A. Firm Information
Bull Harbor Capital LLC (“BHC” or the “Adviser”) is a registered investment adviser with the U.S.
Securities and Exchange Commission (“SEC”). BHC is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Maryland. BHC was founded in November 2022, and is owned
by CRJ Financial Holding, LLC, L3RIA, LLC, T4G Management, LLC, Kenneth Brodkowitz (Chief
Investment Officer), and Robert Herman (Chairman). Sean Joiner (President) owns CRJ Financial
Holding, and Lloyd Polmateer (CEO) owns L3RIA, LLC, and T4G Management LLC is owned by the
4100 Group Inc. Candy Palugi is the Firm’s Chief Compliance Officer. This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory business
provided by BHC.
Certain Investment Adviser Representatives (“IAR”) market and deliver advisory services under a
practice name or “doing business as”, whose names and logos may appear on marketing materials
as approved by BHC, or client statements approved by the custodian. It is important to note that,
in certain cases, the businesses are legal entities of the IARs and are never legal entities of BHC or
the custodian. However, the IARs are Independent Contractors with BHC and advisory services are
provided exclusively through BHC.
B. Advisory Business Offered
BHC offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, charitable organizations, and retirement plans (each referred to as a “Client”).
Investment Management Services
BHC provides customized investment advisory solutions for its Clients. This is achieved through
personal Client contact and interaction while providing continuous discretionary investment
management and related advisory services. In certain instances, BHC may provide its services on
a non-discretionary basis. As a discretionary investment adviser, BHC will have the authority to
supervise and direct the portfolio without prior consultation with the Client. Clients who choose a
non-discretionary arrangement must be contacted prior to the execution of any trade in the
account(s) under management. This may result in a delay in executing recommended trades, which
could adversely affect the performance of the portfolio. This delay also normally means the
affected account(s) will not be able to participate in block trades, a practice designed to enhance
the execution quality, timing and/or cost for all accounts included in the block. In a non-
discretionary arrangement, the client retains the responsibility for the final decision on all actions
taken with respect to the portfolio.
BHC works with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. BHC will then construct a
portfolio utilizing mutual funds, exchange-traded funds (“ETFs”), individual public and/or private
equity and fixed income securities. The Adviser may also utilize covered options and other types
of investments, as appropriate, to meet the needs of a particular Client.
BHC’s investment strategy is primarily long-term focused, but the Adviser may buy, sell, or re-
allocate positions that have been held less than one year for reasons that include, but are not
limited to: changes in Client objectives; account inflows/outflows; security fundamentals and/or
market conditions. The first step of the BHC investment process is to determine the strategic asset
allocation targets. Once BHC establishes the long-term framework, it’s determined if the Adviser
should tactically adjust the allocation targets based on the current market environment and short-
term economic outlook. BHC will construct, implement, and monitor the portfolio in connection
with the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client
will have the opportunity to place reasonable restrictions on the types of investments to be held in
their respective portfolio, subject to acceptance by the Adviser.
BHC evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. BHC may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. BHC may recommend specific positions to increase sector or
asset class weightings. The Adviser may recommend employing cash positions as a possible hedge
against market movement. BHC may recommend selling positions for reasons that include, but are
not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio,
change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
BHC will provide investment advisory services and portfolio management services and will not
provide securities custodial or other administrative services. At no time will BHC accept or
maintain custody of a Client’s funds or securities, except for authorized deduction of the Adviser’s
fees. All Client assets will be managed within their designated account at the Custodian, pursuant
to the terms of the investment advisory agreement.
Portfolio Management accounts will be custodied at Fidelity (“Fidelity”) or Interactive Brokers
(“IB”).
Financial Planning Services
BHC will typically provide a variety of financial planning services to Clients, pursuant to a written
financial planning agreement. Services are offered in a variety of areas and are often tailored to the
Client’s needs, goals, and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a
financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including, but not limited to investment
planning, retirement planning, personal savings, education savings and other areas of a Client’s
financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include
general recommendations for a course of activity or specific actions to be taken by the Client. For
example, recommendations may be made that the Client start or revise their investment programs,
commence, or alter retirement savings, establish education savings and/or charitable giving
programs. BHC may also refer Clients to an accountant, attorney, or another specialist, as
appropriate for their unique situation. For certain financial planning engagements, the Adviser will
provide a written summary of Client’s financial situation, observations, and recommendations. For
consulting or ad-hoc engagements, the Adviser may not provide a written summary.
Financial planning and consulting recommendations may pose a potential conflict between the
interests of the Adviser and the interests of the Client. For example, a recommendation to engage
the Adviser for investment management services or to increase the level of investment assets with
the Adviser would pose a conflict, as it would increase the advisory fees paid to the Adviser. Clients
are not obligated to implement any recommendations made by the Adviser or maintain an ongoing
relationship with the Adviser. If the Client elects to act on any of the recommendations made by the
Adviser, the Client is under no obligation to execute the transaction through the Adviser.
Retirement Plan Advisory Services
BHC provides non-discretionary retirement plan advisory services for retirement plans (each a
“Plan”) and the sponsor of the Plan (the “Plan Sponsor”). The Adviser’s retirement plan advisory
services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan.
Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally
include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Support
• Investment Management
• Performance Reports
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Certain of these services are provided by BHC serving in the capacity as a fiduciary under the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with
ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of BHC‘s fiduciary
status, the specific services to be rendered and all direct and indirect compensation the Adviser
reasonably expects under the engagement.
Retirement Plan Rollover Recommendations
To the extent we recommend you roll over your account from a current retirement plan to an
individual retirement account (“Rollover IRA”), managed by BHC please know that BHC and our
investment adviser representatives may have a conflict of interest. We can earn increased
investment advisory fees by recommending that you roll over your account at the retirement plan
to a Rollover IRA managed by BHC. We will earn fewer investment advisory fees if you do not roll
over the funds in the retirement plan to a Rollover IRA managed by BHC. Thus, our investment
adviser representatives have an economic incentive to recommend a rollover of funds from a
retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that
you open an IRA account to be managed by our Firm can be based on our economic incentive and
not based exclusively on whether or not moving the IRA to our management program is in your
overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to a
retirement plan participant regarding a rollover of funds from the retirement plan in accordance
with the fiduciary status described below, (ii) not recommend investments which result in BHC
receiving unreasonable compensation related to the rollover of funds from the retirement plan to
a Rollover IRA, and (iii) fully disclose compensation received by BHC and all persons associated
with BHC (our “Supervised Persons”) and any material conflicts of interest related to
recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from
making any materially misleading statements regarding such rollover.
When making a rollover recommendation BHC is serving in the capacity as a fiduciary under the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
Use of Independent Managers
BHC will at times recommend that Clients utilize one or more investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a client’s investment
portfolio, based on the Client’s needs and objectives. Factors
that BHC considers in
recommending/selecting Independent Managers generally include the Client’s stated investment
objective(s), management style, performance, risk level, reputation, financial strength, reporting,
pricing, and research.
In certain instances, the Client will be required to authorize and enter into an investment
management agreement with the Independent Manager(s) that defines the terms in which the
Independent Manager(s) will provide its services. In other cases, BHC retains the authority to
terminate the Independent Manager’s relationship or to add new Independent Managers without
specific Client consent. In any case, the Firm will perform initial and ongoing oversight and due
diligence over each Independent Manager to ensure the strategy remains aligned with Client’s
investment objectives and overall best interest. BHC will also assist the Client in the development
of the initial investment objectives and managing the ongoing Client relationship. The Client, prior
to entering into an agreement with an Independent Manager, will be provided with the
Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the
appropriate disclosures).
Co-Advisory Arrangement with Matson Money, Inc.
BHC has entered into a co-advisory agreement (the “Co-Advisory Agreement”) with Matson Money,
Inc. (“Matson”), an SEC registered investment adviser. When appropriate and in accordance with
a Client’s investment plan, BHC will recommend that the Client engage the co-advisory services of
Matson and BHC.
In such a situation, the Client, BHC, and Matson will enter into a tri-party investment management
agreement (the “Investment Management Agreement”), pursuant to which BHC is responsible for
selecting an appropriate and suitable investment model for the Client based on the Client’s
investment objectives, risk tolerance, financial situation, time horizon, current investments, and
financial goals. Matson is granted discretionary trading authority to invest the assets in the Client’s
portfolio, which are typically invested in one or more series of the mutual fund RBB Fund, Inc.,
including the Free Market U.S. Equity Fund, Free Market International Equity Fund and Free Market
Fixed-Income Fund (collectively, the “Matson Funds”). Each Matson Fund is a “fund of funds”,
which invests primarily in shares of no-load mutual funds managed by Dimensional Fund Advisors
(“DFA”) based on the investment characteristics specified by Matson and described in the Matson
Funds prospectus. Each Matson Fund is designed to target specified percentages of certain asset
classes in the Matson Fund’s applicable investment category to seek maximum portfolio
diversification, enhanced return potential and diminished portfolio volatility. Matson reserves the
right, in its sole discretion, to create and allocate assets in client accounts to additional funds
managed by Matson in the future. Matson may also invest Client assets in unaffiliated cash sweep
vehicles for temporary or other defensive purposes. More complete information is available in
each applicable Matson Fund prospectus.
In addition, BHC will provide certain ongoing advisory services to the Client in accordance with the
Co-Advisory Agreement. The Client will have the authority to retain the co-advisory services of
BHC and Matson and to terminate the Investment Management Agreement with BHC and Matson.
IARs of BHC who wish to offer the tri-party Investment Management Agreement with Matson to
their Clients and thereby participate in the Matson advisory program are required to pay a one-
time fee to Matson in the amount of $10,000. The fee includes educational and training courses,
some of which are required by Matson prior to permitting participation in the program. Matson
also requires IARs to enter into tri-party Investment Management Agreements with Matson on
behalf of BHC with respect to at least $100,000 of Client assets within the first year of participation
in the program. If this minimum is not met, Matson reserves the right to terminate its relationship
with the IAR, which may include terminating any Investment Management Agreements where such
IAR is the signatory and requiring affected Clients to work with a different IAR. As the amount of
assets managed pursuant to a tri-party Investment Management Agreement increases, the amount
of marketing assistance provided to each applicable IAR increases, at no additional cost. Therefore,
Phone: (301) 907-9030
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BHC IARs who offer the Matson advisory programs have an incentive to select Matson over another
program. BHC IARs will continue to review Client portfolio for program suitability and will retain
responsibility for an annual review of Client accounts.
Sub-Advisory Relationship with Gries Financial LLC
BHC has entered into a sub-advisory agreement (the “Sub-Advisory Agreement”) with Gries
Financial LLC (“Gries”), an SEC registered investment adviser under common control with BHC.
Pursuant to the Sub-Advisory Agreement, BHC may be engaged by Gries to provide discretionary
investment advisory services to certain portions of the portfolios of specified clients of Gries. BHC
and Gries share a Chief Investment Officer, as further described below, and the Chairman of BHC is
the CEO of Gries. BHC and Gries are also affiliated through TG4 Financial Services, LLC, which owns
Gries and is a minority owner of BHC.
Shared Services Agreement with Gries Financial LLC
BHC also has a shared services agreement in place with Gries, an adviser under common control
with BHC. When appropriate for a client, we will utilize Gries to provide personalized or model
investment portfolios to our clients. When Gries Chief Investment Officer Services (“CIO Services”)
are utilized by one of our Clients, the Client will pay a fee for these services up to a maximum of 15
basis points on the assets under management. This fee is in addition to our investment advisory
fee. All fees are disclosed in the investment management agreement signed by the client.
AssetMark, Inc. Platform Arrangements
BHC has entered into two separate agreements with AssetMark, Inc. (“AssetMark”). AssetMark is
an SEC registered investment adviser that has developed the AssetMark Platform (the “AssetMark
Platform”). The AssetMark Platform consists of certain investment solutions and tools to help
investment advisers provide advisory services to their clients. The two agreements that BHC has
in place with AssetMark are: (i) a platform agreement, and (ii) a solicitation agreement. When
appropriate and in accordance with a client’s investment plan, BHC will recommend that the client
engage the services of AssetMark, as more specifically set forth below.
Platform Agreement
Under the platform agreement, BHC will utilize the AssetMark Platform to help manage the client’s
assets. The AssetMark Platform contains various investment solutions, each of which includes one
or more investment strategies. The investment solutions offered through the AssetMark Platform
will generally be based on model portfolios or managed by discretionary managers. In addition,
the AssetMark Platform provides certain administrative and other services, including, but not
limited to, training and business consulting services, marketing support, preparation of
individualized client materials, and the arrangement of custodial, brokerage, and related services
on behalf of the client.
In such a situation, the client will enter into a client services agreement (the “Client Services
Agreement”) with BHC, pursuant to which BHC will be responsible for selecting an appropriate and
suitable investment solution and investment strategy offered through the AssetMark Platform for
the client based on the client’s investment objectives, risk tolerance, financial situation, time
horizon, current investments, and financial goals. Under this arrangement, BHC is granted
discretionary trading authority to invest the assets in the client’s portfolio pursuant to the selected
investment solution and investment strategy offered through the AssetMark Platform. The total
fee payable is set forth in the Client Services Agreement.
Solicitation Agreement
Under the solicitation agreement, BHC will recommend that a client engage the investment
advisory services of AssetMark. In such a situation, the client will enter into an investment advisory
agreement with AssetMark, and AssetMark will have discretionary trading authority to invest the
assets in the client’s portfolio. However, BHC will provide certain ongoing services, including
conducting an annual review of the client’s account to determine whether there have been any
changes to a client’s financial situation or investment objectives and whether the client would like
to impose reasonable restrictions on the management of his, her, or its assets and/or modify any
existing conditions on such assets. In exchange for introducing the client to AssetMark and for the
ongoing services provided by BHC, BHC receives initial and ongoing compensation from AssetMark.
The amount of such compensation is negotiated by BHC and AssetMark in each case. The initial
compensation is paid to BHC by AssetMark when contributions in excess of $2,000 are made to
client accounts, and ongoing compensation is paid to BHC by AssetMark on the basis of the value
of the client’s account. Additionally, BHC may receive additional fees from AssetMark depending
on the investment solutions selected for a particular client. In such a case, the additional fee may
be deducted from the client’s account by AssetMark and paid to BHC.
C. Client Account Management
Prior to engaging BHC to provide investment advisory services, each Client is required to enter into
one or more agreements with the Adviser that define the terms, conditions, authority and
responsibilities of the Adviser and the Client. These services may include:
• Establishing an Investment Strategy – BHC, together with the Client, will develop an
investment strategy targeted to achieve the Client’s investment goals and objectives.
• Asset Allocation – BHC will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance of risk for each Client.
• Portfolio Construction – BHC will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – BHC will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Assets Under Management
As of December 31, 2023, BHC has approximately $173,000,000 total assets under management.
The Firm manages approximately $50,000,000 on a discretionary basis and $123,000,000 on a
non-discretionary basis.