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1. Cover Page
FIRM BROCHURE AND BROCHURE SUPPLEMENT
EBH CAPITAL MANAGEMENT LLC
doing business as QuantStreet Capital
1333A North Avenue, Suite 743
New Rochelle, New York 10804
www.quantstreetcapital.com
This firm brochure and brochure supplement provide information about the qualifications and
business practices of QuantStreet Capital and its supervised persons, Harry Mamaysky and Isaac
Mamaysky. If you have any questions about the contents of this brochure, please contact Isaac
Mamaysky by telephone at 212.537.3877 or by email at imamaysky@quantstreetcapital.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.
Additional information about QuantStreet Capital, Harry Mamaysky, and Isaac Mamaysky is
available on the SEC website at www.adviserinfo.sec.gov. Registration as an investment adviser
does not imply a certain level of skill or training.
March 2026
2. Material Changes
Material Changes Since Last Annual Amendment
This brochure includes the following material changes since the last version of this brochure,
which was filed in March of 2025. New language has been added to reflect the following:
● QuantStreet’s assets under management increased to approximately $190,000,000 as of
January 2026.
● QuantStreet is now registered as an investment adviser with the SEC and has withdrawn
its New York investment adviser registration.
● The brochure further describes QuantStreet’s use of a proprietary machine learning
algorithm, including the addition of related risk disclosures.
● The brochure describes QuantStreet’s new use of artificial intelligence tools to generate
news summaries, which are shared with certain clients who opt in, and the brochure
includes related risk disclosures.
● QuantStreet has a policy not to vote proxies for clients unless a particular client requests
that the firm does so and provides written instructions about how to vote.
● QuantStreet does not typically aggregate orders into block trades, but rather enters
separate orders for each client account, which may result in less favorable pricing as
compared to aggregation.
● QuantStreet now offers an adviser affiliation option for independent investment advisers
to affiliate with the firm as investment adviser representatives.
● QuantStreet now works with Interactive Brokers as an additional custodian.
● The brochure includes an updated discussion of fee schedules and billing practices.
● The brochure includes additional disclosures clarifying QuantStreet’s relationship with
model portfolio subscribers, including that QuantStreet does not have discretionary
authority over, does not monitor, and does not make suitability determinations with
respect to the client accounts of subscribers.
● QuantStreet now offers Target-Date Replicating Portfolios at multiple risk levels, which
attempt to replicate the average performance of target-date funds operating at comparable
risk levels, and the brochure includes related risk disclosures.
Full Brochure Available
To receive a copy of the latest version of this firm brochure, please contact Isaac Mamaysky by
telephone at 212.537.3877 or by email at imamaysky@quantstreetcapital.com.
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3. Table of Contents
1. Cover Page
2. Material Changes
Material Changes Since Last Annual Amendment
Full Brochure Available
3. Table of Contents
4. Advisory Business
Firm Description
Types of Advisory Services
Tailoring of Advisory Services
Assets Under Management
5. Fees and Compensation
Management Fees
Brokerage Fees, Security Fees, and Other Fees
Compensation for Sale of Securities
6. Performance-Based Fees and Side-by-Side Management
7. Types of Clients
Description
Minimum Account Size
8. Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis and Investment Strategies
Risk of Loss
9. Disciplinary Information
10. Other Financial Industry Activities and Affiliations
Material Relationship to Advisory Business or Clients
11. Code of Ethics, Personal Trading
Code of Ethics
Trading in Same Securities as Clients
12. Brokerage Practices
Selecting and Recommending Broker-Dealers for Client Transactions
Order Aggregation
13. Review of Accounts
Periodic Reviews
Review Triggers
Regular Reports
14. Client Referrals and Other Compensation
15. Custody
Constructive Custody
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Account Statements
16. Investment Discretion
17. Voting Client Securities
Proxy Voting
18. Financial Information
19. Requirements for State-Registered Advisers
S1. Brochure Supplement Cover Page
S2. Educational Background & Business Experience
S3. Disciplinary Information
S4. Other Business Activities
S5. Additional Compensation
S6. Supervision
S7. Requirements for State-Registered Advisers
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4. Advisory Business
Firm Description
EBH Capital Management LLC, which does business as QuantStreet Capital (“QuantStreet
Capital” or “QuantStreet”), was organized as a limited liability company under the laws of the
State of New York in 2021 and has offices in Westchester County, New York. QuantStreet
Capital is registered as an investment adviser with the SEC. Registration does not imply a certain
level of skill or training. QuantStreet Capital is owned by Harry Mamaysky and Isaac
Mamaysky.
Types of Advisory Services
QuantStreet Capital offers investment management, financial planning, and consulting services
to individuals, trusts, retirement plans, businesses, and charitable organizations; model delivery
subscriptions and consulting to clients including other financial advisory firms and asset
managers; and an adviser affiliation program to investment adviser representatives. To a lesser
extent, QuantStreet also offers educational speaking engagements.
is appropriate. In addition
to
Approach to Investing
QuantStreet offers a quantitative asset allocation strategy, which it implements using a
proprietary machine
learning algorithm (“Model”) combined with discretionary human
oversight. The Model constructs portfolios at multiple risk levels by combining certain
forecasting variables with historical data, with the goal of optimizing the return of each
investment portfolio at its targeted risk level. QuantStreet applies statistical analysis and
econometric modeling to historical prices, fundamental, macroeconomic, and other data. The
firm assesses risk using historical standard deviations, correlations, market betas, and measures
of tail risk. QuantStreet’s CIO carefully constrains the Model’s decision-making parameters,
reviews the recommendations of the Model, and is able to override the Model-generated
portfolio when he determines an override
the firm’s
Model-generated strategies, QuantStreet also offers portfolios (“Target-Date Replicating
Portfolios”) that attempt to replicate the average performance of target-date funds operating at
multiple risk levels, based on QuantStreet’s analysis of publicly available returns data associated
with target-date funds.
QuantStreet’s SMA Strategies
For those clients who have separately managed accounts (“SMAs”), QuantStreet generally
manages the assets on a fully discretionary basis and offers various strategy options based on
client risk level and investment objectives.
QuantStreet offers certain Model-based standard (non-custom) strategies,
including: a
conservative strategy called the Balanced Strategy; a moderate risk strategy called the Core
Strategy; a higher risk strategy called the Aggressive Strategy; and various other strategies at
different risk levels (“Strategies”). In addition, QuantStreet offers Target-Date Replicating
Portfolios and, as explained below, QuantStreet also offers custom investing strategies to meet
specific client needs.
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In its Core Strategy, QuantStreet aspires to maintain a level of risk that is generally in line with
that of an 85/15 stock/bond portfolio which is 85 percent invested in a broadly diversified U.S.
stock market index and 15 percent invested in a diversified index of intermediate-duration U.S.
government bonds (the “Risk Benchmark Portfolio”). In its Balanced Strategy, QuantStreet
targets a level of volatility below that of the Risk Benchmark Portfolio. In its Aggressive
Strategy, QuantStreet targets a level of volatility above that of the Risk Benchmark Portfolio.
QuantStreet offers other Strategies at risk levels ranging from conservative to aggressive; they
are calibrated to deviate from the Risk Benchmark Portfolio accordingly. QuantStreet is
permitted to choose a higher or lower risk level for each Strategy based on QuantStreet’s
assessment of market conditions or if QuantStreet believes a temporary risk modification will
improve portfolio performance.
As explained in the “Tailoring of Advisory Services” section below, QuantStreet also offers
custom investing strategies to address individual client goals and needs. For example,
QuantStreet may make specific decisions in a client portfolio to account for the client’s other
investments, the client’s risk exposure to a particular industry, the tax implications of selling
existing positions, and the client’s goals and requests.
Model Portfolio Subscriptions
In addition to its SMA offerings, QuantStreet offers subscriptions to model portfolios. On a
monthly basis, subscribers receive two sets of model portfolios: (1) Target-Date Replicating
Portfolios; and (2) tactical portfolios, which may experience turnover higher than that of the
Target-Date Replicating Portfolios, depending on QuantStreet’s assessment of market
opportunities and risks.
QuantStreet’s model portfolios are intended as a resource for institutional, professional, and/or
other sophisticated investors to use as one reference point when making investment decisions.
Subscribers must conduct an independent analysis of the model portfolios, their informational
value, their limitations, and their suitability to inform any particular investment strategy.
QuantStreet does not have discretionary authority over any model portfolio subscriber’s client
accounts, does not monitor such accounts, and does not provide suitability determinations.
News Summaries
QuantStreet provides certain clients who opt in with automated summaries of financial news or
market developments generated using artificial intelligence tools. These summaries are produced
without human review prior to distribution, are provided for informational and educational
purposes, and are not individualized investment advice.
Adviser Affiliation
QuantStreet offers independent investment advisers the option to affiliate with QuantStreet as
investment adviser representatives. Affiliated advisers will provide advisory services to clients
under QuantStreet’s registration. They will be subject to QuantStreet’s policies and compliance
supervision, and will receive access to our model portfolios and operational and technology
infrastructure. This affiliation option is a new offering, and as of the date of this brochure,
QuantStreet does not yet have any non-owner affiliated advisers.
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Tailoring of Advisory Services
QuantStreet SMA Strategies
Some clients invest in a QuantStreet Strategy without engaging in a larger financial planning
process. For these clients, QuantStreet provides advice about choosing an appropriate risk level
but does not otherwise tailor the investments in the Strategy to the particular needs, investment
objectives, or investment guidelines of the client. Investing in a QuantStreet Strategy without
engaging in a larger financial planning process should not be considered a comprehensive
investment plan. QuantStreet will only use one of its Strategies for an investor if QuantStreet
believes that the Strategy is appropriate for the investor’s goals and circumstances.
QuantStreet also offers bespoke portfolio management and financial planning services at an
additional cost. When QuantStreet engages in a financial planning process with a client,
QuantStreet may determine that one of its existing Strategies is appropriate for the client as a
comprehensive investment plan. Alternatively, QuantStreet may determine that the client
portfolio needs a modified approach based on various individualized considerations, such as the
client’s other investments, the client’s risk exposure to a particular industry, the tax implications
of selling existing positions, and the client’s goals and requests. In this case, QuantStreet engages
in custom portfolio management.
Clients may impose restrictions on investing in certain securities or types of securities.
QuantStreet works with clients on an individualized basis to implement such restrictions.
Model Portfolio Subscriptions
QuantStreet does not typically tailor its model portfolios, and each subscriber receives the same
set of model portfolios. However, on a case-by-case basis, QuantStreet may agree to provide a
model portfolio subscriber with additional resources or analysis based on the subscriber’s
specific requests.
Assets Under Management
As of January 2026, QuantStreet Capital had approximately $190,000,000 in assets under
management (“AUM”), all of which were managed on a discretionary basis. This AUM includes
personal accounts that QuantStreet manages for its owners, Harry Mamaysky and Isaac
Mamaysky and their families.
As previously explained, QuantStreet provides model portfolios to other asset managers.
Because those firms retain full discretionary authority over their own client accounts, are solely
responsible for their own client accounts, and independently decide whether and how to
implement the models in their own client accounts, the assets they manage using QuantStreet’s
models are not included in QuantStreet’s AUM.
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5. Fees and Compensation
Management Fees
Separately Managed Account Fees
For SMA clients, QuantStreet is generally compensated through an annual management fee
based on a percentage of the assets under management in the client’s account. QuantStreet
typically offers management fees that range from 0.30% to 0.80% of AUM, although actual fees
may be higher or lower depending on factors such as the services provided, the complexity of the
relationship, and the size of the account.
QuantStreet’s management fees may be negotiated based on the size of an account, the nature of
the investments involved, the complexity of client objectives, and other client-specific
considerations. Higher fees may apply when a client has atypical objectives or requires a
customized investing solution, and lower fees may be offered for larger accounts or under other
circumstances. QuantStreet may enter into other fee arrangements and adjust its approach to fees
for various other reasons, as agreed upon with each client. QuantStreet occasionally waives fees
for accounts such as those belonging to family members.
QuantStreet typically charges SMA management fees quarterly in advance and typically deducts
its fees directly from client accounts. However, a client may choose to be billed for fees rather
than to have fees directly deducted, and QuantStreet may allow clients to pay in arrears.
QuantStreet’s Investment Management Agreement for SMA clients generally permits either the
client or QuantStreet to terminate the investment advisory relationship at any time. Upon
termination, QuantStreet will typically maintain the client’s existing positions, but may move the
client’s positions into cash upon the client’s request. If a relationship terminates, QuantStreet
refunds any unearned fees previously paid on a prorated basis for the number of calendar days
remaining after the termination date in the period on which fees have been prepaid.
Management fees are calculated and billed by Charles Schwab and Interactive Brokers using
their standard fee calculation methodologies based on custodial account records. QuantStreet
ensures that fee rates are entered correctly and then relies on the custodians’ calculations and
billing systems.
Model Portfolio Fees
QuantStreet offers model portfolio subscriptions to asset managers, financial advisers, and other
sophisticated clients based on a fee scale ranging from $1,200 for a subscriber with no or
negligible assets under management (such as a new advisory firm) to $31,000 for a subscriber
with an overall AUM of $1 billion. Intermediate AUM levels are charged intermediate-level fees,
and fees are negotiated on an individualized basis with subscribers that manage over $1 billion in
AUM.
However, actual subscription fees may be higher or lower than the fees set forth in the fee
schedule depending on the nature of the services provided and other considerations. For
example, if a particular subscriber requests custom analysis in addition to model portfolios, then
QuantStreet may charge a higher fee. On the other hand, if a particular subscriber was an early
adopter of QuantStreet’s models, or is just launching their business, then QuantStreet may charge
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a lower fee. QuantStreet’s fees are negotiable, and QuantStreet may choose to increase these fees
over time, as agreed upon with each client.
QuantStreet typically bills model portfolio subscribers quarterly in advance, but may enter into
other billing arrangements on a case-by-case basis. Subscribers receive an invoice near the start
of each quarter. If a subscription relationship terminates, QuantStreet refunds any unearned fees
previously paid on a prorated basis for the number of calendar days remaining after the
termination date in the period on which fees have been prepaid.
Other Services
QuantStreet may provide consulting services and paid speaking engagements. The fees and
billing arrangements for these services will be determined and negotiated on a case-by-case basis
and may include flat fees or hourly fees, depending on each potential client’s needs and goals
and the details of the engagement. While QuantStreet offers these services, as of the date of this
brochure, we are not providing either of these services to any clients.
In addition, if we have any non-owner affiliated advisers in the future, they may be required to
pay QuantStreet a minimum annual fee and/or percentage of advisory revenue, in each case
pursuant to a written agreement with QuantStreet. The specific terms of any such arrangements
will be negotiated on a case-by-case basis. As previously noted, we do not currently have any
non-owner affiliated advisers.
Brokerage Fees, Security Fees, and Other Fees
Brokerage firms typically charge transaction fees on purchases or sales of securities, and certain
account custodians may charge custodial fees. Also, the ETFs, ETNs, mutual funds, and other
securities in which QuantStreet invests may charge fees, which are in addition to the fees that
clients pay to QuantStreet for its services. Additional information about transaction expenses is
available in the section of this firm brochure and brochure supplement entitled “Brokerage
Practices.”
Compensation for Sale of Securities
QuantStreet does not receive any commissions, compensation, or other financial incentive for
selecting one particular type of security over another. QuantStreet does not have any financial
relationships with the issuers of the securities that it selects for client accounts.
6. Performance-Based Fees and Side-by-Side Management
This item is not applicable.
7. Types of Clients
Description
QuantStreet Capital offers investment management, financial planning, and consulting services
to individuals, trusts, retirement plans, businesses, and charitable organizations. QuantStreet
offers model portfolio subscriptions and consulting to clients including other financial advisory
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firms and asset managers. Several QuantStreet clients are, or are controlled or influenced by,
QuantStreet personnel or members of their families.
Minimum Account Size
For its SMA clients, QuantStreet requires a minimum account size of $300,000. QuantStreet may
increase or decrease this minimum in the future, and it makes exceptions for individual clients
who have smaller accounts.
8. Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis and Investment Strategies
Investing in securities and financial markets involves risks of loss that clients should be prepared
to bear.
QuantStreet uses a proprietary machine learning algorithm (the Model), together with human
oversight, to allocate client assets across liquid asset classes with the goal of maximizing
expected returns at each targeted risk level. QuantStreet offers various investment strategies with
different volatility targets and may adjust risk levels or portfolio turnover in response to market
conditions. While the Model informs QuantStreet’s investment decisions, QuantStreet’s CIO
constrains the Model’s parameters and may override Model-generated portfolios when he
determines that doing so is appropriate.
In addition, QuantStreet offers the Target-Date Replicating Portfolios described above. These
portfolios attempt to replicate the average performance of a number of target-date funds
operating at multiple risk levels. The replicating portfolios are estimated by QuantStreet based on
publicly available information and historical return relationships.
QuantStreet may invest client assets into: ETFs, ETNs, mutual funds, U.S. Treasury securities,
corporate bonds, government-issued bonds, single-company stocks, securities that track stock
portfolios, options and other derivatives, and other types of investments that QuantStreet
considers to be advantageous for clients. As explained in the “Brokerage Fees, Security Fees,
and Other Fees” section above, ETFs, ETNs, mutual funds, and other financial products often
charge a fee out of the assets invested in those products. The fees payable to ETFs, ETNs, mutual
funds, and other financial products are in addition to the management fees payable by a client to
QuantStreet Capital.
The main sources of information that inform QuantStreet’s Model and are used by QuantStreet to
make investment decisions include: financial publications; general economic data; research
materials prepared by others; information provided by corporate rating services; annual reports,
prospectuses, filings with the Securities and Exchange Commission; company press releases and
public communications; direct communications with other market participants; financial and
macroeconomic data sets; financial and general news media; and similar sources.
In addition, QuantStreet uses artificial intelligence tools to assist in monitoring large volumes of
news articles and market commentary. The tools review and summarize news stories and
highlight developments that may be relevant to the asset classes in which the firm invests. The
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news summaries are used as one informational input to QuantStreet’s investment process. The
CIO uses the summaries with the goal of ensuring that he does not miss major news stories that
may impact our investment decisions. If an AI news summary contains information that the CIO
does not already know and the CIO plans to make an investment decision based on such
information, then the CIO first verifies the information using the traditional sources of
information outlined in the prior paragraph.
Risk of Loss
All investment programs have certain risks of loss that investors must be prepared to bear.
QuantStreet Capital’s clients face the following investment risks:
Dependence on CIO: The performance of an investment account at QuantStreet Capital is
critically dependent on the efforts of QuantStreet’s CIO, Harry Mamaysky. In the event of the
CIO’s unavailability or inability to perform his duties, the firm may not be able to operate
effectively. Biographical information about Harry Mamaysky is included in the brochure
supplement at the end of this brochure. Harry Mamaysky devotes the time and effort that he
deems necessary to supervision of QuantStreet Capital investment accounts, but he has other
outside professional responsibilities explained later in this brochure.
investment
process
is
driven
by
Model-Based Risks: QuantStreet’s
an
algorithmically-driven Model developed by the CIO. The Model entails various risks,
including the following: the Model may rely on inaccurate or incomplete information in
making its investment decisions, which would lead the Model to make incorrect investment
decisions; as the CIO updates the Model, a programming mistake, software bug, system
outage, or cybersecurity breach can lead to adverse outcomes; the Model may be overfitted to
historical data and may not perform well during unforeseen market events; the Model often
lacks information about current events, which requires the CIO to impose discretionary
overrides on the Model; and QuantStreet puts self-imposed constraints around the Model and
thereby limits the parameters within which the Model makes investment decisions, which
may reduce flexibility or responsiveness to changing market conditions. For all these reasons,
the Model may cause investment losses. Also, QuantStreet uses machine learning and
artificial intelligence tools to assist in processing large volumes of financial and economic
information, such as summarizing news flow, detecting market patterns, and evaluating risk
exposures. While these tools are intended to enhance analytical capabilities, they are subject
to limitations, including potential biases in training data, overfitting, and misinterpretation of
inputs. QuantStreet’s use of machine learning and artificial intelligence tools may lead to
incorrect conclusions, suboptimal investment decisions, and investment losses.
Target-Date Replication Risk: QuantStreet’s Target-Date Replicating Portfolios are based
on our analysis of publicly available information and historical return relationships. The
resulting portfolios consist of ETFs meant to replicate the average performance of target-date
funds at multiple risk levels rather than the actual holdings of any specific target-date fund.
Because the methodology relies on historical data and statistical relationships, there is no
guarantee that portfolios constructed using prior-period data will accurately track the future
performance of target-date funds; these portfolios may not closely approximate the returns of
target-date funds and may produce materially different and potentially worse results.
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AI News Summary Risk: QuantStreet uses artificial intelligence tools to summarize major
news stories and analyze how they may impact the firm’s investment decisions. These
summaries may contain inaccuracies, omissions, hallucinations, or mischaracterizations of
underlying news reports, and they rely on third party information sources that may
themselves be inaccurate. When making investment decisions, QuantStreet’s CIO uses the
news summaries as one of many reference points, with the goal of ensuring that he has not
missed major news stories that may impact the firm’s investment decisions. If an AI news
summary contains information that the CIO does not already know and the CIO plans to
make an investment decision based on such information, then the CIO first verifies the
information using the traditional sources of information outlined earlier in this section.
QuantStreet also emails these automated news summaries to certain clients who opt in to
receiving them. The summaries are produced without human review, are not individualized
investment advice, and are provided only for informational and educational purposes.
Market Risk: The price of a security may drop in reaction to tangible and intangible events
and conditions. External factors may cause this type of risk regardless of the specific
circumstances relating to a security. For example, political, economic, and social conditions
may influence market conditions. In addition, risks specific to a security may adversely
impact its price. For example, an ETF may have a large concentration in a particular security,
sector, or country at a time when the security, sector, or country experiences adverse events.
Tax Risk in ETFs, Mutual Funds, and Other Investment Products: In some cases, an
ETF, mutual fund, or other investment product will distribute capital gains to shareholders.
These capital-gain distributions are not always desirable, as shareholders are responsible for
paying the capital gains tax. QuantStreet Capital will usually wish to reinvest any
capital-gain distributions. In order to make the reinvestment, QuantStreet Capital will need to
buy more shares in the ETF, mutual fund, or investment product, which may result in
additional fees.
Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar
next year, because the purchasing power of the dollar is eroding at the rate of inflation.
Volatility Risk: Volatility refers to the amount of uncertainty or risk about the magnitude of
changes in the value of a security. High volatility means that the price of a security may be
spread over a large range of possible outcomes and the price of a security may change
dramatically over a short time period. Very large price drops may occur. Many securities
have experienced high volatility and large price drops in recent years. While each of
QuantStreet’s investing strategies is subject to this risk, its more aggressive strategies are
especially prone to volatility risk.
Currency Risk: A security that is not denominated in United States dollars is subject to
fluctuations in the value of the United States dollar against the currency in which the security
is denominated. For example, the dollar value of a security denominated in euros will
decrease if the dollar strengthens against the euro. This type of risk is also called
exchange-rate risk.
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Reinvestment Risk: Future proceeds from investments may be reinvested in government or
corporate bonds at a lower rate of return because of potentially lower future yields.
Business Risk: This risk is associated with a particular industry or a particular issuer. For
example, an oil production company depends upon a lengthy process of finding, transporting,
and then selling oil before the company can generate a profit. As a result, an oil production
company carries a higher risk of profitability variance than an electric utility company, which
generates income from a relatively stable customer base that must purchase electricity
regardless of the economic environment.
Liquidity Risk: Liquidity is the ready ability to convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
U.S. Treasury bills are highly liquid, while real estate is not. Only investors who are
financially able to maintain their investment without a need for immediate liquidity should
consider an investment with QuantStreet Capital.
Structural Risk: QuantStreet Capital invests in ETFs, ETNs, mutual funds, and/or other
investment products that may use leverage, and may invest in financial derivatives. While
QuantStreet does not engage in short-selling, it may have exposures that are similar to
short-selling. ETFs, ETNs, and other investment products are exposed to risks, such as the
inability to post collateral or sufficient capital relative to the size of the underlying positions,
which may force these investments to unwind their positions quickly in unfavorable market
conditions, which may result in large losses to investors.
Financial Risk: Excessive borrowing to finance the operations of a business increases risks
to profitability, because the company is required to repay principal and interest in both good
and bad economic times. During periods of financial stress, the inability of a company to
meet its loan obligations may decrease the value of its securities and, in some cases, force the
company to seek bankruptcy protection.
Risks Related to Public-Health Crises: A future public-health crisis, such as the outbreak
of COVID-19, may have unpredictable and adverse impacts on global, national, and local
economies, which in turn may negatively impact QuantStreet clients and their investment
performance. Such events are difficult to predict and present material uncertainty and risk
with respect to the performance of client investments.
Custodian Risk: While the custodians of QuantStreet’s clients’ funds are well-known and
widely-recognized custodians, there is a risk that such custodian firms will not provide the
services that they promise to QuantStreet’s clients. There is also a risk that one or more
custodians may have financial challenges that would negatively impact clients.
9. Disciplinary Information
This item is not applicable.
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10. Other Financial Industry Activities and Affiliations
Material Relationship to Advisory Business or Clients
In addition to his role as a managing member and CCO of QuantStreet Capital, Isaac Mamaysky
is a partner in a law firm (among other professional commitments outside of the financial
industry, as explained in the “Educational Background & Business Experience” section below).
In addition to his role as a managing member and CIO of QuantStreet, Harry Mamaysky is a
professor at Columbia Business School.
Some of Isaac’s law clients are similar to QuantStreet’s target investors and model portfolio
subscribers. This creates a potential conflict of interest. Isaac may have a financial incentive for
QuantStreet investors to become clients of his law firm and vice versa. If one of QuantStreet’s
investors or subscribers expresses interest in becoming a law client, or if one of Isaac’s law
clients expresses interest in becoming a QuantStreet investor, then any potential conflict will be
promptly disclosed and discussed with the client or prospective client.
All legal services are provided solely through the law firm and not through QuantStreet, which
does not provide legal advice. QuantStreet does not receive any portion of the legal fees charged
by the law firm, and the law firm does not receive any portion of the advisory fees charged by
QuantStreet.
11. Code of Ethics, Personal Trading
Code of Ethics
QuantStreet follows a code of ethics expressing the organization’s commitment to honest,
ethical, and lawful conduct and its prohibition on the use of material nonpublic information,
among various other matters. The code of ethics also includes sections related to compliance
with securities laws, reporting of violations of the code to the CCO, and the distribution of the
code to all supervised persons. To request a copy of the code of ethics, please call or email the
CCO at 212.537.3877 or imamaysky@quantstreetcapital.com.
Trading in Same Securities as Clients
QuantStreet Capital permits its supervised persons to purchase and sell securities for their
personal accounts and for the accounts of individuals who are related to them. Because these
securities may be among those purchased or sold for QuantStreet’s client accounts, conflicts of
interest between QuantStreet Capital and its clients may arise. In general, QuantStreet Capital
seeks to identify and manage any specific conflict of interest by disclosing the conflict and
conferring with the impacted client. Transactions in client accounts and for the accounts of
persons and entities related to QuantStreet may be traded simultaneously to mitigate the conflict
of interest.
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12. Brokerage Practices
Selecting and Recommending Broker-Dealers for Client Transactions
Research and Soft Dollar Benefits
QuantStreet does not maintain custody of client assets that it manages, although QuantStreet may
be deemed to have constructive custody when clients give authority to deduct fees from their
accounts. QuantStreet routinely recommends that its SMA clients custody and broker their
invested funds with Charles Schwab and, more occasionally, Interactive Brokers. QuantStreet
receives certain research and services other than trade execution from the custodians.
Through the custodians, QuantStreet receives access to institutional brokerage services, such as
trading, custodianship, and reporting. The custodian’s support services also include software and
technology that facilitates: client account management and data access (trade confirmations,
account statements, etc.); trade execution, aggregation, and allocation; securities pricing and
other market data; payment of QuantStreet’s fees from client accounts; recordkeeping and client
reporting; and other practice management resources. In addition, the custodians may provide
QuantStreet with investment research.
Receiving these services from the custodians benefits QuantStreet because it does not have to
provide these services itself or pay to receive these services from third parties. This creates an
incentive for QuantStreet to recommend these custodians to clients as both custodians and
broker-dealers, which presents a potential conflict of interest: QuantStreet may choose the
custodians for reasons other than receiving the lowest cost of trade execution.
QuantStreet has a fiduciary duty to act in the best interests of its clients, including an obligation
to seek best execution of client transactions. Best execution involves seeking to execute
securities transactions in a manner that is most favorable to the client under the circumstances,
not necessarily the lowest commission or cost. In selecting the custodians, QuantStreet
considered a range of factors, including execution quality, commission and fee structures,
financial stability, responsiveness, and the availability of research and other brokerage services.
The custodians generally do not charge separately for custody services but are compensated by
client account holders, including through commissions, transaction-related fees for securities
trades executed through them, and the interest charged on margin loans. Such commissions or
fees may be higher than those charged by other custodians/broker-dealers, but QuantStreet has
determined that the amount paid is reasonable in relation to the value of the brokerage and
research services provided by the custodians.
Directed Brokerage
While most QuantStreet SMA clients currently use Schwab as their custodian, and some also use
Interactive Brokers, QuantStreet permits clients to choose their own custodian and broker-dealer.
If a client chooses a different custodian from Schwab or Interactive Brokers, then the client will
establish their own relationship with the custodian by entering into an agreement directly with
the custodian, just as clients currently do with Schwab and Interactive Brokers. QuantStreet
Capital may not be able to accommodate all custodians. When a client directs brokerage,
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QuantStreet may be unable to achieve most favorable execution of client transactions, which
may cost clients more money.
Order Aggregation
QuantStreet often enters trades for multiple client accounts at or around the same time. Each
account receives its own execution and may receive a different execution price, as determined by
the custodian. Because QuantStreet does not aggregate these orders into a single block trade,
clients may receive different execution prices and may not benefit from potential transaction-cost
efficiencies and savings that can accompany aggregated orders.
QuantStreet generally does not aggregate orders into block trades, but it may do so in the future
where it determines that aggregation is appropriate and consistent with its compliance policies
and duty to seek best execution. If a client chooses their own custodian and broker, then
QuantStreet may not be able to aggregate orders, and the client may receive less favorable
pricing.
13. Review of Accounts
Periodic Reviews
For its SMA clients, QuantStreet typically reviews client accounts on a monthly basis and makes
portfolio changes as appropriate. QuantStreet also typically reviews the contents of its model
portfolios on a monthly basis. Such reviews are conducted by Harry Mamaysky.
Review Triggers
Client inquiries, significant changes in market conditions, new investment information, changes
in a client’s financial circumstances, or other events that QuantStreet determines to be material
may prompt more frequent reviews of SMA client accounts or model portfolios.
Regular Reports
In addition to the account statements they receive from Charles Schwab or Interactive Brokers,
SMA clients receive a typically-monthly email newsletter explaining QuantStreet’s analysis of
the markets and how that analysis informs QuantStreet’s investing decisions. This newsletter is
sent to QuantStreet’s then-current mailing list, which includes all clients who have not opted out,
and is not individualized.
Model portfolio subscribers receive a document monthly, alongside the model portfolios,
containing an explanation of that month’s models. QuantStreet makes its model portfolio reports
available to certain SMA clients to provide a deeper explanation of QuantStreet’s investment
decisions made in such clients’ accounts. These reports are not typically individualized.
14. Client Referrals and Other Compensation
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In the future, QuantStreet Capital may pay referral fees or other remuneration in order to receive
client referrals. QuantStreet may establish a relationship with an individual or team that solicits
investment advisers, other institutional clients, or individual investors to retain QuantStreet. In
this case, QuantStreet will likely pay a percentage of AUM for any clients that are referred. Any
such referral or solicitation arrangements will be conducted in compliance with applicable law,
including the SEC’s Investment Adviser Marketing Rule.
15. Custody
Constructive Custody
QuantStreet Capital may be deemed to have constructive custody of client accounts because it is
generally permitted to debit its fees directly from the accounts. All client funds and securities are
held at qualified custodians, which maintain actual custody of client assets.
Account Statements
Clients are provided account statements at least quarterly by Charles Schwab or Interactive
Brokers. The account statements are sent directly to each client by postal mail or delivered
electronically. Clients should carefully review these statements when they are received.
16. Investment Discretion
QuantStreet generally accepts discretionary authority to manage securities accounts on behalf of
its SMA clients. QuantStreet generally has the authority to determine, without obtaining client
consent, the securities to be bought or sold and the quantity of securities to be bought or sold. In
the uncommon event that QuantStreet does not have such authority from a particular client, or a
client has otherwise limited QuantStreet’s trading authority, QuantStreet consults with the client
prior to each applicable trade to obtain authority.
17. Voting Client Securities
Proxy Voting
QuantStreet Capital’s authority to vote proxies depends on the terms of each client’s investment
management agreement. Some clients have agreements under which they retain responsibility for
receiving and voting all proxies, and QuantStreet does not accept authority to vote proxies for
those clients. For those clients, QuantStreet does not monitor for proxy solicitations, notify
clients of any proxy materials received, or take any action with respect to proxy materials.
Some clients have agreements that grant QuantStreet authority to vote proxies relating to
securities held in their accounts. Although this authority exists, QuantStreet Capital has informed
these clients of its policy not to vote proxies unless a client provides written instructions
directing QuantStreet to vote a particular proxy and specifying how that proxy should be voted.
Absent such written instructions, clients retain responsibility for receiving and voting all proxies,
and QuantStreet does not monitor for proxy solicitations, notify clients of any proxy materials
received, or take any action with respect to proxy materials.
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If a client instructs QuantStreet to vote a proxy and provides written voting instructions, then
QuantStreet follows those instructions exactly and does not substitute its own judgment. To the
extent a matter to be voted upon presents a potential conflict between the interests of the client
and those of QuantStreet Capital, the firm will disclose the conflict to the affected client and will
follow the client’s written voting instructions.
Clients may request information regarding any proxies voted on their behalf and may request a
copy of QuantStreet Capital’s proxy voting policies. QuantStreet Capital will maintain records of
proxy voting activities (if any) and provide them to clients upon request.
18. Financial Information
This item is not applicable.
19. Requirements for State-Registered Advisers
This item is not applicable.
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S1. Brochure Supplement Cover Page
BROCHURE SUPPLEMENT
EBH CAPITAL MANAGEMENT LLC
doing business as QuantStreet Capital
1333A North Avenue, Suite 743
New Rochelle, New York 10804
www.quantstreetcapital.com
This brochure supplement provides information about Harry Mamaysky and Isaac Mamaysky
that supplements the QuantStreet Capital brochure. You should have received a copy of that
brochure. Please contact Isaac Mamaysky by telephone at 212.537.3877 or by email at
imamaysky@quantstreetcapital.com if you did not receive QuantStreet Capital’s brochure or if
you have questions about the contents of this supplement.
Additional information about Harry Mamaysky and Isaac Mamaysky is available on the SEC
website at www.adviserinfo.sec.gov.
March 2026
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S2. Educational Background & Business Experience
Harry Mamaysky
Born 1971
Brown University, BS in Computer Science and BA in Economics, 1992
Brown University, MS in Computer Science, 1994
Massachusetts Institute of Technology, PhD in Financial Economics, 2000
Harry Mamaysky founded QuantStreet Capital in 2021 and has been a managing member since
its inception. Since 2016, he has been a professor at the Columbia Business School, where he
currently works alongside his role at QuantStreet. From 2015 to 2016, Harry was a visiting
research scholar and adjunct professor at the Columbia Business School. From 2008 to 2014, he
was a managing director at Citigroup Global Markets Inc.
Isaac Mamaysky
Born 1982
University of Rhode Island, BA in Philosophy, summa cum laude, 2005
Boston University School of Law, JD, cum laude, 2008
Isaac Mamaysky cofounded QuantStreet Capital and has been a managing member since 2022.
He oversees compliance and operations. In addition to his role at QuantStreet, Isaac is a partner
at Potomac Law Group PLLC (since 2019), an adjunct professor at the Elisabeth Haub School of
Law at Pace University and previously at Albany Law School (since 2020), and a founder and
executive director of CZ Wellness Group, Inc. (d/b/a Camp Zeke) (since 2012).
S3. Disciplinary Information
This item is not applicable.
S4. Other Business Activities
Isaac Mamaysky is an attorney at a law firm called Potomac Law Group PLLC and an officer
and executive director of a nonprofit called Camp Zeke. These activities provide a substantial
portion of Isaac’s income and take a substantial amount of his time. Isaac is also an adjunct
professor at the Elisabeth Haub School of Law at Pace University, which represents an
insubstantial amount of his time and income. The potential conflicts between Isaac’s legal work
and his work at QuantStreet are disclosed in the “Other Financial Industry Activities and
Affiliations” section above.
Harry Mamaysky is a professor of finance, which provides a substantial portion of Harry’s
income and takes a substantial portion of Harry’s time.
S5. Additional Compensation
This item is not applicable.
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S6. Supervision
Currently, Harry Mamaysky and Isaac Mamaysky are the only supervised persons of QuantStreet
Capital. QuantStreet is a family-run firm owned and managed by its two principals, who are
brothers. Harry Mamaysky generally provides investment advice to clients, and Isaac Mamaysky
generally oversees firm operations and compliance. Each managing member has authority to
supervise the other, and supervision is carried out on an ongoing basis. QuantStreet may add
additional supervised persons in the future, including through its new adviser affiliation program
described in the firm brochure. Any future supervised persons will be subject to QuantStreet’s
written supervisory procedures and compliance oversight by the CCO. Questions relating to the
supervision of QuantStreet Capital personnel may be directed to Isaac Mamaysky at
212.537.3877.
S7. Requirements for State-Registered Advisers
This item is not applicable.
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