Colarion is an SEC registered investment adviser and is a limited liability company (LLC) formed under
the laws of the State of Alabama.
• Samuel Haskell is the Managing Member and 100% owner of Colarion.
• Colarion filed its initial application to become registered as an investment adviser in May 2017.
Introduction
The investment advisory services of Colarion are provided to you through an appropriately licensed and
qualified individual who is an investment adviser representative of Colarion (referred to as your investment
adviser representative throughout this brochure).
Description of Advisory Services
The following are descriptions of the primary advisory services of Colarion. Please understand that a
written agreement, which details the exact terms of the service, must be signed by you and Colarion, or
assigned, before providing you the services described below.
Asset Management Services – Colarion offers asset management services, which involves Colarion
providing you with continuous and ongoing supervision over your specified accounts.
You must appoint the firm as your investment adviser of record on specified accounts (collectively, the
“Account”). The Account consists of separate account(s) held by qualified custodian(s) under your name. The
qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all
rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and
receive transaction confirmations) of the Account.
The Account is managed based on your financial situation, investment objectives and risk tolerance. The
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firm actively monitors the Account and provides advice regarding buying, selling, reinvesting or holding
securities, cash or other investments in the Account.
We will need to obtain certain information from you to determine your financial situation and investment
objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk
tolerance or investment objective and whether you wish to impose or modify existing investment
restrictions; however, we will contact you at least annually to discuss any changes or updates regarding
your financial situation, risk tolerance or investment objectives. We are always reasonably available to
consult with you relative to the status of your Account. You have the ability to impose reasonable
restrictions on the management of your accounts, including the ability to instruct the firm not to purchase
certain securities.
It is important that you understand that we manage investments for other clients and may give them
advice or take action for them or for our personal accounts that is different from the advice we provide or
actions taken for you. We are not obligated to buy, sell or recommend to you any security or other
investment that we may buy, sell or recommend for any other clients or for our own accounts. We may buy or
sell securities in which Colarion clients may also transact business in.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We
strive
to allocate investment opportunities believed to be appropriate for your account(s) and other
accounts advised by my firm among such accounts equitably and consistent with the best interests of all
accounts involved. However, there can be no assurance that a particular investment opportunity that
comes to our attention will be allocated in any particular manner. If we obtain material, non-public
information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any client or use it for any client’s benefit.
Colarion is advisor to the Mint Financial Sector Fund, LP (“The Mint Partnership”), which uses related but
different strategies in relation to high net worth advisory clients of Colarion LLC. The Mint Partnership
may more proactively participate in private placements or other securities offerings, and more frequently seeks
to hedge the performance of client portfolios.
Limits Advice to Certain Types of Investments
Colarion provides investment advice on the following types of investments:
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Warrants
• Corporate Debt Securities
• Treasury Securities
• Options Contracts on Securities
Although we generally provide advice only on the products previously listed, we reserve the right to offer
advice on any investment product that may be suitable for each client’s specific circumstances, needs,
goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we may increase cash
holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market
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behavior. We may modify my investment strategy to accommodate special situations such as low basis
stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax
situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.)
Tailor Advisory Services to Individual Needs of Clients
Colarion’s advisory services are always provided based on your individual needs. This means, for
example, that when we provide asset management services, you are given the ability to impose
restrictions on the accounts we manage for you, including specific investment selections and sectors. We
work with you on a one-on-one basis through interviews and questionnaires to determine your investment
objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with my investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
Such tailoring to client needs does not apply to partners of the Mint Financial Sector Fund, LP.
Client Assets Managed by Colarion
Colarion advises on approximately $119,901,089 million in discretionary client assets and $6,043,000 in non-
discretionary assets.