HAVEN PRIVATE

ITEM 1 Cover Page DISCLOSURE BROCHURE THE INVESTMENT ADVISERS ACT OF 1940 RULE 203-1 Part 2A of Form ADV: Firm Brochure CORPORATE HEADQUARTERS Principal Office & Mailing Address 976 Lake Baldwin Lane Suite 201 Orlando, Florida 32814 SEC File #: 801-129272 Firm IARD/CRD #: 329012 Haven Private, LLC R E G I S T E R E D I N V E S T M E N T A D V I S O R Contact Information P: 321.329.8674 www.havenprivate.com B R O C H U R E D A T E D information about Haven Private, LLC This Disclosure Brochure provides information about the qualifications and business practices of Haven Private, LLC, which should be considered before becoming a client. You are welcome to contact us if you have any questions about the contents of this brochure – our contact information is listed to the right. Additional is also available on the SEC’s website at www.adviserinfo.sec.gov. 1 JANUARY 2026 The information contained in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Administrator. Furthermore, the term “registered investment advisor” is not intended to imply that Haven Private, LLC has attained a certain level of skill or training. © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com  DISCLOSURE BROCHURE I MATERIAL CHANGES T E M 2 There are no material changes to report. This Disclosure Brochure has been reviewed and is current as of the date indicated on the cover. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 2 of 25  DISCLOSURE BROCHURE I TABLE OF CONTENTS T E M 3 ITEM 1 Cover Page 1 ITEM 2 Material Changes 2 ITEM 3 Table of Contents 3 ITEM 4 Advisory Business 4 ITEM 5 Who We Are Assets Under Management What We Do Fees & Compensation 4 5 5 7 ITEM 6 Discovery Meeting Portfolio Management Fee Portfolio Monitoring Fee General Consulting Fee Performance-Based Fees & Side-By-Side Management 7 7 10 11 11 ITEM 7 Types of Clients 11 ITEM 8 Methods of Analysis, Investment Strategies & Risk of Loss 11 ITEM 9 Methods of Analysis Investment Strategies Managing Risk Disciplinary Information 11 13 14 16 ITEM 10 Other Financial Industry Activities & Affiliations 16 ITEM 11 Financial Industry Affiliations Insurance Company Activities Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 16 18 18 ITEM 12 Code of Ethics Client Transactions Personal Trading Brokerage Practices 18 19 20 20 ITEM 13 Custodial Services Aggregating Trade Orders Review of Accounts 20 21 21 ITEM 14 Portfolio Management Reviews Client Referrals & Other Compensation 21 22 ITEM 15 Referral Compensation Other Compensation (Indirect Benefit) Insurance Compensation Pooled Investment Vehicle Compensation Retirement Rollover Compensation Custody 22 22 22 22 23 23 ITEM 16 Management Fee Deduction Standing Letters of Authorization Investment Discretion 23 24 24 ITEM 17 Voting Client Securities 24 ITEM 18 Financial Information 25 Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 3 of 25  DISCLOSURE BROCHURE I ADVISORY BUSINESS T E M 4 Who We Are Haven Private, LLC1 (hereinafter referred to as “Haven Private”, “the Company”, “we”, “us” and “our”) is a fee-based2 registered investment advisor3, organized to offer private wealth management services4 designed to assist you, our client5, achieve the financial stability, security, and independence you desire. Owners The following persons control the Company: CRD# Name Title Marc R. Angle 5713710 Stacey L. Cole 7223460 Johnny M. Gibson 4054687 Paul (Judd) Hershiser 2311230 Managing Member of Elevate IV, LLC, owner of Haven Private, LLC. Serving as a Member & Chief Executive Officer of Haven Private, LLC. Managing Member of Elevate IV, LLC, owner of Haven Private, LLC. Serving as a Member & Chief Compliance Officer of Haven Private, LLC. Managing Member of Elevate IV, LLC, owner of Haven Private, LLC. Serving as a Member & Chief Investment Officer of Haven Private, LLC. Managing Member of OLH Capital, LLC, owner of Haven Private, LLC. Serving as a Member & Chief Operations Officer of Haven Private, LLC. Our Mission Our mission is to provide customized advice and personalized services to you and your family. We want to be that trusted confidant you reach for, to come alongside and guide you with your financial and investment decisions as you pursue a better lifestyle focused on addressing today’s needs, while building tomorrow’s dreams, and preparing the foundation for a sound retirement and lasting legacy for future generations. 1 Haven Private, beginning in March of 2022, became the d/b/a name for AlphaQ Advisors, LLC that was organized in May of 2006. Haven Private was spun-off from AlphaQ as a separate Limited Liability Company in 2023, to establish Haven Private as a separate advisory firm. 2 As a “fee-based” investment advisor, the compensation we receive can include sales commissions in addition to the compensation paid by you, our client, for the portfolio management services we provide. See Item 10, “Other Financial Industry Activities & Affiliations” for disclosure on these services. 3 The term “registered investment advisor” is not intended to imply that Haven Private, LLC has attained a certain level of skill or training. It is used strictly to reference the fact that Haven Private, LLC is “Registered” as an “Investment Advisor” with the United States Securities & Exchange Commission and “Notice Filed” with such other state regulatory agencies that may have limited regulatory jurisdiction over our business practices. 4 Haven Private, LLC is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any private wealth management services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). 5 A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small business, a trust, a guardianship, an estate, a retirement plan, or any other type of entity to which we choose to give investment advice. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 4 of 25  DISCLOSURE BROCHURE We will do our best to keep you focused on where you want to go, offer advice on how best to get there, and continually remind you of the importance of maintaining a disciplined investment approach to achieve your financial goals. Assets Under Management As of December 31, 2025, our assets under management totaled: Discretionary Accounts ....................................................... $428,078,706 We do not offer non-discretionary asset management services. What We Do We provide private wealth management solutions designed to help you maximize wealth, maintain investment expectations, and manage risk. We will guide you and your family through your respective wealth journey, assisting you to manage your family balance sheet6 with fiscally responsible decisions and disciplined economic choices. Regardless of where you are in your wealth journey, focus of private wealth management begins with identifying your standards of living and quality of lifestyle expectations. We will accomplish this through an initial Discovery Meeting where we will review the financial information we requested for discussion. Together, questions will be asked, information shared, and an evaluation made as to whether we should move to the next step. During the meeting, we will: v Learn about your core values and guiding principles. v Seek to understand your financial concerns and how you have been addressing them. v Discover your financial objectives and what success looks like for you. v Create an internal profile consisting of your current income and expenses, assets, career objectives, investment goals, risk tolerance and investment time horizon, targeted rate of return, and prior investment experience, along with personal information about your relationships, your values, and interests. Moving forward from the Discovery Meeting, should you engage us for our wealth management services, we will begin defining your objectives, goals, and expectations to guide us in the development of, at minimum, an Investment Policy Statement (“IPS”) that defines your investment parameters and what asset mix is most suitable for your unique investment expectations and risk tolerance. Our services include: Portfolio Management We will create and manage a diversified portfolio, allocating your assets among various investments considering your stated investment objectives. Our management strategies are not limited to any specific product or service; however, the majority of our portfolio allocations will utilize a mix of equity (“stock”) positions, Investment Company (“mutual fund”) products, Exchange-Traded Funds (“ETFs”), fixed-income/debt (“bond”) instruments, real estate funds that include Real Estate Investment Trusts (“REITs”), and cash/cash equivalent securities to meet your investment objectives7. Information regarding our 6 We define the balance sheet as the assets we manage as well as assets that might be managed elsewhere, such as: business ventures and associated real estate; personal assets such as collections; titling of these assets; charitable and philanthropic ventures; and the human capital including educating subsequent generations of the family on financial matters. 7 You may, at any time, impose restrictions in writing on the securities we may recommend (i.e., limit the types/amounts of particular securities purchased for your account, etc.). Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 5 of 25  DISCLOSURE BROCHURE management fee structure is disclosed under “Portfolio Management Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” Portfolio Monitoring As part of our wealth management services, we may recommend you use separate, independent sub-advisors or third-party money managers (“Independent Managers”) to manage all or a portion of your investment portfolio. The Independent Managers we introduce have developed a defined management process and strategy for their investment portfolios. We are not involved in the day-to-day buy/sell decision for your assets managed by these Independent Managers. If your investment parameters and/or goals change or the Independent Manager you have selected is not performing to expectations, we can recommend changing the Independent Manager but may not be able to dictate changes to their investment strategy. The Independent Manager we recommend manage your portfolio will implement an investment strategy that correlates best with your Investment Policy Statement (“IPS”). Our responsibility to both you and the Independent Manager, we direct to manage your account, will be to: v Recommend only Independent Managers whose investment strategies fit your management criteria and risk tolerance level while ensuring you meet the minimum requirements of the Independent Manager to open a managed account. v Evaluate the Independent Manager’s investment returns and performance to ensure they are a fit with risk objections. v Suggest changes to a Independent Manager, if necessary, as market factors and your personal goals dictate. v Handle all administrative and clerical duties as may be required by the Independent Manager to service your account since they will have little or no direct contact with you. Information regarding the portfolio monitoring fee structure is disclosed under “Portfolio Monitoring Fee” in Item 5, “Fees & Compensation.” General Consulting The consulting services we offer are independent of our portfolio management and portfolio monitoring services. Under this arrangement, we do not provide any on-going management of your account or give continuous investment advice. We will perform the desired task, but you are responsible for implementing any of the advice if you have not engaged us separately for that service. Consulting services can include the following: v General and/or specific advice on non-managed investments such as private placements and independent hedge fund offering. Independent retirement plan benchmarking and cost analysis. v Real Estate Investments opportunities. v v Preparing consolidated reports from multiple sources (i.e., brokerage, IRA, variable annuity accounts, managed accounts, etc.) into a single quarterly performance report for your review and consideration. v General and/or specific life insurance or annuity contract review and recommendations. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 6 of 25  DISCLOSURE BROCHURE For information on our fees for consulting services, see “General Consulting Fee” under Item 5, “Fees & Compensation.” I FEES & COMPENSATION T E M 5 Discovery Meeting The Discovery Meeting has no cost or obligation. This meeting provides the opportunity for both parties to get to know each other and for us to share in greater detail how we can address your monetary objectives: v Diagnose your current family financial need. v Address your financial concerns and answer your questions on how we can assist you. v Discuss private banking for credit and lending, liquidity, and money movement needs and how we can facilitate their services when necessary while providing reporting capabilities and oversight of the transactions. v Recommend financial resolutions to lower costs, reduce risks, increase expected returns, and/or increase tax efficiency to improve the likelihood of successfully achieving your goals. v Explain our investment methodology and how our investment strategies work; and, v Explain the benefits of wealth planning8 and how an evaluation of your wealth management needs is beneficial beyond just managing your investable assets. From the Discovery Meeting, our objective will be to move forward under an advisory contract to manage your portfolio assets. We will prepare the necessary agreements to perform the desired service. If, however, you do not wish to engage us for our wealth management services, you will be responsible for implementing any recommendations coming out of the Discovery Meeting. All wealth management solutions discussed will have been concluded and we are not responsible to implement the advice or for any on-going supervision, monitoring, and/or reporting. Portfolio Management Fee Portfolio management is provided on an asset-based fee9 arrangement. The management fee will be calculated based on the average daily balance10 of your account(s) for each day in the previous calendar quarter your account was managed multiplied by one-fourth of the corresponding annual percentage rate for each portion of your portfolio assets that fall within each tier (See “Billing” below under “Protocols for Portfolio Management” for formula calculation.). 8 We do not charge a fee for wealth planning; it is a complementary service available to all clients. At our discretion, based on your unique financial need, we will prepare at minimum a limited-scope financial plan. 9 An asset-based fee is a percentage fee charged based on your assets under management for our professional time giving continuous advice, managing investment strategies, and suggesting investment options. We receive no other compensation for this advisory service unless first disclosed to you. 10 The average daily balance is calculated first by determining the maximum number of days from which to retrieve prices and then accumulates the values of your account on each day of the calendar quarter. This accumulation is then divided by either the total number of days the account balance was not zero or the total number of days in the quarter your account was managed. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 7 of 25  DISCLOSURE BROCHURE The tier breaks are as follows: Portfolio Value First $2,000,000 ........................................ Annual Fee Rate Not to Exceed 1.25% Next $3,000,000 ........................................ 0.90% Next $5,000,000 ........................................ 0.60% Next $15,000,000 ....................................... 0.50% Next $25,000,000 ....................................... 0.45% Over $50,000,000 ...................................... Negotiable Our management fee will be fully disclosed to you in an advisory agreement prior to conducting any portfolio management services. We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size, complexity, and nature of the portfolio managed. In addition, for the portion of your portfolio that exceeds into the next tier level, either through additional deposits or asset growth, a fee break will occur. At our discretion, we may combine the account values of family members, business associates, or other combinations we deem appropriate to determine the applicable advisory fee. Combining account values may increase the asset total, which may result in you paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We do not require a minimum account size to open a portfolio management account. Protocols for Portfolio Management Services The following protocols establish how we handle our portfolio management accounts and what you should expect when it comes to: (i) managing your account; (ii) your bill for investment services; and (iii) other fees charged to your account(s). Discretion We will establish discretionary trading authority on all management accounts to execute securities transactions at any time without your prior consent or advice. You may, however, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of margin or leverage, etc.) Billing Your account will be billed quarterly, in arrears, a blended fee based on the fair market value for the portion of your portfolio (including cash and cash equivalent securities) that fall within each tier of our fee schedule. For example: Annual Fee % (Per Tier) Tier Fee Contribution (Based on the Account Value Within Each Tier) 1.25% 0.90% 0.60% 0.50% Account Value: $14,500,000 First $2,000,000 Next $3,000,000 Next $5,000,000 Next $4,500,000 Blended Annual Fee % 0.17% 0.19% 0.20% 0.16% 0.72% Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 8 of 25  DISCLOSURE BROCHURE For new management accounts opened in mid-quarter, our fee will be based upon a pro- rated calculation of your assets managed for the calendar quarter just ending. Advisory fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Management Fee Exclusions Custodial Fees The above fees for our portfolio management are exclusive of any charges imposed by the custodial firm(s) who has custody of your account; including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. There can be no assurance that Charles Schwab & Co., Inc. (“Schwab”) will not change its transaction fee pricing in the future. These fees/charges are in addition to our investment advisory fee. We do not receive any portion of Schwab fees/charges. Investment Company Fees All fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses, which we do not share in, generally include management fees and various fund expenses, such as 12b- 1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. For more information on the custodial firms, we recommend to custody your portfolio accounts, see Item 12, “Brokerage Practices”. Termination of Portfolio Management Service To terminate our portfolio management service, either party (you or us) may terminate the advisory agreement at any time by written notification to the other party, provided such written notification is received at least 5 days before the termination date. Such written notice should include the termination date and any final instructions on the account (i.e., liquidate the account, finalize all transactions, and/or cease all investment activity). In the event termination does not fall on the first/last day of a calendar quarter, we shall bill your account a pro-rated management fee based upon the number of days during the quarter we managed your portfolio account from when the termination notice goes into effect. The final invoice will be billed immediately upon receipt of your notice of termination. Once we implement the termination of portfolio management services, neither party has any obligation to the other – we no longer earn management fees or give investment advice, and you become responsible for making investment decisions. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 9 of 25  DISCLOSURE BROCHURE Portfolio Monitoring Fee The Independent Managers who will be used to manage your account(s) will disclose the fees for management services in their Disclosure Brochures (the Independent Manager’s ADV Part 2A: Firm Brochure), which we will provide you prior to, or at the same time as, opening an account. The total fees to be charged to your account will include: 1. Our portfolio monitoring fee, based upon the above fee schedule disclosed above under “Portfolio Management Fee.” 2. The Independent Manager’s management fee, payable pursuant the fee schedule established by the Independent Manager to whom you are referred. These fees may or may not be negotiable. 3. Trading commissions and/or account charges, which may be imposed by the custodian or broker/dealer used to custody your account(s). The total fees billed to your account using both the Independent Manager to manage your portfolio and us to monitor your portfolio, could cause the overall fees billed to your account to be higher than if you didn’t use a separate Independent Manager to manage your account. You are encouraged to read our Disclosure Brochure and the Independent Manager’s Disclosure Brochure to understand the fees you will pay before agreeing to use a separate Independent Manager. Our Responsibilities Relating to Portfolio Monitoring The Independent Manager we select together will implement their investment strategy for the portion of your managed assets we have designated for them to manage. Under this arrangement: v Our responsibility to you will be to continuously evaluate the performance of your portfolio to confirm the Independent Manager adheres to your asset allocation guidelines and will make recommendations to you regarding the Independent Manager as market factors and your personal goals dictate. We will provide all administrative and clerical duties as may be required to service your account. The Independent Manager may have little or no direct contact with you. We are not involved in the day-to-day buy/sell decision for your assets managed by these Independent Managers v Our responsibility to the Independent Manager will be to ensure you meet their minimum qualifications and that you have been given proper disclosure. The Independent Manager we choose together to manage your portfolio account(s) will include all pertinent disclosures in their Disclosure Brochures (Form ADV Part 2A: Firm Brochure) relating to their management services, which we will provide you, if required and necessary, prior to, or at the time, we open the account. You are encouraged to carefully review these disclosures. Portfolio Monitoring Protocols You will want to consult the Independent Manager’s Disclosure Brochure for their policies on how they will handle your account, such as: billing, deposits and withdrawals, fee exclusions, termination, and any other unique advisory costs associated with their service since we do not handle any account administration. We will discuss these arrangements with you when we go to open your account with an Independent Manager; however, you are encouraged to read their terms for management on your own. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 10 of 25  DISCLOSURE BROCHURE General Consulting Fee Our general consulting fee is a negotiable hourly rate not to exceed $500 per hour for our service. All consulting fees will be completely itemized in a billing statement at the completion of the requested service. General consulting services can be terminated at any time. I PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT T E M 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts. I TYPES OF CLIENTS T E M 7 The types of clients to whom we offer advisory services are described above under “Who We Are” in the Item 4, “Advisory Business” section. We have no minimum account size for portfolio management as disclosed above under “Portfolio Management Fee” in Item 5 above in the “Fees & Compensation” section of this Brochure. I METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS T E M 8 Our portfolio management services are designed to achieve your financial and life goals. Your financial needs, investment objectives, time horizon, liquidity, taxes, and risk tolerance help us determine an effective investment strategy. Your tailored portfolio can include a mix of equity (“stock”) positions, Investment Company (“mutual fund”) products, Exchange-Traded Funds (“ETFs”), fixed-income/debt (“bond”) instruments, real estate funds that include Real Estate Investment Trusts (“REITs”), and cash/cash equivalent securities to meet your investment objectives. We could recommend alternatives depending on your unique investment objectives and risk tolerance (i.e., private placements, digital assets, closed-end funds, leveraged ETFs, and derivatives, such as: options and commodities). If we recommend investing in one of these securities, we will discuss the limitations of such security and the potential risk factors to your portfolio. Methods of Analysis We will use various analytical methods to analyze securities and develop an appropriate asset allocation portfolio. Fundamental Analysis Fundamental analysis is a method of analyzing the intrinsic value of a financial asset, such as a stock or bond, by examining its underlying economic and financial factors. It involves analyzing a company's financial statement and ratios to determine its financial health and growth prospects. The goal of fundamental analysis is to determine whether the current market price of an asset is undervalued, fairly valued, or overvalued. RISKS – Fundamental analysis places greater value on the long-term financial structure and health of a company, which may have little to no bearing on what is actually happening in the marketplace. Investing in companies with sound financial data/strength and a history Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 11 of 25  DISCLOSURE BROCHURE of healthy returns can be a good long-term investment to hold in your portfolio; however, such fundamental data does not always correlate to the trading value of the stock on the exchanges. In the short-term, the stock can decrease in value as investors trade in other market sectors. Quantitative Analysis Quantitative analysis uses mathematical and statistical models to analyze financial markets and assets. It involves using many data points, such as historical prices, trading volume, and other financial metrics, to identify patterns and trends. This information is used to make investment decisions based on statistical probabilities and risk management principles. RISKS – The key benefit of quantitative analysis is its ability to reduce complex figures to a single piece of data that is easy to grasp, discuss, and support decision-making and investment recommendations. However, quantitative analysis relies on mathematical models and historical data, which may not always be a reliable indicator of future performance and real-world conditions. Technical Analysis Technical analysis utilizes current and historical pricing information to help us identify trends in the broader domestic and foreign equity and fixed income markets, and in the underlying assets themselves. This may involve the use of various technical indicators, such as moving averages and trend-lines, among others. RISKS – Technical analysis is charting the historical market data of a stock, taking into consideration current market conditions, to forecast the direction of a future stock price rather than using fundamental tools for evaluating a company’s financial strength. Technical analysis focuses on the price movement of a security trading in the marketplace. This is an ideal tool for short-term investing to identify ideal market entry/exit points. However, no market indicator is absolutely reliable, and your investment portfolio can underperform in the short-term should the market indicators be incorrect. Cyclical Analysis Cyclical analysis uses cyclical patterns and economic data to predict economic trends and market movements. It is based on the theory that economic activity follows a predictable expansion and contraction pattern known as the business cycle. We can predict economic growth and market trends by identifying where the economy is in the business cycle. RISKS – Cyclical data reveals regular intervals of repeated events that can be forecasted into the future to time the market on when to buy/sell a security. The risk with cyclical analysis is attempting to buy/sell a security based on a future price prediction and missing beneficial movements in price due to an error in timing. This causes harm to the value of the security being bought too high or sold too low. Behavioral Economics and Market Psychology In additional to the above analysis techniques, we consider behavioral economics and market psychology in our investment and trading decisions. Large groups of investors may act irrationally for periods of time (the herd mentality), and we seek to exploit the mispricing of equities that this may cause. Social media is now a significant factor in the movement of stocks, and we seek to find ways to trade and invest around the volatility that it creates. RISKS – Attempting to predict rational and/or irrational investment tendencies with social media groups is risky due to their whimsical nature not based on any guiding investing Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 12 of 25  DISCLOSURE BROCHURE principles. This strategy is usually very short-term due to the extreme tendencies of the group but is a great tool to trade securities with good fundamentals that have been affected by the herd mentality. Fundamental analysis provides us with a broad long-term view of a security that begins with determining a company’s value and the strength of its financials while quantitative analysis assists us with portfolio optimization techniques. Technical analysis is short-term focusing on the statistics generated by market activity, behavioral economics is also short-term but mostly focuses on social trends and the political, societal mood for the day and, cyclical analysis provides us with historical data on market trends to focus our technical/behavioral analysis for optimal entry/exit points. Investment Strategies We are not bound to a specific investment strategy or ideology for the management of your investment portfolio. We understand markets and money made from increased stock values has greater risk (volatility) than money earned from dividends (secure and stable) in income- oriented securities. Our goal is to balance making and earning money by maintaining a disciplined management approach, regardless of the strategy, so as to not sacrifice long-term goals for short-term gains. Asset Allocation Strategy Asset allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Other features of our asset allocation strategies can utilize these portfolio-modeling structures for analyzing various possible portfolio groupings of securities. Modern Portfolio Theory Modern Portfolio Theory (“MPT”)11 is the analysis of a portfolio of stocks as opposed to selecting stocks based on their unique investment opportunity. The objectives of MPT is to determine your preferred level of risk and then construct a portfolio that seeks to maximize your expected return for that given level of risk. Strategic Allocation Modeling Strategic asset allocation is a strategy that involves setting target allocations for various asset classes, then periodically rebalancing the portfolio back to the original allocations when target allocations deviate significantly from the initial setting due to differing returns from various assets. Tactical Allocation Modeling Tactical asset allocation is a dynamic investment strategy that actively rebalances a portfolio allocation mix to take advantage of short-term market pricing anomalies or strong market sectors. 11 The “Portfolio Theory” was developed and introduced by Harry M. Markowitz in his paper “Portfolio Selection” published in 1952 by the Journal of Finance while he was working on his PhD doctoral thesis at the University of Chicago. Mr. Markowitz further refined his theory during the latter part of the 1950’s and on into the 70’s. Along the way, his theory became known as the “Modern Portfolio Theory”. Mr. Markowitz won the Nobel Memorial Prize in Economic Sciences in 1990 as a co-laureate along with William Sharpe. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 13 of 25  DISCLOSURE BROCHURE Core-Satellite Approach Core-Satellite is an investment strategy that blends a static (passive) and dynamic (active) investment management style to achieve more consistent tracking to asset class benchmarks. The objective behind the core-satellite approach is that most of the portfolio will be dedicated to matching its benchmark, while a smaller allocation will target enhanced returns so that, when the two elements are combined, the portfolio is potentially able to beat its benchmark in a risk-controlled manner. Value Investing Strategy Value Investing involves selecting securities that trade for less than their intrinsic values, being more concerned with the business and its fundamentals than other influences on the stock’s price. Value investing is about findings stocks or funds invested in stocks that we believe the market has undervalued and out of favor with the market creating a deflated stock price. If we find that a company’s fundamentals reveal the stock to be undervalued, we may buy the security. Bond Portfolio Strategy The primary investment objective of our bond management strategy is to produce a stable rate of current income, consistent with long-term preservation of capital. This objective is met by investing in fixed-income, investment grade securities, including: U.S. government obligations, corporate bonds, mortgage and asset-backed securities, tax-exempt bonds when appropriate, and certificates of deposits. A secondary objective is to take advantage of opportunities to realize capital appreciation by investing in below investment-grade, fixed- income securities and convertible securities. This investment philosophy is a low-risk, passive management technique. We will evaluate the bond portfolio’s performance using the Bloomberg U.S. Aggregate Bond Index as a benchmark, along with regular evaluations in regard to duration (interest rate sensitivity), industry and sector weightings, convexity, and yield to maturity, liquidity and quality – the key factors that determine fixed income market performance. Managing Risk Market Risk Factors Associated with All Investments The biggest risk to you is the risk that the value of your investment portfolio will decrease due to moves in the market. This risk is referred to as the market risk factor, also known as variability or volatility risk. Other important risk factors: v Interest Rate Risk – Interest rate risk affects the value of bonds more than stocks. Essentially, when the interest rate on a bond begins to rise, the value (bond price) begins to drop; and vice versa, when interest rates on a bond fall, the bond value rises. v Equity Risk – Equity risk is the risk that the value of your stocks will depreciate due to stock market dynamics causing one to lose money. v Currency Risk – Currency risk is the risk that arises from the change in price of one currency against that of another. Investment values in international securities can be affected by changes in exchange rates. v v Liquidity Risk – A financial risk where a company is unable to meet short-term financial obligations without selling either hard-assets or finding another way to reduce the discrepancy between cash flow and debt obligations. Inflation Risk – The reduction of purchasing power of investments over time. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 14 of 25  DISCLOSURE BROCHURE v Commodity Risk – Commodity risk refers to the uncertainties of future market values and the size of future income caused by the fluctuation in the prices of commodities (i.e., grains, metals, food, electricity, etc...). The risk factors we have cited here are not intended to be an exhaustive list but are the most common risks your portfolio will encounter. Other risks that we haven’t defined could be political, and over-concentration to name a few. However, notwithstanding these risk factors, the most important thing for you to understand is that regardless of how we analyze securities or the investment strategy and methodology we use to guide us in the management of your investment portfolio, investing in a security involves a risk of loss that you should be willing and prepared to bear; and furthermore, past market performance is no guarantee that you will see equal or better future returns on your investment. Risks Associated with using Leveraged and Inverse ETFs Leveraged and inverse ETFs use financial derivatives and debt instruments to generate double or triple the daily performance of an underlying index or asset class, thus increasing exposure to market swings. Before agreeing to our investment management services, you should consider the following risk disclosures. Leveraged and Inverse ETFs: v Are complex products that have the potential for significant loss of principal and are not appropriate for all investors. Investors should consider their financial ability to afford the potential for a significant loss. v Seek investment results for a single day only. The effect of compounding and market volatility could have a significant impact upon the investment returns. Investors may lose a significant amount of principal rapidly in these securities. v May be more volatile under certain market conditions. Investors holding leveraged ETFs over longer periods of time should monitor those positions closely due to the risk of volatility. v Are focused on daily investment returns, and their performance over longer periods of time can differ significantly from their stated daily objective. Investors may incur a significant loss even if the index shows a gain over the long term. v Use a variety of derivative products in order to seek their performance objectives. The use of leverage in ETFs can magnify any price movements, resulting in high volatility and potentially significant loss of principal. v May suffer losses even though the benchmark currency, commodity, or index has increased in value. Investment returns of leveraged ETFs may not correlate to price movements in the benchmark currency, commodity, or index the ETF seeks to track. v Some leveraged ETFs may have a low trading volume, which could impact an investor's ability to sell shares quickly. v May be less tax efficient. As with any potential investment, an investor should consult with his or her tax advisor and carefully read the prospectus to understand the tax consequences of leveraged ETFs. Risk Factor Associated with Digital Assets Digital assets cover a wide range of investments. A common characteristic is that they use distributed ledger technology (blockchain) to store, record and validate transactions. There are many types of digital assets, including cryptocurrencies, non-fungible tokens (NFTs), stablecoins and security tokens. In addition, you, as an investor, can participate in coin and token offerings, issued by developers of digital currency to raise money. Digital Assets: Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 15 of 25  DISCLOSURE BROCHURE v Lack market protections – Digital assets may present investment opportunities and might help you diversify, but they currently lack the robust regulatory protections and market oversight that investors have with stocks and bonds. v Can be extremely volatile – Different cryptocurrencies experience varying degrees of price volatility, but the sector, in general, has seen extreme volatility relative to more traditional investment assets. This means that price swings – and any investment value – may go up and down dramatically and unpredictably, and the risk of losing all of your investment is significant. v Have limited regulation – Regulation of digital assets isn’t as clearcut as it is with stocks, bonds and other traditional securities. The lack of regulatory clarity regarding some digital assets might increase the risk for fraudulent schemes and deceptive tactics – and might leave you with little recourse to recover funds invested or hold parties accountable. v Susceptible to scams – This includes Ponzi Schemes, the sale of fake coins – paid for with real crypto – and phishing scams where crooks pose as reputable people or entities and try to steal tokens and your personal information. Whatever the scam, once assets are sent, they’re generally gone for good. v Predisposed to theft – Theft of digitally stored coins and tokens is a real risk, and some digital asset platforms are better at protecting against cybersecurity risks and theft than others. There are many touchpoints where something can go wrong (such as with digital wallet providers), and many of these entities might be operating internationally and without any regulatory oversight. As in the case of scams, recovery of stolen digital assets is rare. v Prone to spoofing attempts – Bad actors have tried to lure unsuspecting investors into storing their public and private keys with fake trading platforms. Fraudsters might befriend you to entice you to move your digital wallets to a different (fraudulent) platform, or they might pose as fake tech support staff for legitimate platforms. It’s important to carefully vet an institution before using its service. v Tokens might not be received and might have little utility or worth – For digital assets that are contingent on certain triggering events – such as ICOs contingent on the development of a new enterprise and a related future public sale of tokens – the triggers might not occur, and you might not receive the associated tokens. Even if you do receive tokens, they might be worth nothing or might be redeemable only for goods or services by the token issuer. Furthermore, there might be no ability to trade or exchange tokens. I DISCIPLINARY INFORMATION T E M 9 We have no legal or disciplinary events to report. I OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS T E M 1 0 Financial Industry Affiliations The Managing Members of Haven Private named in Item 4, “Advisory Business” above, through one or more companies, may: (i) serve as a member on the Board of Directors and/or as an officer or partner in which they have other managerial duties; (ii) act as a sub-advisor and/or portfolio manager; and/or (iii) provide additional services as an agent and/or representative of that entity. These personal business interests are separate and distinct from the operations of Haven Private, including certain advising and consulting activities that are beyond the scope of services we provide. Those businesses that are financial industry related are listed as follows: Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 16 of 25  DISCLOSURE BROCHURE Enclave Risk Management, LLC – Enclave is an independent insurance agency offering life and health insurance from multiple insurance companies that best meets your insurance needs. Enclave is wholly owned by Elevate IV, LLC that is in turn majority owned by Mr. Angle, Ms. Cole, and Mr. Gibson. These Managing Members through Elevate IV, LLC control and provide operational oversight of Enclave. Topper Hill, LLC d/b/a Topper Hill Group – Topper Hill Group is an independent insurance agency offering property and casualty insurance to help mitigate loss in the event of an unforeseen accident in your home or on your property. Topper Hill Group is equally owned by Elevate IV, LLC and an unaffiliated entity. As previously indicated Elevate IV, LLC is majority owned by Mr. Angle, Ms. Cole, and Mr. Gibson. Through their roles as Managing Members of Elevate IV, LLC they assist with control and operational oversight of Topper Hill Group. GL-Regal Pine I, LP – GL-Regal Pine I, a Delaware Limited Partnership, is organized as a private Regulation D offering to target investment opportunities primarily as a “fund of funds” for investment in funds or other pooled investment vehicles and may also target investments in equity or debt securities. Investments can include but not limited to private equity funds, private credit funds, real assets, opportunistic investments cryptocurrencies, including pooled investment vehicles that invest in cryptocurrencies. Other investments may include early stage, late stage or majority control operating companies within the defense, cybersecurity, space technology and related sectors across the federal and commercial markets. Haven Private will serve as the sub- advisor to the GL-Regal Pine I. Intentionalize, LLC – Intentionalize is a business enterprise that provides advanced strategic consulting to entrepreneurs, founders, and successful families seeking to align their financial and personal success with their long-term goals and values. The firm focuses on helping clients protect what they have built, clarify future objectives, and design an intentional legacy. Intentionalize is wholly owned by Mr. Angle and Ms. Cole. As owners, they provide operational oversight and work directly with clients to optimize future plans, identify risks and opportunities, and develop tailored, practical strategies. Potential Time Management Conflict The oversight obligation the Managing Members have, as control persons for each of the above-named entities, can range from 5% to 10% of their time depending on their responsibilities, operational constraints, and administrative functions and duties. The Managing Members’ responsibilities to these entities can create a time management conflict, which might impede their ability to address your investment needs as an advisory client of Haven Private. You should consider this conflict of interest before making your final decision to engage Haven Private for advisory services. Regardless, the Managing Members feel their responsibilities to these other entities will have little impact on their duty to manage your investment portfolio. Conflicts Working with Affiliated Entities Referral to, from, and between the above-named entities the Managing Members own creates a potential conflict of interest to our fiduciary duty to be impartial with our advice and to keep your interests ahead of our own. As control persons, shareholders, and/or representatives in each of the above-named entities, the Managing Members are able to influence the direction of investment activities – keeping all services in house. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 17 of 25  DISCLOSURE BROCHURE Accepting any of the Managing Members’ recommendations to use one of the above-named entities, can lead to increased personal revenues in the form of advisory/referral fees, salary, income/dividend returns, bonuses, and incentive fees. Therefore, before accepting any recommendation to engage an affiliated company, you may wish to consider other options to ensure that the services from our affiliates are comparable or equivalent to the service you might receive from other independent firms. Private Fund Investment Limitations and General Considerations You may be solicited, along with other independent investors, to invest in the GL-Regal Pine I, LP if you are an “accredited investor”, as defined in Rule 501 of Regulation D under the 1933 Act. If you do not meet this qualification, you may be disqualified from investing in this private investment fund. However, should it be determined that you do fit the criteria to invest, and you express interest to invest, a Confidential Private Placement Memorandum (“PPM”) will be provided to you. The PPM discloses all possibilities for conflicts of interest and inherent risks, which are necessary for you to make an informed decision. You are under no obligation to invest in this private investment fund. However, if you do choose to invest, you also have the right to rescind your subscription and receive a full refund of your investment within three (3) business days after entering into a Subscription Agreement. See “Pooled Investment Vehicle Compensation” under Item 14, “Client Referrals & Other Compensation” for more information on the potential conflicts. Insurance Company Activities Certain of our management persons are licensed as life and annuity insurance agents by the State of Florida and as non-resident agents in other states. As agents, these management persons are licensed to sell insurance-related products and earn commissions from the sale of these products. A conflict of interest can potentially occur when these management persons, as trusted advisors managing your portfolio for a fee, recommend you purchase an insurance product in which they will earn a commission. This can create a situation of divided loyalty and the objectivity of the advice rendered could be subjective and create a disadvantage to you. Therefore, keep in mind you are under no obligation to accept the recommendations made by our management persons to purchase insurance related products. You are free to reject their recommendation or, if you need the insurance, to choose the insurance agency, agent, and insurance company from whom to purchase the insurance. However, if you elect to purchase the insurance, regardless of where, and from whom you purchase it, such person will be entitled to earn a commission. More information on the potential conflicts and economic benefits from being a licensed insurance agent can be found in each of our management persons “Brochure Supplements.” I CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING T E M 1 1 Code of Ethics As a fiduciary, the Company has an affirmative duty to render continuous, unbiased investment advice, and at all times act in your best interest. To maintain this ethical responsibility, we Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 18 of 25  DISCLOSURE BROCHURE have adopted a Code of Ethics that establishes the fundamental principles of conduct and professionalism expected by all personnel in discharging their duties. This Code is a value- laden guide committing such persons to uphold the highest ethical standards, rooted in the most elementary decorum. Our Code of Ethics is designed to deter inappropriate behavior and heighten awareness as to what is right, fair, just and good by promoting: v Honest and ethical conduct. v Full, fair and accurate disclosure. v Compliance with applicable rules and regulations. v Reporting of any violation of the Code. v Accountability. To help you understand our ethical culture and standards, how we control sensitive information and what steps have been taken to prevent personnel from abusing their inside position, a copy of our Code of Ethics is available for review upon request. Client Transactions We have a fiduciary duty to ensure that your welfare is not subordinated to any interests of ours or of our personnel. The following disclosures are internal guidelines we have adopted to assist us in protecting all of our clientele. Participation or Interest It is against our policies for any owners, officers, directors and employees to invest with you or with a group of clients, or to advise you or a group of clients to invest in a private business interest or other non-marketable investment unless prior approval has been granted by our Chief Compliance Officer, and such investment is not in violation of any SEC and/or State rules and regulations. Insider Trading Policy We comply with the Insider Trading and Securities Fraud Enforcement Act of 1988. Together with the Investment Advisers Act of 1940 and SEC Rule 204A-1 (Code of Ethics), these rules prohibit trading in securities—or sharing information with others for trading purposes—based on material, non-public information. We do not share non-public information with anyone who does not have a legitimate need to know, and we maintain internal controls to safeguard your personal information. Our insider trading policy is designed to prevent misuse by clearly defining what constitutes “insider information” and requiring all supervised persons and investment adviser representatives to follow strict procedures and compliance expectations. Class Actions, Bankruptcies, and Other Legal Proceedings Policy The Company does not elect to participate in class action lawsuits on your behalf. Such decisions shall remain with you or with an entity you designate. We will neither advise nor act on your behalf in legal proceedings involving companies whose securities are held in your account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, you may direct us to transmit copies of class action notices to you or a third party or to relate requested claim form information to you or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 19 of 25  DISCLOSURE BROCHURE Personal Trading Employees are allowed to invest their own money in securities, including securities that may also be recommended to you. In most cases, personal trades are made independently of client trading. However, there may be times when an employee buys or sells the same security at or near the time we trade for clients. Because this could create a conflict of interest, we follow strict guidelines to protect you 1. Employees with discretion over client accounts may not trade for themselves based on non-public or employment-derived information. Client interests always come first. 2. Our Chief Compliance Officer regularly reviews personal holdings and trading activity of access employees. 3. All employees must follow applicable federal and state advisory regulations. 4. If employee accounts are included in aggregated (“bunched”) orders, client orders receive priority and are filled first. 5. Violations of these rules may result in disciplinary action, including termination. Personal trading is monitored to ensure it does not disadvantage clients or compromise our fiduciary duty. I BROKERAGE PRACTICES T E M 1 2 Custodial Services The Company maintains a custodial relationship with Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of FINRA/SIPC, through Schwab Advisor Services, a business unit that provides custodial services to independent investment advisers. Schwab provides services including custody of client assets, trade execution, clearance, and settlement of transactions. While we do not have a soft-dollar arrangement with Schwab, we receive certain economic and administrative benefits from Schwab Advisor Services that are not typically available to retail clients of Schwab. These benefits create a potential conflict of interest because they provide an incentive for us to recommend Schwab as custodian. The benefits we receive include, but are not limited to: v Access to electronic systems for order entry, account information, and reporting. v Receipt of duplicate client statements and trade confirmations. v Access to trading and operational support services, including a dedicated trading desk. v Access to batch trading capabilities for the aggregation and allocation of transactions. v The ability to have advisory fees deducted directly from client accounts. v Access to educational, practice management, and consulting resources. These benefits are not paid for with client commissions and do not constitute soft-dollar arrangements. We are not affiliated with Schwab, and Schwab does not supervise or direct the investment advice we provide. We retain sole responsibility for the investment advice rendered to clients. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 20 of 25  DISCLOSURE BROCHURE Direction of Transactions and Best Execution As a fiduciary, we seek to obtain best execution for client transactions, taking into account factors such as execution capability, transaction costs, financial strength, responsiveness, and the overall quality of services provided. The custodial support services and benefits we receive from Schwab create a potential conflict of interest, as they provide an incentive to recommend Schwab as custodian. We address this conflict by periodically evaluating Schwab’s services and pricing and by determining that Schwab’s overall services are reasonable and appropriate for our clients. We generally recommend Schwab as custodian and do not routinely offer clients a selection of alternative custodians. Clients are not required to use Schwab and may select a different custodian; however, doing so may limit our ability to provide certain services and may result in additional costs to the client. Aggregating Trade Orders When we place trades, our goal is to treat clients fairly and to seek the best possible outcome for everyone (this is called “best execution”). To help do that, we often combine similar client orders into one larger “block” trade and then allocate the shares to each account. We generally do this only when (i) combining orders is expected to improve execution, and (ii) no client is consistently helped or hurt by the practice. Before we aggregate orders, we consider several factors, including: v Trading volume of the security. In heavily traded markets, block trades can help clients receive the same price and timing, rather than being filled at different prices throughout the day. v Number of client accounts involved. If only a small number of accounts are participating, placing separate orders may be more efficient or may result in better execution than aggregating them. v Type of investment and order complexity. Certain securities and more complex orders may be better handled individually to achieve the best execution. This approach is intended to improve fairness, consistency, and overall execution quality for our clients. I REVIEW OF ACCOUNTS T E M 1 3 Portfolio Management Reviews Your investment strategy and holdings are monitored by Stacey L. Cole and reviewed on an on- going basis by the Investment Advisor Representative (“IAR”) managing your account. We may review your portfolio more frequently when market conditions change, the economy shifts, or tax laws are updated. We also adjust cash levels as needed. If there are significant changes in your personal or financial situation—or in your goals—we may need to re-evaluate your portfolio and update our recommendations. It is your responsibility to let us know about these changes so we can make appropriate updates to your managed account(s). Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 21 of 25  DISCLOSURE BROCHURE You will receive account statements from Schwab, the custodian of your account(s), at least quarterly. These statements show your current holdings, the cost basis of each investment, and their current market value. We encourage you to review these statements carefully. They summarize your account value, holdings, and all transactions made during the quarter. Reviewing them helps confirm that everything is reported accurately and that your portfolio continues to align with your expectations. I CLIENT REFERRALS & OTHER COMPENSATION T E M 1 4 Referral Compensation We may directly compensate persons for client referrals provided such persons are qualified and have entered a referral partner’s agreement with us as required by Rule 206(4)-1 of the Investment Adviser Act of 1940, as amended. Under such arrangements, if a referral partner referred you, the referral partner will provide you complete information on our relationship – the relationship between the referral partner and us – and the compensation the referral partner will receive should you choose to open an account. This compensation will be paid solely from our fee and will not result in any additional charge to you. The referral partner is not licensed to give you any investment advice and therefore cannot advise you on the management of your account. A referral partner simply makes an introduction and is compensated only if you were to open a management account with us under these arrangements. Other Compensation (Indirect Benefit) As indicated in Item 12, “Brokerage Practices” above, we can receive from Schwab (and others) without cost (and/or at a discount) support services and/or products. You do not pay more for investment transactions effected and/or assets maintained at Schwab (or any other institution) as result of this arrangement. There is no corresponding commitment made by us to Schwab, or to any other entity, to invest any specific amount or percentage of your assets in any specific mutual funds, securities, or other investment products as the result of the above arrangement. Insurance Compensation For those management persons who are commissioned insurance agents, there is an incentive for them to recommend only those insurance products in which they will receive a commission. Consequently, loyalties could be divided, and the objectivity of our advice could be subjective and create a disadvantage to you. Therefore, you are under no obligation to purchase any insurance products from our management persons. You are free to choose the insurance agency, agent, and insurance company from whom to underwrite our insurance recommendations. Keep in mind that regardless of the agent you select to purchase the insurance from, that person will be entitled to earn a commission from the sale. Pooled Investment Vehicle Compensation Our fiduciary duty binds us to an ethical standard of complete care and loyalty and to avoid circumstances that might affect, or appear to affect, this standard unless we act transparently and provide you full and fair disclosure on any potential conflict. Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 22 of 25  DISCLOSURE BROCHURE Haven Private serves as the sub-advisor to the GL-Regal Pine I, LP. As such, the Managing Members of Haven Private will receive economic benefits from recommending that you invest in this private investment fund. These benefits could be, but are not limited to, an increase in advisory/consulting fees, salaries, and incentive fees should you choose to invest. Therefore, before accepting our recommendation to invest in this affiliated private fund, you should consider other investment opportunities to ensure the expenses and investment returns are comparable or equivalent to this private investment fund. See “Financial Industry Affiliation” and “Private Fund Investment Limitations and General Considerations” above under Item 10, “Other Financial Industry Activities & Affiliations” for disclosure about time management, affiliated entity considerations, and the investment qualifications of the private investment fund. Retirement Rollover Compensation If we recommend that you roll over retirement plan assets into an IRA that we manage, we will earn an advisory fee on those assets. Because that increases our compensation, the Department of Labor (“DOL”) views this as a potential conflict of interest (“self-dealing”). We are prohibited from making that recommendation unless we comply with the DOL’s Prohibited Transaction Exemption 2020-02 (“Improving Investment Advice for Workers & Retirees”). Under this exemption, we act as a fiduciary when providing rollover advice and will only recommend a rollover if we believe it is in your best interest. Before doing so, we compare your current plan to an IRA—considering factors such as fees and expenses, services, investment options, and your specific needs—and we document the reasons for our recommendation. When you leave an employer, you typically have four choices for your retirement assets: 1. Leave the assets in your former employer’s plan, if the plan allows it. 2. Roll the assets into your new employer’s plan, if available and rollovers are permitted. 3. Roll the assets into an Individual Retirement Account (“IRA”); or 4. Cash out the account (which may result in taxes and/or IRS penalties, depending on your age). If you decide to roll over your retirement assets to an IRA, you are under no obligation to hire us to manage those funds. You are free to choose any IRA provider or advisor you prefer. I CUSTODY T E M 1 5 Management Fee Deduction We do not take possession of or maintain custody of your funds or securities but will simply monitor the holdings within your portfolio and trade your account based on your stated investment objectives and guidelines. Physical possession and custody of your funds and/or securities are maintained with Charles Schwab & Company, Inc., as indicated above in Item 12, “Brokerage Practices.” We are however defined as having custody since you have authorized us to deduct our advisory fees directly from your account. Therefore, to comply with the United States Securities and Exchange Commission’s Custody Rule (1940 Act Rule 206(4)-2) requirements, and to protect you as well as to protect our advisory practice, we have implemented the following regulatory safeguards: Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 23 of 25  DISCLOSURE BROCHURE v Your funds and securities will be maintained with a qualified custodian in a separate account in your name. v Authorization to withdraw our management fees directly from your account will be approved by you prior to engaging in any portfolio management services. Deducted advisory or management fees will be reflected on your monthly statement from Schwab and/or the custodian of your account. Please also note that the custodian does not verify the accuracy of the management fee calculation. To the extent that we provide you with periodic account statements or reports, you are urged to compare any statement or report provided by Haven Private with the account statements received from the account custodian. Standing Letters of Authorization We will allow you to maintain a Standing Letter of Authorization (“SLOA”) with Haven Private. However, SLOAs with asset transfer instructions to a third-party (e.g., any person/entity/joint account other than just you alone) define us as having custody under the Custody Rule (1940 Act Rule 206(4)-2). Therefore, to comply with the No-Action Letter issued by the SEC, relating to SLOAs and the Custody Rule, we have implemented the following regulatory safeguards and will only accept SLOAs under these conditions: v The person and place of delivery must always be identified in the SLOA instructions. We will not approve any SLOAs where we are authorized to modify the instructions relating to the person and/or place of delivery. v We will not accept SLOA instructions for delivery to a person affiliated with our firm and/or located at our place of business. v The timing and amount of assets to transfer can be open-ended per the instructions of the SLOA. v All SLOA instructions must be in writing and confirmed with your signature. We will not accept verbal changes to any SLOAs. The SEC SLOA No-Action Letter identifies seven (7) steps to follow as part of the safekeeping requirements. The first two bullet-points above are our responsibility under the No-action Letter, the remaining five (5) are the responsibility of the qualified custodian (Schwab). If you would like a complete list of the safekeeping instructions, let us know and we will be glad to provide you a copy. I INVESTMENT DISCRETION T E M 1 6 We have you complete our advisory agreement, which sets forth our discretionary trading authority to buy and sell securities in whatever amounts are determined to be appropriate for your account and whether such transactions are with, or without, your prior approval. You may, at any time, impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of margin or leverage, etc.). I VOTING CLIENT SECURITIES T E M 1 7 Haven Private’s Investment Committee has primary responsibility for coordinating the voting of proxy solicitations. Proxy solicitations will be voted in your best interest and in accordance with our established Proxy Voting Policies and Procedures. For information on how we vote Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 24 of 25  DISCLOSURE BROCHURE proxies or for information on our Proxy Voting Guidelines, you may contact the office and arrangements will be made for you to receive a copy of our Guidelines and records of how we voted. We will assess all circumstances surrounding those corporate matters being proposed for vote by proxy solicitation prior to submitting our decision. All non-routine issues being proposed will require further evaluation of the relevant facts and circumstances. If it is not clear how to interpret or apply our Proxy Voting Guidelines for a particular vote, any decision to proceed will be based on what we have determined will best service the long-term best interests of our clients – even if that includes deviating from our current Guidelines. Haven Private engages a third-party provider to assist with the administration of proxy voting. We may advise or act on your behalf in legal proceedings involving companies whose securities are held in your account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. Any assistance with class-action matters, the unaffiliated third-party service provider we engage to assist with this recovery will earn a fee not to exceed 20% of the recovered amount. If desired, you may direct us to transmit copies of class action notices directly to you or to a third-party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. We usually vote proxies on your behalf although you may direct how we vote a particular proxy solicitation, or you may retain the right to vote all proxies for your account. If you elect to vote your own proxies, the custodian of your managed accounts will mail you all proxy solicitations. Any proxy solicitations inadvertently received by us will be immediately forwarded to you for your evaluation and decision. If you have specific questions regarding an action being solicited by the proxy that you do not understand, or you want clarification, you may contact us, and we will explain the particulars. I FINANCIAL INFORMATION T E M 1 8 We are not required to include financial information in our Disclosure Brochure since we will not take physical custody of client funds or securities or bill client accounts six (6) months or more in advance for more than $1,200. We are not aware of any current financial conditions that are likely to impair our ability to meet our contractual commitments to you. In addition, the Company has not, nor have any of our officers and directors, been the subject of a bankruptcy petition at any time during the past ten years. END OF DISCLOSURE BROCHURE Form ADV: Part 2A © eAdvisor Compliance, Inc. – Disclosure Brochure Design Layout. www.eAdvisorCompliance.com Page 25 of 25