Overview
Assets Under Management: $491 million
Headquarters: SUMMIT, NJ
High-Net-Worth Clients: 88
Average Client Assets: $5 million
Services Offered
Services: Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (BRAVE ASSET MANAGEMENT, INC.)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
Number of High-Net-Worth Clients: 88
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 81.97
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 777
Discretionary Accounts: 777
Regulatory Filings
CRD Number: 108512
Last Filing Date: 2024-03-15 00:00:00
Website: https://bravefamilyadvisors.com
Form ADV Documents
Primary Brochure: BRAVE ASSET MANAGEMENT, INC. (2025-03-21)
View Document Text
BRAVE FAMILY ADVISORS
47 SUMMIT AVENUE, SUMMIT, NJ 07901
908-522-8822
MARCH 2025
This Brochure provides information about the qualifications and business practices of Brave Asset
Management, Inc. doing business as BRAVE Family Advisors (“ADVISER” or “BFA”). If you
have any questions about the contents of this Brochure, please contact us at 908-522-8822. The
information in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
BFA is a federally registered investment adviser. Registration of an Investment Adviser does not
imply any level of skill or training. The oral and written communications of an Investment Adviser
provide you with information about which you determine to hire or retain an Investment Adviser.
MATERIAL CHANGES
The following material changes have been made to this Brochure since March 2024, the date of
the last Brochure:
We have no material changes to report since our last annual update filing.
Pursuant to the SEC’s Rules, we will ensure that you receive a summary of any material changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We
may further provide other ongoing disclosure information about material changes as necessary.
We will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Currently, our Brochure may be requested by contacting Mr. Jamie Haire at 908-522-8822 or
jhaire@bravefamilyadvisors.com.
information about BFA
is also available via
the SEC’s web
site
Additional
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons
affiliated with BFA who are registered, or are required to be registered, as investment adviser
representatives of BFA.
ii
TABLE OF CONTENTS
MATERIAL CHANGES .............................................................................................................................. ii
TABLE OF CONTENTS ............................................................................................................................. iii
ADVISORY BUSINESS .............................................................................................................................. 1
FEES AND COMPENSATION ................................................................................................................... 1
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................. 2
TYPES OF CLIENTS ................................................................................................................................... 2
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................... 2
INVESTMENT CONSULTING SERVICES ............................................................................................... 3
DISCIPLINARY INFORMATION .............................................................................................................. 4
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 4
CODE OF ETHICS ....................................................................................................................................... 4
BROKERAGE PRACTICES ........................................................................................................................ 5
REVIEW OF MANAGED ACCOUNTS ..................................................................................................... 6
CLIENT REFERRALS AND OTHER COMPENSATION......................................................................... 6
CUSTODY .................................................................................................................................................... 6
INVESTMENT DISCRETION .................................................................................................................... 6
VOTING CLIENT SECURITIES ................................................................................................................ 7
FINANCIAL INFORMATION .................................................................................................................... 7
iii
ADVISORY BUSINESS
BFA is a federally registered investment adviser that provides investment supervisory and
consulting services to its clients. Effective as of July 2020, we rebranded and commenced doing
business under the name BRAVE Family Advisors. BFA is owned by its principals T. Brett Haire,
Jr. (“Mr. Brett Haire”), Scott A. Morrison (“Mr. Morrison”) and James P. Haire (“Mr. Jamie
Haire”) and has been in business since 1992. Effective as of January 1, 2022, Mr. Jamie Haire
replaced Mr. Brett Haire as the Chief Compliance Officer of BFA. Clients’ investment accounts
are managed upon a discretionary basis, and, upon request, a non-discretionary basis.
After a careful review of each client’s needs and goals, BFA personalizes the services it offers.
Upon first meeting with a new client, BFA will determine that client’s risk tolerance. Once so
identified, BFA will move forward to build a balanced portfolio of equities and fixed income
products which matches the risk profile created. Additionally, some clients may impose
restrictions on the investment in certain securities or types of securities. For example, sometimes
clients may not wish to invest in certain industry sectors consistent with their personal or political
beliefs. BFA’s principals explain to each client the elements of the portfolio it develops and will
also explain the potential implications of any restrictions imposed by a client. BFA also offers
investment consulting services to “participant-directed” retirement plans established by a plan
sponsor under the provisions of Section 404(c) of the Employee Retirement Income Security Act
of 1974, as the same shall be amended or updated from time to time (“ERISA”) (each a “Plan”).
As of December 31, 2024, BFA managed $542,786,417 of its clients’ assets on a discretionary
basis and $0 of its clients’ assets on a non-discretionary basis.
FEES AND COMPENSATION
The annual fee for investment account management services of new clients who commence receipt
of services from BFA after January 1, 2013, is one percent (1%) of the value of all managed assets
of such client.
The annual fee is calculated quarterly, representing one-fourth of the annual rate fee, and is based
upon the value of managed assets on the last business day of each calendar quarter. The fee is
payable at the end of each calendar quarter for which services have been provided. BFA does not
accept any prepayment of advisory fees. In the event the assets managed by the Adviser are under
management for less than one calendar quarter, BFA’s compensation shall be calculated and
payable on a pro rata basis. The advisory fees charged by BFA are negotiable and on a tiered fee
schedule.
The consulting fees charged by BFA to Plans are assessed on a negotiated basis point cost with
the Plan.
For ease of operation, BFA requests permission from investment management clients and plans to
deduct appropriate quarterly fees calculated in arrears from their account; however, if a client
would prefer to pay by check that form of payment is acceptable as well.
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BFA’s fees assessed to its clients are exclusive of brokerage commissions, transaction fees, and
other related costs and expenses which may be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, third party investment and other third parties such as
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds also charge internal management fees, which are
disclosed in a fund’s prospectus. Such charges, fees and commissions are all exclusive of and in
addition to BFA’s fee, and BFA shall not receive any portion of these commissions, fees, and
costs.
The specific manner in which fees are charged by BFA is established in a client’s written
agreement with BFA. Management fees shall be prorated for each capital contribution and
withdrawal made during the applicable calendar quarter (with the exception of de minimis
contributions and withdrawals).
Upon termination of any account, any earned, unpaid fees will be due and payable.
Regarding brokers’ fees compensation, please also refer to the section entitled “Brokerage
Practices” below which describes the factors BFA considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
BFA does not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client).
TYPES OF CLIENTS
BFA provides portfolio management services to individuals, high net worth individuals, charitable
institutions, foundations, estates, and trusts. BFA maintains no established minimum asset
requirement for such clients’ accounts. BFA also offers investment consulting services to Plans.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS
BFA uses a variety of methods of analysis and investment strategies to formulate its investment
advice and manage assets. These methods include charting, fundamental, technical, and cyclical
analyses.
Strategies used to implement investment advice given to clients may include long term and short-
term purchases (securities held less than or more than one year), trading securities (securities sold
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within a year) short sales, margin transactions, writing and buying options.
Generally, BFA discourages the use of leverage in its clients’ investment portfolios. The risks of
using short sales include the fact that while the possible gains are limited, an adverse price change
can mean that an investor loses more than the original value with the potential of no upper limit.
Due to risk, BFA uses short sales sparingly, usually to hedge market risk or to arbitrage temporary
price distortions. Margin transactions are used by a limited number of clients, often as a source of
short-term borrowing for specific purposes. The risks of trading securities on margin include the
potential loss of more than what the client deposited if the value of the purchased securities decline
and there is a forced sale to cover a margin deficiency. Option activity is confined to a small
number of client accounts and used with close consultation between BFA and the client regarding
the anticipated outcome relative to the funds invested. Writing and buying options entails the risk
of the option’s value changing over time as the value is impacted by how much the underlying
security price moves, how long it takes and the security’s volatility.
BFA does not guarantee the future performance of any account or any specific level of
performance, or the success of any investment decision or strategy. All investment decisions are
subject to various market, currency, economic, political and business risks and investment
decisions will not always be profitable. As a client, you are advised that it remains your
responsibility to promptly notify us if there is ever any change in your financial situation or
investment goals so that BFA’s review of your portfolio may be updated in line with your current
financial objectives.
Investing in securities involves risk of loss that clients should be prepared to bear.
INVESTMENT CONSULTING SERVICES
BFA offers investment consulting services to “participant-directed” retirement plans established
by a Plan sponsor under the provisions of Section 404(c) of ERISA. Section 404(c) permits a plan
participant to exercise control over the assets which comprise such participant’s retirement account
under the plan. BFA provides the following services to those types of Plans and their participants:
• Recommendations on Plan investment options to Plan sponsor;
• Assistance with enrollment of Plan participants;
• Education of participants on Plan investment elections; and
• Periodic review of Plan performance with Plan sponsor.
All these consulting services are provided as “investment education” and not with a view to BFA
being a “fiduciary” of such Plan assets. BFA does not have any discretionary control over any
Plan assets.
BFA additionally does not provide individualized investment advice to Plan participants and any
investment recommendations by BFA are provided solely to the Plan sponsor regarding the Plan
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assets. Specifically, BFA does not provide individualized advice to Plan participants in the event
that the following situations are present with respect to a Plan:
•
the Plan permits individual self-directed brokerage accounts and/or participant loans
thereunder; or
•
the Plan permits Plan participants to invest in publicly traded stock of the Plan sponsor.
DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of BFA or the integrity of BFA’s
management. BFA has no information applicable to this Item.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
BFA has no relevant information to provide for this Item.
CODE OF ETHICS
BFA has adopted a Code of Ethics for all supervised persons of the firm describing its high
standards of business conduct, and fiduciary duty to its clients. The Code of Ethics includes, among
other things, provisions relating to the confidentiality of client information, a prohibition on insider
trading, the reporting of personal securities trading procedures, addresses conflicts which may
arise from personal trading by BFA’s supervised persons and reminds supervised persons they
must abide by federal and state securities laws. All supervised persons at BFA must acknowledge
the terms of the Code of Ethics annually, or as amended.
BFA’s employees and persons associated with BFA are required to follow BFA’s Code of Ethics.
Consistent with clients’ investment objectives, BFA may cause accounts over which it has
management authority to effect (and may recommend to clients or prospective clients), the
purchase or sale of securities in which BFA, and/or its clients, directly or indirectly, have a position
of interest. Subject to following the Code of Ethics, and applicable laws, principals, officers,
employees and supervised investment adviser representatives of BFA may trade for their own
accounts in securities which are recommended to and/or purchased for BFA’s clients. The Code
of Ethics is designed to assure that the personal securities transactions, activities and interests of
BFA’s principals, officers, employees and supervised investment adviser representatives will not
interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing
such decisions while, at the same time, allowing employees to invest for their own accounts.
Nonetheless, because the Code of Ethics would permit principals, officers, employees and
supervised investment adviser representatives to invest in the same securities as clients, there is a
possibility that such party might benefit from market activity by a client in a security held by said
party. Trading by such parties is continually monitored under the Code of Ethics to reasonably
prevent conflicts of interest between BFA and its clients.
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Certain affiliated accounts may trade in the same securities with client accounts on an aggregated
basis when consistent with BFA’s obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a total
average price. BFA will retain records of the trade order (specifying each participating account)
and its allocation, which will be completed prior to the entry of the aggregated order. Completed
orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated
on a pro rata basis. Any exceptions will be explained in the order.
Clients will receive priority in execution of orders on those occasions when client and Adviser (or
a person related to the Adviser) are active in the security simultaneously. This process is
coordinated by the Adviser’s officers located at the trading desk who will exercise continual
oversight.
BFA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting
Mr. Jamie Haire.
BFA acts as adviser to clients that include BFA’s own shareholders, officers, employees, and their
respective relatives. With respect to any such clients, BFA may give advice, and take action which
may differ from the advice given with respect to a client’s account. Adviser shall have no
obligation to purchase or sell for a client’s account, or to recommend for purchase or sale by a
client’s account, any security which Adviser, its principals, affiliates, employees or supervised
investment adviser representatives may purchase or sell for themselves or for any other clients,
however, neither Adviser nor any of its shareholders, directors, officers, employees or supervised
investment adviser representatives will act as a principal in connection with transactions involving
a client’s account without that client’s specific prior written approval.
BFA will not effect any principal or agency cross securities transactions for client accounts. Also,
it will not cross trades between client accounts. Principal transactions are generally defined as
transactions where an adviser, acting as principal for its own account, buys from or sells any
security to any advisory client.
BROKERAGE PRACTICES
When BFA has discretionary authority over an account, it has the authority to determine, without
obtaining specific client consent, the securities to be bought or sold and the amount of securities
to be bought and sold. Adviser may use more than one broker-dealer in executing transactions for
its client. Some of these executing brokers may calculate commissions on a “dollar per ticket”
basis, whereas others may use a “cents per share” formula plus a somewhat smaller “dollars per
ticket” charge. The factors which Adviser considers in selecting any broker-dealer, and in
determining the reasonableness of its commissions, are price, skill in execution, level of service,
research, and financial responsibility. Although a broker-dealer chosen by Adviser may not charge
the lowest commission rates available, Adviser believes that the commission rates charged are fair
to its clients, when taking into consideration the factors listed above.
Adviser has the authority to select the broker and agree to that broker’s commission rates, but BFA
5
does so after negotiating for the lowest execution rates it can obtain from that broker. BFA
reviews, to the extent practicable, and at least annually, the commission rates charged by other
comparable, qualified brokers to determine that the brokerage commissions being paid by BFA’s
clients remain competitive with other rates.
BFA has no soft dollar arrangements with any firms and therefore no such costs need to be passed
on to clients.
REVIEW OF MANAGED ACCOUNTS
Customer accounts and the individual investments in customer accounts which are managed by
BFA are regularly monitored. These reviews are conducted based upon asset allocations, stock
market sector weightings, fundamental factors, and other valuation methods, by Mr. Morrison. Mr.
Jamie Haire, as the Chief Compliance Officer, also has the specific responsibility of reviewing the
holdings and transaction reports regarding the accounts of Adviser’s employees. The reviews of
these holdings are done when each employee is first hired, and thereafter, on a quarterly and annual
basis.
BFA’s managed clients are provided with monthly written statements from the custodian. The
statements include an inventory and valuation of the investments in the account.
CLIENT REFERRALS AND OTHER COMPENSATION
BFA does not currently receive referral fees or other compensation from any third party for client
referrals.
CUSTODY
BFA does not maintain custody of client assets. All client assets are custodied with nationally
recognized, SEC-registered and FINRA member broker-dealer/custodians.
Clients receive monthly statements from the broker dealer, or other qualified custodian, that holds
and maintains client’s investment assets. BFA urges its clients to carefully review such statements
and compare such official custodial records to the account statements that BFA provides to its
clients. BFA’s statements may sometimes vary from custodial statements based on respective
accounting procedures, reporting dates, or valuation methodologies of certain securities, but all
inconsistencies should be checked through carefully.
INVESTMENT DISCRETION
BFA usually receives discretionary authority from clients for accounts which it intends to manage
at the outset of an advisory relationship. This authority empowers BFA to select the identity and
amount of securities to be bought or sold. In all cases, however, BFA’s discretion will be exercised
in a manner consistent with the stated investment objectives for the particular managed client
6
account. All consulting services to Plans shall be provided by BFA on a non-discretionary basis.
When selecting securities and determining amounts, BFA observes the managed client’s
investment limitations and restrictions. Any specific investment guidelines and restrictions
required by a client must be provided to BFA in writing.
VOTING CLIENT SECURITIES
BFA will not vote a client’s securities without the client’s prior authorization or a valid signed
proxy. A managed account client has the option to have BFA vote its securities and may authorize
BFA to do so. BFA has adopted and follows proxy voting policies and procedures in compliance
with its responsibilities under Rule 206(4).
BFA votes client proxies in the manner it considers to best benefit, and in the best interests of, the
client. This means it votes in the way BFA believes is most likely to protect the client and
maximize the client’s return. Generally, BFA will vote its proxies in accordance with the
recommendation of company management but in those instances where BFA decides it should
oppose management’s recommendation in the best interests of the client, it will cast the votes
accordingly and document its reasons.
In the event that there is ever a conflict of interest between BFA, and the issue being voted, BFA
will notify the client and request direct instructions from the client as to how to cast the vote.
Clients may obtain a copy of BFA’s complete proxy voting policies and procedures upon request
from Mr. Jamie Haire. Clients may also obtain information from BFA about how BFA voted any
proxies on their behalf.
FINANCIAL INFORMATION
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about their financial condition depending on how they operate their
business.
Please be advised that BFA has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.
7
T. Brett Haire, Jr.
BRAVE Family Advisors
47 Summit Avenue,
908-522-8822
March 2025
This Brochure Supplement provides information about T. Brett Haire, Jr. that supplements
the BRAVE Family Advisors Brochure. You should have received a copy of that Brochure.
Please contact Mr. Jamie Haire if you did not receive BRAVE Family Advisors Brochure
or if you have any questions about the contents of this supplement.
Educational Background and Business Experience
Thomas Brett Haire, Jr. was born in 1949 and received a B.S. degree in Business from University
of Maryland, College Park, Maryland. Since 1992 he has been, and continues to be, a principal of
BRAVE Family Advisors and serves as its Chairman and Secretary-Treasurer.
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. No information is applicable to this Item.
Other Business Activities
Mr. Brett Haire is not actively engaged in any investment-related business or occupation, other
than his activities on behalf of BFA, as described in BFA’s Brochure.
Additional Compensation
Mr. Brett Haire does not receive any additional compensation for providing advisory services,
other than his salary and bonus compensation for new client referrals.
Supervision
Mr. Jamie Haire is BFA’s chief compliance officer and to that end he reviews and administers all
compliance procedures. Since BFA has only four principals, they work closely together and each
serves, in effect, to supervise the others regarding the investment advice given to clients.
Scott Anthony Morrison
BRAVE Family Advisors
3913 Main Road, Tiverton, Rhode Island 02878
917-392-9268
March 2025
This Brochure Supplement provides information about Scott Anthony Morrison that
supplements the BRAVE Family Advisors Brochure. You should have received a copy of
that Brochure. Please contact Mr. Jamie Haire if you did not receive BRAVE Family
Advisors Brochure or if you have any questions about the contents of this supplement.
Educational Background and Business Experience
Scott Anthony Morrison was born in 1965 and received a BA degree in Economics and
Mathematics from Bennington College, Bennington, Vermont. Since February 2016 he has been,
and continues to be, a principal of BRAVE Family Advisors and serves as its President.
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. No information is applicable to this Item.
Other Business Activities
Mr. Morrison is not actively engaged in any investment-related business or occupation, other than
his activities on behalf of BFA, as described in BFA’s Brochure.
Additional Compensation
Mr. Morrison does not receive any additional compensation for providing advisory services, other
than his salary.
Supervision
Mr. Jamie Haire is BFA’s chief compliance officer and to that end he reviews and administers all
compliance procedures. Since BFA has only four principals, they work closely together and each
serve, in effect, to supervise the others regarding the investment advice given to clients.
James Patrick Haire
BRAVE Family Advisors
47 Summit Avenue,
908-522-8822
March 2025
This Brochure Supplement provides information about James Patrick Haire that
supplements the BRAVE Family Advisors Brochure. You should have received a copy of
that Brochure. Please contact Mr. Jamie Haire if you did not receive BRAVE Family
Advisors Brochure or if you have any questions about the contents of this supplement.
Educational Background and Business Experience
James Patrick Haire was born in 1978 and received a BA degree in History from Middlebury
College in Middlebury, Vermont. Since January 2021 he has become a principal of BRAVE
Family Advisors and serves as its Chief Operating Officer, Chief Financial Officer and Chief
Compliance Officer.
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. No information is applicable to this Item.
Other Business Activities
Mr. Jamie Haire is not actively engaged in any investment-related business or occupation, other
than his activities on behalf of BFA, as described in BFA’s Brochure.
Additional Compensation
Mr. Jamie Haire does not receive any additional compensation for providing advisory services,
other than his salary and bonus compensation for new client referrals.
Supervision
Mr. Jamie Haire is BFA’s chief compliance officer and to that end he reviews and administers all
compliance procedures. Since BFA has only four principals, they work closely together and each
serves, in effect, to supervise the others regarding the investment advice given to clients.