BRIGHTHAVEN FINANCIAL ADVISORS PART 2A FIRM BROCHURE

Firm Brochure (Part 2A of Form ADV) BrightHaven Financial Advisors, LLC. 200 Russell Street, Suite 300 Huntsville, AL 35801 Telephone: 256-763-7386 Email: phillip@brighthavenadvisors.com This brochure provides you with information about the qualifications, business practices and nature of advisory services of BrightHaven Financial Advisors LLC, all of which should be considered before becoming an advisory client of our Firm. Please contact Phillip A. Gibson, Chief Compliance Officer, if you have any questions about this narrative brochure. 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. Registration does not imply a certain level of skill or training. Additional information about our Firm is available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number known as a CRD number. Our Firm’s CRD number is 318730. September 25, 2026  Item 2 Material Changes This Firm Brochure provides you with a summary of BrightHaven Financial Advisors LLC (“BrightHaven” or “Firm”) advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. Material Changes: Should a material change in our operations occur, depending on its nature, we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business. Material Change since last filed ADV amendment on August 17, 2026: • BrightHaven Financial Advisors, LLC is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level. Full Brochure Available We will provide you with a full version of the Firm Brochure as necessary based on changes or new information, at any time, without charge. Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at 256-763-7386 or by email at: phillip@brighthavenadvisors.com 1  Item 3 Table of Contents Item 2 Material Changes ................................................................................................................................................ 2 Item 3 Table of Contents ............................................................................................................................................... 2 Item 4 Advisory Business .............................................................................................................................................. 3 Item 5 Fees and Compensation ................................................................................................................................... 5 Item 6 Performance-Based Fees & Side-by-Side Management ...................................................................... 9 Item 7 Types of Clients ................................................................................................................................................... 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9 Item 9 Disciplinary Information .............................................................................................................................. 12 Item 10 Other Financial Industry Activities and Affiliations .......................................................................... 12 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 12 Item 12 Brokerage Practices ........................................................................................................................................ 13 Item 13 Review of Accounts ......................................................................................................................................... 15 Item 14 Client Referrals and Other Compensation ............................................................................................ 15 Item 15 Custody ................................................................................................................................................................ 15 Item 16 Investment Discretion ................................................................................................................................... 16 Item 17 Voting Client Securities ................................................................................................................................. 16 Item 18 Financial Information .................................................................................................................................... 16 2  Item 4 Advisory Business FIRM DESCRIPTION BrightHaven Financial Advisors, LLC (“BrightHaven” or the “Firm”) is organized as an Alabama limited liability company. BrightHaven’s current business activities consist of providing investment advisory services to individuals, high net worth individuals, families, profit-sharing plans, trusts, estates, and small businesses in Alabama and other states (each referred to as a “Client”). Principal Owner: Phillip A. Gibson, the Firm’s Chief Executive Officer, and Chief Compliance Officer, wholly owns BrightHaven Financial Advisors, LLC. TYPES OF ADVISORY SERVICES Portfolio Management Portfolio Management is based on the individual objectives of each client portfolio and may or may not represent the overall objectives of the clients’ total investment assets. BrightHaven Financial Advisors recommends and employs various investment strategies. Portfolio Management accounts are designed on a discretionary basis by one of BrightHaven’s Investment Advisor Representatives. BrightHaven assists each Portfolio Management client in formulating investment objectives and manages the account within established guidelines regarding, among other matters, diversification and designation of securities that are purchased. Most accounts are managed on a discretionary basis, meaning that the advisor has discretion over what securities to buy and sell. This trading discretion and any limitations on it will be set forth in the client agreement. The services provided are the same regardless of the account structure selected. Depending on the client’s investment objectives, the advisor may manage and provide advice on mutual funds, stocks, bonds, exchange traded funds (ETFs), LPs, and options. Alternative investments may be recommended to qualified investors based on the client’s objectives and risk tolerance. Alternative investments could include real estate, Private Equity, Hedge Funds, Commodities, etc. Alternative Investments can provide diversification benefits to traditional portfolios of stocks and bonds. Each Portfolio Management Account client has the ability to impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of 3  securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or BrightHaven believes that the instructions are inappropriate for the client, BrightHaven will notify the client that, unless the instructions are modified, it will cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict BrightHaven of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Portfolio Management accounts may be custodied at Charles Schwab & Co. (“Schwab”) or Fidelity. For these accounts, each portfolio is tailored to a client’s particular investment needs and circumstances. This includes discretionary investment management in accounts based on the client’s investment needs and a risk strategy (from conservative to aggressive), which is selected in conjunction with the client and incorporated into the account agreement. Under the terms of the agreement with the client, the BrightHaven will: • Formulate an Investment Policy Statement for the client that may include: • An asset allocation policy; and/or • A diversification recommendation among asset classes and styles; • Rebalance the investor portfolio as deemed necessary by BrightHaven. • Report and review investment results from time to time. (See Item 13) • Recommend changes in the client’s investments, investment strategy or objectives. FINANCIAL PLANNING Financial Planning BrightHaven offers financial planning services both on a standalone basis and as an integrated component of its portfolio management service. Clients who engage BrightHaven for portfolio management receive financial planning as part of that service at no additional cost; clients who wish to receive financial planning without ongoing portfolio management may engage BrightHaven for this service independently. Financial planning advice is delivered in the form of a written financial plan tailored to help the client work toward their stated financial goals and objectives. Depending on the client's needs and circumstances, the plan may address any or all of the following areas: • Personal: Family records, budgeting, personal liability, estate information, and financial goals 4  • Tax and Cash Flow: Analysis of income tax spending and planning for past and future years • Death and Disability: Cash needs at death, income needs of surviving dependents, and estate planning • Retirement: Strategies and investment plans designed to help the client work toward their • retirement goals Investments: Analysis of investment alternatives and their effect on the client's portfolio To develop the plan, BrightHaven gathers information through in-depth personal interviews and a review of the client's personal financial information. This includes the client's current financial status, future requirements, risk tolerance, and goals. Based on this review, BrightHaven prepares a written plan intended to help the client work toward their stated objectives. Clients are encouraged to review the plan with their tax accountants, attorneys, and other professional service providers as appropriate. Clients are under no obligation to engage BrightHaven to implement any recommendations contained in a financial plan. Implementation of any or all recommendations is solely at the client's discretion and may be carried out through BrightHaven or through another investment adviser or professional of the client's choosing. ASSETS UNDER MANAGEMENT As of August 17, 2026, BrightHaven had $106,566,352 in discretionary assets and $0 in non- discretionary regulatory assets under management (RAUM), which means securities portfolios for which BrightHaven provides continuous and regular supervisory or management services. Item 5 Fees and Compensation PORTFOLIO MANAGEMENT FEES AND BILLING The specific manner in which fees are charged by BrightHaven for Portfolio Management accounts is established in the client’s written agreement. Fees are based on a percentage of assets under management and calculated at an annual rate and billed in advance on a monthly or quarterly basis. Fees are based on the assets in the account per the schedule below and in some instances, may be negotiated. Account Balances $0 - $500,000 $500,001 - $2,500,000 $2,500,001 - $4,000,000 $4,000,001+ Annual Fee 1.50% 1.35% 1.20% 1.00% Billing starts in full one business day after the client’s account is accepted and opened with the 5  minimum account balance of $500,000 and will be based on the asset value of the account on that date. Advisory account fees will be billed either on quarterly or monthly basis. The initial fee will be prorated according to the number of days remaining in the calendar quarter or month. Thereafter, the fee will be calculated by multiplying the account balance of the assets in the account as of the last trading day of each calendar quarter by the annual fee and then dividing that result by 4, which represents each quarter. If the account is billed monthly, the annual fee is divided by 12 which represents each month. The account value will not be reduced by any margin or other indebtedness of the client with respect to such securities or other investments. Fees will not be adjusted or pro-rated for additions to or withdrawals from the account during the calendar quarter or month, other than a complete withdrawal in connection with a termination of the Account Agreement. All advisory contracts will specify how fees are to be billed. Generally, fees are paid in advance and the initial fee payment is calculated as starting on the date the client’s account is accepted and opened by the firm and will be based on the asset value of the account on that date. Fees will not be adjusted or pro-rated for additions to or withdrawals from the account during the calendar quarter. The total annual fee rate will not exceed industry standard rate of 2.00%. FINANCIAL PLANNING FEES BrightHaven provides financial planning services in two ways: (1) as a component of its portfolio management service, included at no separate or additional charge to portfolio management clients, and (2) as a standalone engagement for clients who wish to receive financial planning without also engaging BrightHaven for portfolio management. The fees described below apply only to clients engaging BrightHaven for standalone financial planning or consulting services; clients receiving financial planning as part of their portfolio management relationship do not pay these fees separately, as the cost is incorporated into the portfolio management fee described elsewhere in this Brochure. STANDALONE FINANCIAL PLANNING — FIXED FEES For clients engaging BrightHaven for standalone financial planning, the Firm’s services typically begin with a financial planning engagement so that each client has a foundation: a personalized plan that includes stated goals and objectives. This service is offered on a fixed- fee basis ranging from $500 to $800 per plan, depending on the client's project, advisor selected, financial profile, and services to be rendered. BrightHaven does not require a retainer, and the estimated financial planning or consulting fee we quote is due upon engagement. Financial planning and consulting services may be ongoing and are indicated in the advisory agreement. All fees are non-negotiable and due upon engagement; however, we will not bill an amount above $500.00 six (6) months or more in advance of delivery of the financial plan to the client. In the event of early termination, the client will be billed for hours worked at a rate of $250.00 per hour, and the client will be 6  refunded the difference. STANDALONE FINANCIAL PLANNING — HOURLY FEE On a limited basis, BrightHaven may be engaged for standalone financial planning and investment consultation services on an hourly-fee basis. This option is typically used for clients requiring a narrowly focused plan, incidental advice, or an abbreviated review session. The hourly rate is $250 per hour, billed in 15-minute increments, with any partial increment treated as a whole increment. Prior to engagement, the client will receive an estimate of the overall cost based on their requirements and the time involved. The fee is due at completion of the engagement. In the event of early termination by the client, fees for hours already worked will be due. Fees for standalone planning services and ongoing support take into consideration factors such as the complexity of the client's financial profile; the time involved in developing the plan and assisting with its execution; the assets comprising the client's overall portfolio; and the number of individual accounts comprising the portfolio. BrightHaven is not compensated on the basis of a share of capital gains upon, or capital appreciation of, the funds or any portion of the funds of the client. OTHER FEES AND EXPENSES In addition to the advisory fees paid to BrightHaven, clients can also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions. These additional charges include securities brokerage commissions, transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses, 12(b)-1 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. The mutual funds BrightHaven could purchase or recommend offer a variety of share classes, including some that do not charge 12(b)-1 fees and are, therefore, less expensive. Some mutual funds within this program pay 12(b)-1 service fees (normally 0.25% per year) to the Custodian. These fees will be disclosed upon request of a client and are available in the applicable mutual fund ‘s prospectus. Retirement Plan Sponsor Consulting Services. Non-Discretionary Retirement Plan Sponsor Consulting Services. In addition to providing investment advisory services to retirement plan participants and plan sponsors, BrightHaven provides non-discretionary investment consulting services to plan sponsors of profit sharing and 401(k) plans under Section 3(21) of ERISA. As a 7  Section 3(21) investment adviser, or non-discretionary adviser, BrightHaven provides the plan sponsor with non-binding investment recommendations regarding the fund options available to plan participants. In providing these services, BrightHaven does not exercise investment discretion, management, or authority over plan assets; does not maintain custody or control over client assets; does not undertake responsibility for execution of trades or administration of the plan; and is not otherwise responsible for valuation, recordkeeping, or proxy voting. The plan sponsor is ultimately required to exercise its own discretion to act upon the investment recommendations provided by BrightHaven, with participants responsible for any individual investment selections made under the plan. Discretionary Retirement Plan Services. BrightHaven also offers discretionary investment management services to retirement plan sponsors under Section 3(38) of ERISA. Rather than developing proprietary investment models, BrightHaven, in its capacity as an "investment manager" under Section 3(38) of ERISA, utilizes model portfolio allocations and fund options made available through each plan's Recordkeeper platform. In exercising this authority with respect to plan assets, BrightHaven performs the following services on behalf of the plan and plan participants: (a) selects portfolio model allocations for retirement plans from the investment options and models available through the plan's Recordkeeper; (b) monitors and, where applicable, facilitates the rebalancing of the selected portfolio model allocations; (c) provides ongoing and continuous discretionary investment management to plan participants who elect to invest their plan account assets in one of the selected portfolio model allocations, based on the Participant Profile Information, including reallocation and rebalancing of participant plan accounts in accordance with the selected model allocations; (d) conducts initial and ongoing meetings with participants who elect to invest in one of the selected portfolio model allocations to obtain and update Participant Profile Information, including advising each participant about the asset management process and the available portfolio model allocations that are suitable investment strategies; and (e) allocates the assets of plan participants among the plan's approved investment alternatives, exercising discretionary investment management to diversify, reallocate, and rebalance participant account allocations in accordance with the selected portfolio model allocations. For a significant portion of its 3(38) engagements, BrightHaven utilizes model portfolios and investment management services provided by an independent third-party investment manager (such as Wilshire Associates or Morningstar Investment Management) that maintains an existing relationship with the plan's Recordkeeper and provides these services on behalf of the plan sponsor or BrightHaven, as applicable. BrightHaven does not receive commissions or other transaction-based compensation in connection with securities transactions placed for client accounts. ACCOUNT TERMINATION 8  Fees are automatically deducted from the account pursuant to the advisory agreement and are not billed separately to clients. Clients must maintain or deposit sufficient funds in the account to cover payment of all fees authorized by the contract. If there are not funds to cover the fees, then BrightHaven can liquidate assets to cover fees. The amount of the fee will be shown on the statement received by the Custodian. BrightHaven urges clients to carefully review such statements. Upon termination of an account, any prepaid, asset-based fees will be prorated according to the days the account was opened during the calendar month and excess fees will be re-bated to the client. All custodial termination and transfer fees assessed by Schwab or Fidelity if any, will be the responsibility of the client. In addition to the advisory fee, accounts will be assessed transaction fees. Transaction fees charged may be higher or lower than transaction charges or commissions charged by other broker-dealers. Each custodian will each receive a portion of the transaction fees paid by clients. Although transaction charges may be identified as commissions on trade confirmations, the Investment Adviser Representative does not receive any portion of these charges. Item 6 Performance-Based Fees & Side-by-Side Management PERFORMANCE-BASED FEES BrightHaven 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). Item 7 Types of Clients TYPES OF CLIENTS BrightHaven provides portfolio management services to individuals, corporations and business entities, pension and profit-sharing plans, charitable institutions, foundations, endowments, estates, trusts, and other U.S. and international institutions. The minimum account size is $500,000. BrightHaven has the discretion to waive the account minimum. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS BrightHaven employs a nimble, high-conviction equity strategy focused on a concentrated 9  portfolio of approximately 20–40 carefully selected companies that possess durable competitive advantages (“moats”), strong balance sheets, and consistent earnings growth. We combine rigorous fundamental research with technical analysis to identify attractive entry and exit points, while remaining adaptable to shifting market themes and maintaining diversification across sectors, geographies, and asset classes as appropriate for each client’s objectives and risk tolerance. The following is a summary of material risks related to each significant investment strategy or method of analysis BrightHaven uses. However, it is important to note that the summary of material risks below is not meant to be exhaustive or complete. Investing in securities involves a high degree of loss, including the risk that the entire amount invested may be lost. Clients should be prepared to bear such risk of loss. • Interest-rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: All investments present the risk of loss of principal – the risk that the value of securities is less than the price paid for the securities. In the past, volatile market conditions have had a dramatic effect on the value of securities. In addition, political conditions, terrorist attacks, other acts of violence or war, health epidemics or pandemics, natural hazards, and/or force majeure affect the operations and profitability of an issuer. Such events also could cause consumer confidence and spending to decrease or result in increased volatility in the U.S. and worldwide financial markets and economy. Any of these occurrences could have a significant impact on the operating results and revenues of an issuer. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Therefore, even when the value of a security is greater than the price paid, there is the risk that the appreciation will be less than inflation. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a 10  steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations could result in bankruptcy and/or a declining market value. • Foreign Security Risk: Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks generally are greater with investments in developing companies. • Cybersecurity Risk: The computer systems, networks and devices used by FSAM and our service providers to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of mutual funds, ETFs and other securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity 11  breaches in the future. Item 9 Disciplinary Information BrightHaven is required to disclose whether there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of BrightHaven’s advisory business or the integrity of its management. BrightHaven, nor any of its principals, or employees have been involved in any legal or disciplinary proceedings related to past or present investment advisory clients. Item 10 Other Financial Industry Activities and Affiliations Some BrightHaven investment adviser representatives are also insurance agents of the Gibson Agency Group, Inc. in Huntsville, AL, which is an independent insurance agency specializing in personal insurance such as car, homeowners, and life insurance. BrightHaven is affiliated with the Gibson Agency Group through ownership or control of Phillip A. Gibson. Phillip A. Gibson is the owner and an insurance agent for Gibson Agency Group. When applicable, life, health, long term care insurance, are offered through the Gibson Agency Group, Inc. All related compensation is separate from advisory services. This arrangement poses a conflict of interest to the extent that there is a financial incentive to recommend insurance products that result in commissions, or other payments. BrightHaven is dedicated to acting in clients’ best interests based on fiduciary principles. Clients are under no obligation to purchase any recommended insurance products. Phillip Gibson is also the sole owner of Phillip A Gibson, LLC., which is a private law practice where he spends approximately 1-3 hours per week devoted to this activity. BrightHaven is affiliated with the private law practice Phillip A. Gibson, LLC. through ownership or control of Phillip A. Gibson. All related compensation is separate from advisory services. This arrangement poses a conflict of interest to the extent that there is a financial incentive to recommend the law services of Mr. Gibson where he may collect other payments for services. Clients are under no obligation to utilize the law services of Mr. Gibson. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading BrightHaven has adopted a Code of Ethics (the “Code”) for all supervised persons of BrightHaven describing its high standard of business conduct, and fiduciary duty to its clients. The Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of 12  significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at BrightHaven must acknowledge the terms of the Code annually, or as amended. BrightHaven employees, including Investment Advisor Representatives, may personally buy or sell securities that are recommended to clients. The Code is designed to assure that these personal securities transactions, activities, and outside interests of BrightHaven’s employees will not interfere with (i) making decisions in the best interest of BrightHaven clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of BrightHaven’s clients. In addition, the Code requires pre-approval of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Employee trading is continually monitored under the Code to reasonably prevent conflicts of interest between BrightHaven and its clients. A copy of BrightHaven’s Code is available to our advisory clients and prospective clients. You may request a copy by emailing Phillip A. Gibson, Chief Compliance Officer, phillip@brighthavenadvisors.com. Item 12 Brokerage Practices SELECTION AND RECOMMENDATION BrightHaven generally recommends that investment management accounts be maintained at Fidelity or Schwab. Prior to engaging BrightHaven to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with BrightHaven setting forth the terms and conditions under which BrightHaven shall manage the client’s assets, and a separate custodial/clearing agreement with each designated broker dealer/ custodian. Factors that BrightHaven considers in recommending Fidelity or Schwab include historical relationship with BrightHaven, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by BrightHaven’s clients shall comply with BrightHaven’s duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to affect the same transaction where BrightHaven determines, in good faith, that the commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration 13  the full range of a broker-dealer’s services, including, but not limited to, the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although BrightHaven will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, BrightHaven’s investment management fee. BrightHaven’s best execution responsibility is qualified if securities that it purchases for client accounts are mutual funds that trade at net asset value as determined at the daily market close. Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, BrightHaven may receive from Fidelity or Schwab without cost (and/or at a discount) support services and/or products, certain of which assist the BrightHaven to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by BrightHaven may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by BrightHaven in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received may assist BrightHaven in managing and administering client accounts. Others do not directly provide such assistance but rather assist BrightHaven to manage and further develop its business enterprise. BrightHaven’s clients do not pay more for investment transactions effected and/or assets maintained at, Fidelity or Schwab as a result of this arrangement. There is no corresponding commitment made by BrightHaven to Fidelity, Schwab, or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as a result of the above arrangement. Clients can benefit when trades are aggregated to obtain volume discounts on execution costs. Trade aggregation refers to the practice of combining orders for execution. When consistent with the duty to obtain best execution, multiple client transactions will be aggregated into a single order in order to obtain the best price for clients. In such circumstances, the accounts will share commission costs equally and receive securities at a total average price. BrightHaven 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 on the order. Clients can benefit when trades are aggregated to obtain volume discounts on execution costs. 14  Trade aggregation refers to the practice of combining orders for execution. When consistent with the duty to obtain best execution, multiple client transactions will be aggregated into a single order in order to obtain the best price for clients. In such circumstances, the accounts will share commission costs equally and receive securities at a total average price. BrightHaven 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 on the order. Item 13 Review of Accounts While the underlying securities within Portfolio Management accounts are continually monitored, these accounts are reviewed no less than annually. Accounts are reviewed by advisors in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances or the market, political, or economic environment. In addition to the monthly statements and confirmations of transactions that clients receive from their custodian, BrightHaven will provide online access to account performance, balances, and holdings. Item 14 Client Referrals and Other Compensation ECONOMIC BENEFITS FROM OTHERS BrightHaven does not receive an economic benefit from anyone other than the client for providing investment advice and other advisory services. BrightHaven does not compensate for client referrals. Item 15 Custody CUSTODY OF ASSETS BrightHaven has limited custody of client funds and securities due to the ability to deduct advisory fees from accounts. In accordance with custody rules, BrightHaven will ensure that a qualified custodian maintains the account and that clients receive a quarterly account statement from the qualified custodian. Clients should receive statements at least quarterly from Custodians or other selected qualified custodian that holds and maintains client’s investment assets. BrightHaven urges clients to carefully review such statements and compare the official custodial records to the account statements that BrightHaven provides. BrightHaven statements may vary from custodial 15  statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 Investment Discretion BrightHaven may act in a discretionary capacity. If discretionary authority is granted to select the identity and number of securities to be bought or sold, clients must authorize such discretion in writing in the advisory agreement. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives for the client account. When selecting securities and determining amounts, BrightHaven observes the investment policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to BrightHaven in writing. Item 17 Voting Client Securities BrightHaven does not vote proxies for Clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients should contact their Investment Advisor Representative if they have any questions and/or to obtain this information. Clients will receive their proxies directly from their custodian or transfer agent. Item 18 Financial Information Under no circumstances does BrightHaven require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, BrightHaven is not required to include a financial statement. As an advisory firm that maintains discretionary authority for client accounts, BrightHaven is also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Currently, there are no such financial conditions that exist. BrightHaven has not been the subject of a bankruptcy petition at any time during the past ten years. 16