Haven’s Business Continuity Plan and Procedure is reviewed and tested annually to validate its effectiveness in responding to potential disruptions. These tests assess the Firm’s ability to mitigate real-world events that could disrupt business operations. Belle Haven is committed to remaining responsive to all client needs during any period of disruption.
FOR MORE INFORMATION
For questions about our Business Continuity Plan please contact us at (914) 816-4633 or email us at compliance@bellehaven.com.
Belle Haven Investments, L.P. - Business Continuity Plan Disclosure 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. Past performance is no guarantee of future results. 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.
RATING DISTRIBUTION
The holdings and characteristics of a portfolio, including their weightings, are subject to change and may fluctuate over time. Bond ratings, which reflect the issuer’s financial strength, range from AAA (the highest rating) to D (the lowest rating) and may vary over time. Securities rated BBB and above are considered investment-grade.
FIRM AND WEBSITE DISCLOSURES
The material contained on the Firm’s website (including any attachments or links) is for educational purposes only and should not be relied upon as a forecast, research, investment advice, or a recommendation, offer, or solicitation for the purchase or sale of any security, or the adoption of a specific investment strategy. The information is obtained from sources believed to be reliable; however, its accuracy or completeness is not guaranteed. The opinions expressed reflect the views as of the date of the publication (or an earlier referenced date), and are subject to change without notice. Investment decisions should be based on an investor’s individual objectives and circumstances, and made in consultation with their professional tax, financial or legal advisor.
The material contained on the Firm's website (including any attachments or links), is not intended to serve as tax or legal advice. Investors should consult their tax professional for guidance specific to their individual tax situation. Investing in municipal bonds to generate tax-exempt income may not be suitable for all investors, depending on their tax bracket or account type. Municipal fixed-income securities may have less publicly available information compared to publicly traded corporations, and can be less liquid than corporate bonds. Additionally, a portion of the income may be subject to state or local taxes, and municipal bondholders may also be subject to capital gains taxes, with interest potentially subject to the alternative minimum tax. Furthermore, bonds are subject to ongoing fees and expenses. Investments in portfolios involves various risks, including the potential loss of principal. The bond market is subject to specific risks, such as market, interest rate, issuer, credit, inflation, and liquidity risks. 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, nor is there any assurance that the objective will be met or that a positive return will be realized. Past performance is no guarantee of future results.
This material is not intended for distribution or use by any person or entity in any jurisdiction where such distribution is prohibited or restricted by applicable laws or regulations. This report may not be reproduced, redistributed, or shared with any third party, in whole or in part, for any purpose without the prior written 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 adheres to the Global Investment Performance Standards (“GIPS®”). GIPS® is a registered trademark of the CFA Institute. The CFA Institute does not endorse or promote Belle Haven, nor does it guarantee the accuracy or quality of the content provided. For more information about Belle Haven, including GIPS-compliant performance data for the Firm's strategies and products, please contact service@bellehaven.com.
© Copyright Belle Haven Investments, L.P. 2025. 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, X (Twitter), LinkedIn, Spotify, and iTunes (“Belle Haven Social Media Platforms”), is obtained from sources believed to be reliable; however, its accuracy or completeness is not guaranteed. The opinions expressed on Belle Haven Social Media Platforms reflect the views as of the date of publication (or an earlier referenced date), and are subject to change without notice. Nothing published or otherwise disseminated on Belle Haven Social Media Platforms should be construed as a forecast, research, or investment advice, nor should it be interpreted as a recommendation, offer, or solicitation for the purchase or sale of any security, or adopt a specific investment strategy. Investment decisions should be based on an investor’s individual objectives and circumstances, and made 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), is not intended to serve as tax or legal advice. Investors should consult their tax professional for guidance specific to their individual tax situation. Investing in municipal bonds to generate tax-exempt income may not be suitable for all investors, depending on their tax bracket or account type. Municipal fixed-income securities may have less publicly available information compared to publicly traded corporations, and can be less liquid than corporate bonds. Additionally, a portion of the income may be subject to state or local taxes, and municipal bondholders may also be subject to capital gains taxes, with interest potentially subject to the alternative minimum tax. Furthermore, bonds are subject to ongoing fees and expenses. Investments in portfolios involves various risks, including the potential loss of principal. The bond market is subject to specific risks, such as market, interest rate, issuer, credit, inflation, and liquidity risks. 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, nor is there any assurance that the objective will be met or that a positive return will be realized. Past performance is no guarantee of future results.
Any securities mentioned or described on Belle Haven Social Media Platforms, do not represent the full spectrum of securities purchased, sold, or recommended for client accounts by Belle Haven. There should be no assumption that an investment in the securities identified on Belle Haven Social Media Platforms, was or will be profitable in the future. Belle Haven may or may not currently hold, or intend to hold, the securities discussed on its Social Media Platforms. Belle Haven reserves the right to remove or report any posts or comments on its Social Media Platforms, including but not limited to advertising or promotional materials. Additionally, Belle Haven does not accept purchase or sell orders through its Social Media Platforms and advises to not to disclose any personal or financial information on these platforms.
Third-party content published or otherwise shared on Belle Haven’s Social Media Platforms reflects the views of the contributing third-party and not those of Belle Haven. Belle Haven does not guarantee the appropriateness, accuracy, or usefulness of any third-party content or hyperlinks, nor is it responsible for any unauthorized or copyrighted material posted by third parties on its Social Media Platforms. By using any links embedded within Belle Haven’s Social Media Platforms, you acknowledge that they are provided solely for informational purposes and do not imply any affiliation, sponsorship, endorsement, or representation by Belle Haven with respect to the linked third-party websites. Belle Haven is not responsible for the content, accuracy, completeness, reliability, or privacy practices of these external sites and assumes no liability for any information, opinions, advice, products, or services available on or through them. Belle Haven reserves the right to remove, modify, or edit any third-party content published or posted on its Social Media Platforms. The absence of removal of a third-party post does not constitute an endorsement of the content.
Neither the SEC nor any other federal or state agency, nor any non-U.S. commission, has verified the accuracy or determined the adequacy of the information published or disseminated by Belle Haven on any of its Social Media Platforms. Any claim to the contrary is unlawful. By accessing such content, each reader acknowledges that the information published or disseminated by Belle Haven on its Social Media Platforms is not directed at, nor intended for distribution to or use by, any person or entity in jurisdictions where Belle Haven is prohibited or restricted by law or regulation from making it available. The content may not be reproduced, redistributed, forwarded, or published in whole or in part for any purpose without the prior written 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:
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.