A. DESCRIPTION OF THE ADVISORY FIRM.
Haverdink Financial Management, LLC (“Haverdink Financial Management” or “Adviser”)
has been in the investment advisory business since May 2004. The Adviser is registered
with and regulated by the United States Securities and Exchange Commission.
Haverdink Financial Management is 100% owned by The Kevin and Laura Haverdink
Revocable Trust. Kevin Haverdink is trustee and the Adviser’s President and Chief
Compliance Officer. Mr. Haverdink is registered as an Adviser Representative of the
Adviser. Laura Haverdink is trustee and holds the titles of Vice-President, Secretary and
Treasurer. Ms. Haverdink provides professional administration services and does not
engage in providing financial or investment advisory services.
B. TYPES OF ADVISORY SERVICES
Haverdink Financial Management, LLC, (“Haverdink Financial Management” or the
“Adviser”), is a fee only Registered Investment Adviser. The term “fee only” means that
Haverdink Financial Management and its Adviser Representatives do not accept
commissions in connection with securities or insurance recommendations. Haverdink
Financial Management is only compensated for advisory services via a percentage of
assets under management; hourly fees or project-based fees depending upon the
services requested and scope of the engagement. The Adviser is a fiduciary to each of
its clients.
“Adviser Representatives” are those persons authorized by the firm to deliver financial
and investment advisory services. Adviser Representatives of Haverdink Financial
Management are not registered representatives of a broker/dealer and the
Representatives are not insurance agents.
The Adviser is not a broker/dealer or custodial firm. All transactions in securities will be
executed by an unaffiliated custodial firm of clients’ choosing.
Haverdink Financial Management may offer a complimentary general consultation to
discuss services available, to give a prospective client time to review services desired,
and to determine the possibility of a potential Client-Adviser relationship. Services begin
only after the client and Adviser formalize the relationship with a properly executed
Client Agreement.
After the formal engagement and depending upon the scope of the engagement, the
Adviser and client will share in a data gathering and discovery process in an effort to
determine the client’s needs, goals, intentions, time horizons, risk tolerance and
investment objectives, based upon information provided by the client and the nature of
services requested. The client and Adviser may complete a risk assessment,
investment policy statement or similar document, depending upon the nature of services
to be provided.
Haverdink Financial Management offers Investment Management, Financial
Planning, and General Consultation Services. On occasion, the Adviser may also
offer General Education Seminars or Workshops.
1. Investment Management Services are ongoing in nature, focus solely on portfolio
management, and do not include financial planning services or consultation services
outside the scope of the managed investments.
2. Financial Planning Services are hourly or project-based services and generally
terminate upon the delivery of services unless otherwise agreed in writing.
3. Consultation Services are hourly or project-based services and generally terminate
upon the delivery of services unless otherwise agreed upon in writing.
4. General Education Seminars and Workshops are individual general education
opportunities in connection with investment management and/or financial planning
topics. The content is general in nature and does not constitute individualized services.
Participants are welcome but are never obligated to contact the Haverdink Financial
Management for advisory services.
1. Investment Management Services involve ongoing and continuous portfolio
management. Haverdink Financial Management focuses on providing individualized
services that are tailored to meet the stated needs and objectives of the client. In the
delivery of initial and ongoing services and based upon the client’s level of participation,
the Adviser will normally include a comprehensive review of the overall aspects of a
client’s current financial situation and consider both long and short-term objectives and
goals, or as directed by the client.
Clients engaging in Investment Management Services must play an active role. The
Adviser requires the client to participate in the financial and investment review; the
development of an investment policy or similar document, if applicable; the development
of the investment plan to be followed; as well as participation in reviews and the ongoing
advice and recommendations.
Depending on the nature of the services to be provided, Haverdink Financial
Management generally develops and utilizes an asset allocation model that is consistent
with the client’s desired rate of return, time horizon and risk tolerance. Haverdink
Financial Management can design and implement a portfolio or assist with the
implementation. Where a portfolio has been designed by the client or another party,
Haverdink Financial Management will provide recommendations for re-design,
adjustments or re-balancing.
Once the portfolio has been implemented or transferred for services, Haverdink Financial
Management can provide continuous monitoring, recommendations and investment
advice as outlined in the engagement for services. The ongoing Investment Management
Services is based upon a targeted asset allocation agreed upon between Haverdink
Financial Management and the client. In providing ongoing Investment Management
Services, the Adviser will manage investor funds in accordance with an investment plan
as selected by the client and the Adviser will remain available for ongoing advice and
recommendations. The Adviser will monitor the portfolio in accordance with the directives
provided. Investment Management Services are continuous in nature and thus are
ongoing until terminated by either party.
Haverdink Financial Management can tailor services to focus only on certain portfolio
components or the Adviser can provide comprehensive portfolio management services,
depending upon the client’s wishes and/or the nature of the engagement.
The Adviser welcomes the opportunity to provide individualized services. However,
where investment management services or information are limited, clients must
understand that comprehensive investment needs and or objectives may not be fully
considered due to the client’s option not to receive limited services, the lack of
information received, and/or client disclosure.
Investment Management Services generally begin with an initial data-gathering interview
in an effort to determine the client’s stated individual needs, goals, time horizons and
risk tolerance. Haverdink Financial Management utilizes the information provided by the
client to prepare recommendations for investments, which may include planning for long-
range goals (i.e., retirement planning or college funding) or other segments of an
investment plan that may be desired.
After an analysis and data-gathering process and depending upon the nature of services
desired, the Adviser may prepare reviews, analysis, asset allocation recommendations,
and may recommend specific investments.
Unless otherwise directed by the client, Haverdink Financial Management will generally
seek to allocate a client’s assets among various investments, taking into consideration
the client’s strategic portfolio framework developed with clients. The Adviser attempts to
construct a diversified portfolio of investment recommendations that are within its realm
of expertise. In each case, the stated individual needs, goals and desires of clients are
taken into consideration.
While Haverdink Financial Management will typically recommend investments in mutual
funds, index funds, exchange traded funds, individual equities, U.S. government
securities, municipal bonds, and other fixed-income securities. The Adviser will generally
seek to allocate the client’s assets among various investments, taking into consideration
the overall management style and portfolio framework selected by the client. The
Adviser attempts to construct a diversified portfolio of investment recommendations that
are within its realm of expertise. In each case, the stated individual needs, goals and
desires of clients are taken into consideration.
Depending on the needs of a client, the Adviser may also evaluate or offer advice on
variable life and annuities, but the Adviser does not engage in sales of these types of
products. In addition, if requested and based upon information provided by the client, the
Adviser can prepare an evaluation of existing portfolio investments and provide
recommendations for other investments as deemed appropriate. While the Adviser may
offer general advice on partnership investments, including hedge funds, private limited
partnerships, etc., the services provided to private investments are limited to
consultation regarding the investment opportunity and a review of the offering
documents versus the management of partnership investments, unless specifically
agreed to in writing.
Services and investment recommendations in connection to assets invested in corporate
retirement plans are limited to those offered within the plan and via the plan’s contracted
service providers.
Clients engaging in investment advisory services are expected to play an active role.
The Adviser requires the client to participate in the formation of the investment plan, the
development of investment advice and recommendations and the ongoing services
provided.
Clients may call the office during regular business hours to discuss their portfolio or ask
questions, but the Adviser recommends that clients initiate a meeting with the Adviser no
less than annually. However, clients are obligated to immediately inform the Adviser of
any changes in their financial situation to provide the Adviser with the opportunity to
review the portfolio to ensure it is still structured to help meet the client’s stated needs
and objectives.
The services provided by the Adviser are based upon the client’s stated individual needs
and objectives. In providing ongoing Investment
Management Services, Haverdink
Financial Management will manage investor funds in accordance with an investment
policy/strategy or plan as selected by the client and the client’s written directives. The
Adviser will remain available for ongoing advice and recommendations throughout the
engagement.
If services desired go outside the scope of Investment Management Services, the
Adviser may be available to provide Consultation and/or Financial Planning Services. In
such cases, the Adviser may request a new or amended Client Agreement and
additional fees will apply. The Adviser will not engage in additional services without the
client’s direction.
2. Financial Planning Services involve hourly or project-based services that may be
comprehensive in nature or the services can be tailored to address one or more
components of financial planning. Advice may be provided on issues relating to
retirement planning, cash flow analysis, sponsored benefit determination, business
owner issues, education funding, employee benefit issues, major purchases, and risk
management planning. The services requested may include short-term and/or long-term
goal planning as directed by the client.
The Adviser can tailor services as desired by the client. Financial Planning Services may
be general in nature or can be focused on particular areas of interest or components of
planning rather than on comprehensive planning, depending upon the client’s needs.
The services to be provided and the Adviser’s fee(s) are agreed upon at the time of
engagement. As part of the Adviser’s policy toward full disclosure, advisory fees are
outlined in advance and in writing before any services are performed.
This policy assures that the client’s affairs will be evaluated objectively and in a cost-
effective manner. The Adviser reserves the right to increase or decrease the rate or
amount of the fee with the consent of the client, based upon individual circumstances,
complexities, additional services requested, or a modification in the nature and scope
of services.
When Financial Planning Services only focus on certain areas of client interests, needs
or is otherwise limited, clients must understand that a client’s overall financial and
investment needs, liabilities and objectives may not be considered as a result of time
and/or service restraints placed on the Adviser’s services. Clients requiring assistance
on issues relating to matters outside of financial and investment advisory topics should
consult their personal tax adviser, legal counsel, or other professionals for expert
opinions.
When providing a review or advice on investments within retirement plans, the advice
and any recommendations are limited to plan offerings and the service provider(s)
selected by the plan providers.
Implementation of any advice or recommendations pertaining to securities or non-
securities matters, in whole or in part, is entirely at the client’s discretion via the service
provider(s) of the client’s choice.
Financial Planning Services generally utilize long-term strategies so that continuous
monitoring is not required. The advice provided by the Adviser may include
recommendations for updates and reviews. Clients are welcome but are never obligated
to retain the Adviser for additional or follow-up services. Where additional or new
services are desired, Haverdink Financial Management may require an amended or new
client agreement.
Financial Planning Services will not include any portfolio monitoring, investment reviews
or investment management. Investment Management Services may be available via a
new client agreement.
3. Haverdink Financial Management is available to provide Consultation Services on
an hourly or project basis. Advice may be provided on general issues relating to
investments, portfolios, or other issues of interest to clients. The Adviser can tailor
services as desired by the client. Consultation Services are not comprehensive in nature
in that services only focus on certain areas of client interests, needs or is otherwise
limited. Therefore, clients must understand that a client’s overall financial and investment
needs and objectives may not be considered as a result of time and/or service restraints
placed on the Adviser’s services. The services provided terminate upon delivery unless
otherwise agreed in writing. The advice provided by the Adviser may include
recommendations for updates and reviews and the client’s responsibility to follow-up and
secure additional services under a new or amended agreement.
Adviser Representatives may suggest the client work closely with the client’s attorney,
accountant, insurance agent, and the client’s custodian. Clients requiring assistance on
issues relating to matters outside of investment advisory topics should consult their
personal tax Adviser, legal counsel, or other professionals for expert opinions.
Implementation of any advice or recommendations pertaining to securities and/or
non-securities matters, in whole or in part, is entirely at the client’s discretion via the
service provider(s) of the client’s choice.
When providing a review or advice on investments within retirement plans, the advice
and any recommendations are limited to plan offerings and the service provider(s)
selected by the plan providers.
The advice provided by the Adviser may include recommendations for updates and
reviews and these services can be obtained under a new or amended agreement at the
client’s discretion.
Consultation Services will not include any portfolio monitoring, reviews, follow-ups, or
other services. If additional or new services are desired, clients are welcome to secure
these services via a new or amended agreement. Investment Management Services
may also be available via a new client agreement.
4. Haverdink Financial Management may also conduct general Educational
Workshops and Seminars on topics relating to investment management or financial
issues. The presentations will provide general information only. Participants are never
obligated but are welcome to seek out individualized services from the Adviser.
From time to time, the Adviser may charge a fee for Educational Workshops or
Seminars, depending upon the nature of services, complexity of content, materials
provided, location, or at the discretion of the Adviser. All fees and the Adviser’s
cancellation policy (and refund policy, if applicable) will be clearly noted in the offering
document or invitation.
C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
Haverdink Financial Management focuses on providing individualized services. The
Adviser can tailor services to focus only on certain portfolio components, depending
upon the client’s wishes and/or the nature of the engagement. However, where client
services or information are limited, clients must understand that comprehensive financial
and/or investment needs and objectives may not be fully considered due to the client’s
option to receive limited services, the lack of information received, and/or client
disclosure.
The Adviser and client will share in a data gathering and discovery process in an effort to
determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and
investment objectives, based upon information provided by the client and the nature of
services requested.
The client and Adviser may complete a risk assessment, investment policy statement or
similar document, depending upon the nature of services to be provided. Clients may not
impose reasonable restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs unless otherwise agreed by the Adviser in writing.
Clients are welcome to set parameters on the Adviser’s limited discretionary authority in
writing as to types of investments and amounts purchased or sold.
Retirement Plan Rollovers: Haverdink Financial Management is a fiduciary to each of
its clients and fiduciary duties apply to investment advice in connection with your
retirement plan account or individual retirement account within the meaning of Title I of
the Employee Retirement Income Security Act and the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way our firm earns
compensation (asset-based fees for managed accounts) creates some conflicts with
your interests, Therefore, we must operate under a special rule that requires us to act in
your best interest and not put our interests ahead of yours. At the time of a rollover
recommendation, we will provide you with a written disclosure discussing the reasons
the rollover is in your best interests. Also, under this special rule’s provisions, we must:
* Meet a professional standard of care when making investment recommendations
(give prudent advice).
* Never put our financial interests ahead of yours when making recommendations
(give loyal advice).
* Provide basic information about conflicts of interests and fees while avoiding
misleading statements about these topics and investments
* Follow policies and procedures designed to ensure that we give advice that is in
your best interest.
* Charge no more than is reasonable for our services
Where clients retain authority to implement recommendations, they are welcome to
implement advice and recommendations, in whole or in part, via the financial services
provider(s) of their choice. Certain clients may engage in client-directed transactions
(investing on their own) and in such cases, the Adviser will not provide investment
suitability and/or due diligence reviews or ongoing management services for these types
of investments unless specifically agreed in writing. In the event the Adviser agrees to
complete a client-directed transaction (as requested by a client), it will do so only as a
value-added service for the client.
D. WRAP FEE PROGRAMS
Haverdink Financial Management does not participate in recommending wrap fee
programs nor does the Adviser sponsor or act as a manager of a wrap fee program.
E. AMOUNTS OF ASSETS UNDER MANAGEMENT
Haverdink Financial Management’s assets under management as of the close of
business on 12/31/2023, totaled $171,296,000 in 472 limited discretionary accounts.
The managed assets are owned by individual investors and those meeting the
definition of high-net-worth investors.