Overview
Assets Under Management: $175 million
Headquarters: BELLEVUE, WA
High-Net-Worth Clients: 28
Average Client Assets: $6 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (ADV PART 2A- HARA CAPITAL LLC)
| 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: 28
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 92.65
Average High-Net-Worth Client Assets: $6 million
Total Client Accounts: 110
Discretionary Accounts: 109
Non-Discretionary Accounts: 1
Regulatory Filings
CRD Number: 315108
Last Filing Date: 2024-05-08 00:00:00
Website: https://haracapital.com
Form ADV Documents
Primary Brochure: ADV PART 2A- HARA CAPITAL LLC (2025-03-27)
View Document Text
Form ADV – Part 2A
Version date: March 26, 2025
Hara Capital LLC
13555 SE 36th St.,
Ste 100
Bellevue, WA 98006
(425) 522-2322
rob@haracapital.com
www.haracapital.com
This brochure provides information about the qualifications and business practices of Hara Capital LLC.
If you have any questions about the contents of this brochure, please contact us at (425) 522-2322 or by
email at: rob@haracapital.com. 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. Registration
as an investment adviser does not imply a certain level of skill or training.
Additional information about Hara Capital LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Hara Capital LLC’s CRD number is: 315108.
Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Hara Capital LLC on
03/26/2024 are described below. Material changes relate to Hara Capital LLC’s policies, practices or conflicts of
interests.
• Financial planning may be provided for clients in connection with portfolio management services.
However, financial planning is not offered as a stand-alone service, and Hara does not charge any
additional fees when providing financial planning. (Item 4)
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................2
Item 5: Fees and Compensation .............................................................................................................................2
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................3
Item 7: Types of Clients ..........................................................................................................................................3
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................4
Item 9: Disciplinary Information ...........................................................................................................................5
Item 10: Other Financial Industry Activities and Affiliations ...........................................................................5
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................6
Item 12: Brokerage Practices ..................................................................................................................................6
Item 13: Review of Accounts ..................................................................................................................................8
Item 14: Client Referrals and Other Compensation ............................................................................................8
Item 15: Custody ......................................................................................................................................................9
Item 16: Investment Discretion ..............................................................................................................................9
Item 17: Voting Client Securities (Proxy Voting) ................................................................................................9
Item 18: Financial Information ...............................................................................................................................9
Item 4: Advisory Business
Hara Capital LLC (“Hara”, or the “Firm”) is a Limited Liability Company organized in the State of
Washington. The Firm was formed in 2021 and became registered as an investment adviser in
September 2021, and the principal owner is Robert J. Dainard.
Customized portfolio management
Hara offers customized portfolio and asset management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client on both a discretionary and non-
discretionary basis. This management is ongoing alongside centrally managed risk, where the
entirety of a client’s wealth is considered in regard to levels of exposure to various factors such
as inflation/deflation and pro-cyclical investment risks, among others. Hara generally constructs
portfolios using liquid assets such equities, ETFs, fixed income securities, and non-US securities.
When and where appropriate, Hara may also recommend and advise allocation to Illiquid
securities such as private placements, or other securities that help diversify client portfolios. The
investments of each client are measured with respect to each client’s individual risk tolerance
levels and time horizon. Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs.
Financial planning may be provided for clients in connection with portfolio management services.
However, financial planning is not offered as a stand-alone service, and Hara does not charge any
additional fees when providing financial planning.
Assets Under Management
As of December 31st, 2024, Hara capital has $166,863,115 in discretionary assets under
Management and $1,282,394 in non-discretionary assets under management.
Item 5: Fees and Compensation
Fees Based on Assets Under Management
Hara is a fee-only advisory firm, meaning it does not receive commissions. Hara believes this
method of compensation minimizes conflicts of interest.
For all assets, Hara will charge up to 1% of assets. These fees are generally negotiable based on
client specific factors, and the final fee schedule will be memorialized in the client’s advisory
agreement. Clients may terminate the agreement without penalty upon written notice.
Hara uses the balance in the client’s account on the last day of the billing period for purposes of
determining the market value of the assets upon which the advisory fee is based.
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For partial billing periods, the fees will be prorated based upon the number of days the account
was open during a billing period.
In computing the market value of any investment of the Account, the securities in the Account
listed on a national securities exchange or otherwise subject to current last-sale reporting shall
be valued at the amount reported on the statement that Client receives from the Custodian. Such
securities which are not traded nor subject to last-sale reporting shall be valued at the latest
available bid price reflected by quotations furnished to Hara by such sources as it may deem
appropriate. Any other security shall be valued in such manner as determined by Hara and Client,
consistent with Hara’s fiduciary duty, to reflect the security’s fair market value. Client may dispute
valuations with Hara if Client disagrees, at which point Client and Hara will discuss the valuation
in order to promptly resolve the dispute.
Neither Hara nor its supervised persons accept any compensation for the sale of investment
products, including asset-based sales charges or service fees from the sale of mutual funds.
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with
client's written authorization on a quarterly basis. Fees are paid in arrears.
Hara collects its fees in arrears. It does not collect any fees in advance.
Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees,
mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by Hara. Please see Item 12 of this brochure regarding broker-dealer/custodian.
Item 6: Performance-Based Fees and Side-By-Side Management
Hara does not accept performance-based fees or other fees based on a share of capital gains on
or capital appreciation of the assets of a client.
Item 7: Types of Clients
Hara provides advisory services to the following types of clients:
Individuals, including High-Net-Worth Individuals
Trusts and estates
-
-
- Corporations or Business Entities including Charitable Foundations
Hara generally requires a minimum account size of $5 million. Minimum account size may be
waived for certain clients at Hara’s discretion.
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Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
Methods of Analysis and Investment Strategies
Hara’s Investment philosophy is predicated on the core belief that investment returns are
intrinsically linked to the cash flows they ultimately supply to investors and the quickest way to
permanently impair capital is to overpay for those cash flows.
With this in mind, Hara has developed a framework that is fundamental in nature and aimed at
constructing long-term oriented portfolios that are well diversified to various economic regimes.
Imbedded in the fundamental nature of this framework is a Quality-Value approach to security
selection that breaks down an investment into Profit (ability to generate a return stream), Value
(the value of the assets available to build and sustain a return stream), and Risk (with a focus on
company structure and industry related risks).
Hara also uses Capital Cycle Analysis as it evaluates investment risks and opportunities. This
involves understanding how changes in the amount of capital employed within a particular
industry is likely to impact future returns and how the competitive position of a company is
affected by the changes in the supply side of an industry (rather than industry demand).
Portfolios built by Hara are implemented using equity and fixed income securities, among other
assets where appropriate and depending on the available opportunity set at any given time.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
Material Risks Involved
Past performance is not indicative of future results. Investing in securities involves a risk of loss
that you, as a client, should be prepared to bear.
Market Risk The price of any security, including stocks, bonds, ETFs, or mutual funds may drop in
reaction to tangible and intangible events and conditions that are caused by external factors
independent of any particular security’s individual merit or circumstance. This includes Political,
economic, or social changes that may trigger market events.
Equity Risk Prices of common stocks may fluctuate widely depending on industry conditions,
underlying economic health, changes in earnings or management and a host of other factors.
Mutual Funds and ETF Risk Investing in mutual funds & ETFs carries the risk of capital loss and
thus you may lose money investing in mutual funds. All funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. The
degree of liquidity can vary significantly from one fund to another and losses may be magnified if
no liquid market exists for the fund’s shares when attempting to sell them. Each fund has a unique
risk profile, detailed in its prospectus, offering circular, or similar material, which should be
considered carefully when making investment decisions.
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Fixed income investments generally pay a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt
securities, leveraged loans, high yield, and investment grade debt and structured products, such
as mortgage and other asset-backed securities. In general, the fixed income market is volatile and
fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and
vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income
securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both
issuers and counterparties. The risk of default on treasury inflation protected/inflation linked
bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a
potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed
income securities also include the general risk of non-U.S. investing described below.
Foreign Market Risk Non-U.S. securities present certain risks such as currency fluctuation,
political and economic change, social unrest, changes in government regulation, differences in
accounting and the lesser degree of accurate public information available.
Liquidity Risk Lack of a deep and active liquid market for a security may preclude the ability to
sell a security, partially or in its entirety, at an advantageous price. Reduced liquidity may have an
adverse impact on market price and the ability to sell particular securities when necessary to meet
cash needs or in response to a specific economic event, such as the deterioration of
creditworthiness of an issuer.
Inflation Risk Inflation causes the future value of one US Dollar to erode over time and reduces
the purchasing power of an investor. A material increase in the rate of inflation could cause some
security types, such as fixed income, to experience a decline in value as inflation generally leads
to higher interest rates.
The foregoing list of risk factors is not exclusive and does not include all factors related to general
investment, either with Hara Capital or in broader terms.
Item 9: Disciplinary Information
Hara is required to disclose all material facts regarding any legal or disciplinary events that would
be material to client’s evaluation of the firm. Neither Hara nor any supervised persons have any
applicable information to disclose in this item.
Item 10: Other Financial Industry Activities and Affiliations
Hara is required to disclose any outside financial services activities or affiliations. Neither Hara nor
any supervised persons have any applicable information to disclose in this item.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics
Hara has adopted a written Code of Ethics which applies to all personnel. The Code of Ethics is
intended to ensure that the firm's fiduciary responsibility to clients serves as the guiding principle
in all its activities. The code includes provisions regarding personal securities transactions, insider
trading, and general compliance with laws and regulations, among others.
Hara's Code of Ethics is available free upon request to any client or prospective client.
Investing Personal Money in the Same Securities as Clients
Hara personnel often invest their personal money in the same securities and in the same manner
that is recommended to clients. They believe that this creates an alignment of incentives when it
comes to the careful selection of investments. In doing so, this may provide an opportunity for
representatives of Hara to buy or sell the same securities before or after recommending the same
securities to clients resulting in representatives profiting off the recommendations they provide
to clients. Such transactions may create a conflict of interest.
Hara will always document any transactions that could be construed as conflicts of interest and
will never engage in trading that operates to the client’s disadvantage if representatives of Hara
buy or sell securities at or around the same time as clients. Representatives of Hara will not trade
ahead of client accounts for personal or related person accounts.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on Hara’s duty to seek “best execution,”
which is the obligation to seek execution of securities transactions for a client on the most
favorable terms for the client under the circumstances.
Hara may also consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral communication
with analysts, and other resources provided by the brokers that may aid in Hara's research efforts.
Clients will not necessarily pay the lowest commission or commission equivalent, as Hara weighs
the overall combination of factors in using a particular custodian. Hara will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
Hara will typically require clients to use Charles Schwab & Co., Inc. Advisor Services.
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Research and Other Soft-Dollar Benefits
By its receipt and use of research or certain brokerage services Hara may be considered to be
receiving “soft dollar” benefits from the brokers it utilizes. Hara, however, does not participate in
any formal soft dollar arrangements, earn soft dollar credits or pay specific additional brokerage
commissions for research or other types of soft dollar benefits. To the extent the receipt of
research or brokerage by Hara are deemed to be soft dollar benefits, such benefits fall within the
safe harbor of Section 28(e) of the Securities Exchange Act of 1934.
Brokerage and Custody Costs
Custodians used by Hara generally do not charge clients separate for custody services but are
compensated by charging commissions or other fees on trades that it executes or that settle into
their client accounts. Custodians are also compensated by earning interest on the uninvested
cash, on any margin balance maintained in accounts, and from other ancillary services. Most
trades no longer incur commissions or transaction fees, though there are exceptions. Custodians
disclose their fees and costs to clients, and Hara takes those costs into account when executing
transactions on clients behalf.
Brokerage and Custodian Recommendations
Hara recommends the use of Charles Schwab & Co as a custodian for clients. This
recommendation is based on each custodian’s ability to provide quality overall services to clients
at a competitive cost, including no trade commissions for trading equity securities and user-
friendly access to their online platforms. Hara has entered into an agreement with each custodian
which identifies services provided and the terms and conditions of such services. This may include
access to certain investment products, execution of securities transactions and custody services
that might otherwise require higher account minimums.
It is important to note that Hara receives certain additional benefits from the use of Charles
Schwab which presents a conflict of interest. The benefits offered by Charles Schwab include
access to educational content and events, technology and support (including technology that
substantially assists Hara in the administration of client accounts), compliance and/or legal
consulting, and publications and conferences on practice management.
Hara is independently owned and operated and not affiliated with Charles Schwab & Co., Inc.
Advisor Services.
Brokerage for Client Referrals
Hara receives no referrals from a broker-dealer or third party in exchange for using that broker-
dealer or third party.
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Aggregating (Block) Trading for Multiple Client Accounts
If Hara buys or sells the same securities on behalf of more than one client, then it may aggregate
or bunch such securities in a single transaction for multiple clients in order to seek more favorable
prices, lower brokerage commissions, or more efficient execution. In such case, Hara would place
an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all
clients; provided, however, that trades would be reviewed periodically to ensure that accounts
are not systematically disadvantaged by this policy. Hara would determine the appropriate
number of shares and select the appropriate brokers consistent with its duty to seek best
execution.
Hara seeks to provide investment decisions that are made in accordance with the fiduciary duties
owed to its accounts and without consideration of Hara’s economic, investment or other financial
interests. To meet its fiduciary obligations, Hara attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios, and accordingly, Hara’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another over time.
It is Hara’s policy to allocate investment opportunities and transactions it identifies as being
appropriate and prudent among its clients that is consistent with Hara’s fiduciary duty.
Item 13: Review of Accounts
All client accounts for Hara's advisory services provided on an ongoing basis are reviewed at least
quarterly by Robert Dainard, with regard to clients’ respective investment policies and risk
tolerance levels.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client of Hara's advisory services provided on an ongoing basis will receive a quarterly report
detailing the client’s account, including assets held and asset value, which report will come from
the custodian. Hara does not provide any separate written statements to the client.
Item 14: Client Referrals and Other Compensation
Except as described in Item 12: Brokerage Practices, Hara does not receive compensation for any
non-client activity nor does Hara compensate any non-advisory personnel for client referrals.
Hara does receive indirect benefits from Charles Schwab related to support services (platform &
technology access, research, etc.) that is not contingent upon Hara recommending any particular
advice or security for purchase.
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Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, Hara will be
deemed to have limited custody of client's assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction, and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
Hara provides discretionary and non-discretionary investment advisory services to clients. The
advisory contract established with each client sets forth the discretionary authority for trading.
Where investment discretion has been granted, Hara generally manages the client’s account and
makes investment decisions without consultation with the client as to when the securities are to
be bought or sold for the account, the total amount of the securities to be bought/sold, what
securities to buy or sell, or the price per share. In some instances, Hara’s discretionary authority
in making these determinations may be limited by conditions imposed by a client (in investment
guidelines or objectives, or client instructions otherwise provided to Hara).
Item 17: Voting Client Securities (Proxy Voting)
Hara generally votes proxies for Clients, though clients may retain the right to vote their own
proxies if they choose.
As a fiduciary, Hara has the responsibility to monitor corporate events and cast votes in the best
interest of clients. Accordingly, Hara has adopted written Proxy Voting Policies and Procedures
which are generally designed to support the ability of management to run the business in a
sustainable and cost-effective manner. All votes are cast considering relevant facts and
circumstances at the time of the vote.
Clients may request information on proxy voting including the Proxy Voting Policies and
Procedures by contacting Hara.
Item 18: Financial Information
Hara neither requires nor solicits prepayment of more than $1,200 in fees per client, six months
or more in advance and therefore does not need to include a balance sheet with this brochure.
Hara has not been the subject of a bankruptcy at any point in time.
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