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29 South Main St., Ste. 306
West Hartford, CT 06107
860.561.7050
www.yhbia.com
March 11, 2025
Form ADV, Part 2 A
This Brochure provides information about the qualifications and business practices of YHB
Investment Advisors, Inc. (YHB). If you have any questions about the contents of this Brochure,
please contact us at 860.561.7050 and/or www. yhbia.com. The information in this Brochure has
not been approved or verified by the United States Securities and Exchange Commission (SEC) or
by any state securities authority.
YHB Investment Advisors Inc. is a registered investment advisor. Registration of an investment
advisor does not imply any level of skill or training. The oral and written communications of an
advisor provide you with information that helps you determine to hire or retain an advisor.
Additional information about YHB Investment Advisors, Inc. also is available on the SEC’s website at
www.advisorinfo.sec.gov
Item 1 – Cover Page
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Item 2 – Material Changes
There have been no material changes since the last publication of this brochure on August
12, 2024.
Our brochure may be requested by contacting Anne Space at 860.561.7050 or
aspace@yhbia.com. Our brochure is also available on our website www.yhbia.com.
Additional information about YHB Investment Advisors, Inc. is available via the SEC’s
website at www.advisorinfo.sec.gov. The SEC’s website also provides information about
any persons affiliated with YHB who are registered, or are required to be registered, as
investment advisor representatives of YHB.
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Item 3 -Table of Contents
Item 1 – Cover Page .................................................................................................................................................. …i
Item 2 – Material Changes ........................................................................................................................................ii
Item 3 - Table of Contents....................................................................................................................................... iii
Item 4 – Advisory Business ......................................................................................................................................1
Item 5 – Fees and Compensation ..........................................................................................................................2
Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................4
Item 7 – Types of Clients ...........................................................................................................................................4
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..............................................5
Item 9 – Disciplinary Information ........................................................................................................................6
Item 10 – Other Financial Industry Activities and Affiliations ...............................................................7
Item 11 – Code of Ethics ............................................................................................................................................7
Item 12 – Brokerage Practices ..............................................................................................................................9
Item 13 – Review of Accounts ............................................................................................................................. 11
Item 14 – Client Referrals and Other Compensation ................................................................................ 11
Item 15 – Custody ...................................................................................................................................................... 12
Item 16 – Investment Discretion ........................................................................................................................ 13
Item 17 – Voting Client Securities ...................................................................................................................... 13
Item 18 – Financial Information ......................................................................................................................... 14
Item 19 – Requirements for State-Registered Advisors ......................................................................... 14
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Item 4 – Advisory Business
YHB Investment Advisors, Inc. (YHB) was organized in December 1989. YHB is 100%
independently owned and managed. No shareholder has ownership interest exceeding
25%. The owners are actively involved in the ongoing operations and management of the
company. As of December 31, 2024, the firm had discretionary authority of approximately
$1.98 billion of regulated assets under management. Our services are outlined below.
Personal Asset Management Services
YHB provides to clients personalized investment advisory services consisting of:
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Education as to basic investment concepts, policies and disciplines
Recommendations for target allocations, investment markets and product types
Investment policy guidelines
Recommendation, selection, and trade execution of securities
Ongoing asset review and management
Quarterly reports including:
• Account holdings
• Performance data
Quarterly market newsletters
Access to YHB Charitable Endowment, a donor-advised fund
Ongoing availability for questions on investment markets and strategies
Financial/Administrative/Consulting Services
We also provide special analyses, bookkeeping, or other services tailored for individual
circumstances. This may include consulting services to certain clients who are seeking
guidance in a specific area or for a specific purpose, either on a short-term or ongoing basis.
Such consulting may address any of the following areas:
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Establishing investment policy guidelines
Reviewing and selection of managers
Ongoing manager evaluation and review
Aggregated portfolio and performance reporting
Other specialized consulting
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Pension Consulting Services:
The primary clients for these services will be 401(k) and profit-sharing plans. Clients may
choose to use any or all of the following services.
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Investment Policy Guideline (IPG) Preparation: We will meet with the client (in
person or by telecommunication) to determine an appropriate investment
strategy that reflects the plan sponsor's stated investment objectives for
management of the overall plan. Our firm then prepares a written IPG detailing
those needs and goals and the criteria for selection of investment vehicles as
investment monitoring procedures.
Selection of Investment Vehicles: We assist plan sponsors in constructing
appropriate asset allocation models. We will then review various funds (both
index and managed) to determine which investments are appropriate to
implement the client's IPG. The number of investments to be recommended will
be determined by the client.
Monitoring of Investment Performance: We monitor client investments
continually based as outlined in the IPGs. Although in some situations our firm
may not be involved in any way in the purchase or sale of these investments, we
supervise the client's portfolio and will make recommendations to the client as
market factors and the client's needs dictate.
Employee Communications: For profit sharing and 401(k) plan clients with
individual plan participants exercising control over assets in their own account
(''self-directed plans''), we may also provide annual educational support
designed for the plan participants. The nature of the topics to be covered will be
determined by us and the client under the guidelines established in ERISA
Section 404(c). The educational support will NOT provide plan participants with
individualized, tailored investment advice or asset allocation recommendations.
Item 5 – Fees and Compensation
Personal Asset Management Fees
We are compensated for our investment advisory services based on a percentage of the
assets under our management. The fee will be deducted quarterly in advance based on the
account value (including cash and equivalents, gross of margin loans) at the beginning of
the calendar quarter using the fee schedules outlined below. The initial fee may be pro-
rated from the date of the contract or account funding to the end of the current calendar
quarter.
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Equity and Balanced Accounts
1st $2,000,000 . . . . . . . 1.00%
Next $2,000,000 . . . . . 0.75%
Thereafter . . . . . . . . . . 0.50%
Fixed Income Only
1st $1,000,000 . . . . . . . 0.75%
Next $2,000,000 . . . 0.50%
Thereafter . . . . . . . . 0.25%
When accounts are related by family or close association, we may aggregate several
accounts to achieve more favorable breakpoints in the fee schedule. Such related
groupings may differ from the definition of “family” groups as determined and used by
custodians for purposes of commission rates or other charges. A negotiated fee rate may
apply in certain cases considering account size, composition, complexity or other factors.
Some clients may have different fee schedules based on terms offered or negotiated when
these relationships were established. Fees may be reduced based on changes in account
size, composition, complexity or other factors.
Either party can terminate service with written notice. Any prepaid fees will be promptly
refunded after completion of services.
Certain clients referred to YHB through the Schwab Advisor Network program in Florida as
described in Item 14 are charged by Schwab additional fees ranging from 0.15% to 0.25%.
Pension Consulting / 401(k) Asset Management Fees
The Master Retirement Plan Service Agreement identifies a quarterly advisory service fee.
The fee will be deducted quarterly in advance based on the account value (including cash
and equivalents, gross of margin loans) at the end of the previous calendar quarter. A
negotiated fee rate from the published fee schedule may apply in certain cases considering
account size, composition, complexity or other factors.
Financial/Administrative/Consulting Service Fees
Financial, administrative, or consulting service fees will be quoted based on the specific
service to be provided, the level of expertise required, and the estimated time required to
perform the service. Such fees will be quoted on either an hourly basis or as an ongoing
project fee.
Contracts may be canceled at any time, for any reason, with written notice. Prepaid,
unearned fees will be promptly refunded.
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Commissions and Other Fees
Our asset management fees do not include brokerage commissions, transaction fees, or
other related costs and expenses which are paid by you. Custodians, brokers, third party
investment managers and other third parties may charge you fees such as custodial fees,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge management
fees which are disclosed in a fund’s prospectus. Such charges, fees and commissions are
exclusive of and in addition to our management fee. We do not receive any portion of these
commissions, fees and costs but they may contribute to soft dollar credits for research
described in Item 12.
Item 12 further describes the factors that we consider in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., commissions). Item 7 describes fees for trustee services.
YHB is deemed to be a fiduciary to advisory clients that are employee benefit plans or
individual retirement accounts (IRAs) pursuant to the Employee Retirement Income
Security Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (the
“Code”), respectively. As such, our firm is subject to specific duties and obligations under
ERISA and the Internal Revenue Code that include among other things, restrictions
concerning certain forms of compensation.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge performance-based fees (i.e., fees based on a share of client assets’ capital
gains or capital appreciation) and do not employ side-by-side management practices.
Item 7 – Types of Clients
We offer investment advisory services to individuals (including high net-worth
individuals), charitable institutions, corporations, foundations, municipalities, trusts and
estates, and for retirement and profit-sharing plans.
In addition to portfolio management services described above, the officers and portfolio
managers of YHB are available to be named as trustee, co-trustee or successor trustee of
living and testamentary trusts including irrevocable life insurance trusts. Working with
YHB, these individuals can provide or coordinate some or all of the following services:
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o Trust asset custody and management
o Collection and distribution of income and principal
o Maintenance of tax records
o Communication with tax and other advisors
o Answers to financial planning questions
o Personal services to beneficiaries and families
o Bill paying and tax paying services
YHB itself does not serve in any capacity as corporate trustee. YHB trustees may charge an
add-on fee of up to 0.25% for providing trustee services. This fee is separate from the
investment advisory fee charged by YHB. Trustee fees are paid directly to the named
officer or portfolio manager serving as trustee. Additional fees may be charged for tax
preparation, third-party advisor services, or for extraordinary administration. Fees for
larger portfolios or special circumstances may be discounted.
Under SEC regulations, individuals who serve as trustees are deemed to have “custody” of
client funds in a technical sense, and as a result, YHB is also deemed to have “custody” of
the trusts’ assets. However, client funds and securities will be maintained in individual
accounts with qualified custodians and will receive statements at least quarterly.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Your investment strategy and methods of security analysis consist of:
1. Evaluating your individual needs
2. Creating an appropriate diversified portfolio that may include some or all of the
following asset classes or security types:
a. Selected fixed income securities or funds, potentially including U.S.
government, corporate or municipal bonds
b. Individual equity securities including common and preferred stock
c. No-load equity funds representing selected market sectors
3. Evaluating the relative value of various markets based on economic cycles and
market trends
4. Rebalancing your accounts periodically to meet allocation targets.
We manage fixed income investments with the objectives of creating stable portfolios,
dependable cash flows and predictable rates of return with measured levels of risk. In
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acquiring individual bonds we emphasize investment grade vehicles, good value,
reasonable yields, and minimized credit and interest rate risk. Risks associated with
investments in debt securities include issuer-specific volatility greater than the market as a
whole, impairment of collateral, restrictions on liquidity during certain market conditions,
prepayment of principal, and market value fluctuations with interest rate changes.
For equities, we favor the ownership of stocks of high quality companies with a history of
earnings growth and corporate management with demonstrated success in adding to
shareholder value. Our selection process includes:
1) Independent quantitative and qualitative research
2) Collaboration among the members of our investment team to ensure the best
thinking is reflected in our portfolios, and
3) Independent analysis to give us confidence in our convictions.
Investment and trading risks associated with equities include market value fluctuations
from short or long-term price declines which can include complete value loss for individual
securities.
With mutual funds and exchange traded funds, like other securities, past performance does
not guarantee future results.
Our securities analysis methods rely on the assumption that the information provided by
companies, analysts, ratings agencies and other public sources is accurate and unbiased.
Information used includes economic conditions, historical data, industry outlook, inflation,
interest rates, income tax regulations, as well as fiscal and monetary policies of the United
States and foreign countries.
We do not offer any products or services that guarantee rates of return. Investing in
securities involves risk of loss. Clients assume the risk that returns may be negative or
below those of market indices or other products or services.
Item 9 – Disciplinary Information
Our firm has had no legal or disciplinary events to disclose.
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Item 10 – Other Financial Industry Activities and Affiliations
Some employees serve on the boards of charitable and non-profit organizations, and local
municipal finance committees. More detail regarding these roles and related conflict of
interests are provided in Item 11.
Item 11 – Code of Ethics
Description
We have adopted a Code of Ethics for all supervised persons of the firm outlining high
standards of business conduct and fiduciary duties to our clients. The Code of Ethics
includes provisions relating to the confidentiality of client information, prohibitions of
insider trading, restrictions on the acceptance of significant gifts, the reporting of certain
gifts, business entertainment items, and personal securities trading procedures, among
other things. All of our employees must acknowledge the terms of the Code of Ethics
annually, or as amended.
Personal Securities Transactions
YHB has adopted the following governing principles:
1. The interest of client accounts shall at all times be placed first,
2. All personal securities transactions shall be conducted in such a manner as to avoid
any actual or potential conflict of interest or any abuse of an individual’s trust and
responsibility, and
3. Employees should not take inappropriate advantage of their positions.
We may trade for our own accounts in the same securities that we recommend and
purchase for you. The Code of Ethics is designed to assure that our personal securities
transactions, activities and interests will not interfere with making decisions in your best
interests.
We monitor employee trading under the Code of Ethics to reasonably prevent conflicts of
interest.
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Principal Transactions and Cross Trades
We do not buy or sell securities from our own or any affiliated accounts with funds from
your account. We are not dually registered as an advisor and a broker. We have no
affiliated broker-dealer through which we coordinate transactions.
The SEC does permit purchases and sales between client portfolios (cross transactions)
because they can be transacted with lower commission costs to the advantage of buyer and
seller. When we arrange cross transactions, we rely on the custodian to determine
appropriate cross-level prices. If not provided, YHB will determine a price between the bid
and ask price. We derive no commission or other compensation from cross transactions.
Aggregated Trades
As described in Item 12, at times we aggregate transactions where practical and
advantageous to clients. Employees and/or related accounts may participate in aggregated
trades with the firm’s clients, but not on more favorable terms than offered to clients. In
such circumstances, the affiliated and client accounts receive securities at a total average
price. Our policy prohibits any allocation of trades in a manner such that our proprietary
accounts, affiliated accounts, or any particular client or group of clients receive more
favorable treatment than other client accounts.
Disclosures
The principals of YHB created the YHB Charitable Endowment (YHBCE) to provide clients a
vehicle to create their own Donor Advised Fund (DAF) for the following purposes:
o To support the charitable causes of their choice
o To create a charitable fund in a cost-effective manner that minimizes expenses and
takes advantage of the favorable U.S. tax code provisions to maximize their giving
o To allow clients to consolidate and simplify their financial affairs
YHBCE is a 501(c)(3) tax-exempt legal umbrella created to provide each DAF, as
established by individual clients, to receive tax benefits authorized under U.S. tax
regulations. The original donors, and their successor donor advisors, retain authority over
their Fund, its investment strategy, and any grant recommendations to charities.
With the objective of cost and tax efficiency, YHB funded the original legal and accounting
costs of obtaining the 501(c)(3) non-profit status of the entity. Paul Martel and Mark
Everette, as officers of YHBCE and YHB, as well as other YHB employees who have
responsibilities with the administration and recordkeeping of your fund, receive no
compensation from YHBCE or the individual funds for their administrative services. Other
non-investment related services such as the filing of the annual non-profit tax return is
funded by YHB. In an effort to provide appreciation to the asset values in each fund, YHB
offers investment management services and charges a related fee.
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The officers and other YHB employees currently serve (or have served) on boards and in
leadership positions of several charities during their careers. In addition, Paul Martel is the
founder and current president of a charity which provides free medical services to
international children. There is no intention nor encouragement for any client to use their
funds for any of the charities involving YHB employees. Though it is not something we
encourage, some clients have contributed to the charity founded by Mr. Martel. We realize
that this has the potential to appear as a conflict of interest. In many, if not most cases, the
source of funds for a charitable account is from assets already under management by YHB.
Since U.S. tax regulations stipulate that donations to a charitable fund are irrevocable gifts
to obtain the tax benefits, and since Paul Martel and Mark Everette are officers of both YHB
and YHBCE, this may also create the potential appearance of a conflict of interest. We are
committed to keeping our personal charitable interests separate from those of our clients.
By virtue of the fact that the officers have authority to direct payments to third-party
charities, YHBCE has custody over the assets. Annually, YHBCE is subject to a surprise
examination by an independent public accounting firm to verify the proper administration,
recordkeeping and reporting of client funds and securities.
Several portfolio managers serve on local town finance committees. These employees are
not involved in trading of those towns’ securities and their volunteer service does not
create an advantage or disadvantage or conflict of interest.
We will notify any potentially affected client if a conflict of interest is identified. You may
obtain a copy of our complete Code of Ethics upon request.
Item 12 – Brokerage Practices
Brokerage & Directed Brokerage Services
When undertaking an advisory relationship with our firm, you may instruct us to work
with a specific broker-dealer or “qualified” custodian for their execution and clearing
functions. We recommend that clients use broker-dealers that provide quality services and
competitive rates. Unless otherwise directed, we will affect all brokerage, custody, and
clearing functions through Pershing, LLC, (Pershing) or Charles Schwab & Co. (Schwab).
However, you are not obligated to engage these services and the implementation of any or
all recommendations and the selection of an account custodian are solely at your
discretion. We are independently owned and operated and are not affiliated with any
custodian. You enter an account agreement directly with the custodian. We do not open
the account for you but we may assist you in doing so. YHB may not be able to obtain best
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execution for those clients that direct their execution to particular entities. These clients
may pay higher commissions, greater spreads, other transactions costs, or receive less
favorable net prices on transactions for the account.
Best Execution
Pershing and Schwab transaction charges for trade executions are as follows:
Pershing, LLC
Charles Schwab & Co., Inc.
$1/$1000 ($10 minimum)
$1.20/$1000 ($10 min.)
$0
$0
$0-$24
$0-10
$15
N/A
$8.95
$0-25
$0- $15 $10-$50
Municipal & Corporate Bonds
Municipal & Corporate Bonds prime trades
Common Stock per share
Minimum Charge
Mutual Funds
Fixed Income cross trades
Over-the-counter trades
Foreign security transactions
$6.95
$50
Pershing and Schwab are industry leaders in providing clearing and custody services. Both
offer dedicated customer support and technology to YHB and its clients to maximize
service and efficiency. We annually review schedules of clearing transactions charges with
custodians. Sundry charges for other securities functions such as legal and wire transfers
are normal and customary.
We feel that our arrangement for coordinating brokerage and clearing functions represents
good overall value, safety and quality of execution.
Both Pershing and Schwab provide insurance supplemental to the SIPC coverage provided
by the federal government to protect you in the event of default as custodian. In the event
of such default, such insurance will reimburse you for any discrepancies that may arise
between clients’ records of securities owned and the records provided to the surviving or
acquiring party as new custodian. Such insurance in no way reimburses you for any
individual security losses due to market conditions, bond defaults, poor company
performance, or for any event rising from the advice of our portfolio managers.
Soft Dollar Benefits for Research
We have negotiated soft dollar benefit arrangements with Pershing where certain portions
of the commissions charged on trades are credited for payment directly for certain services
related to research and investment decision-making that benefit YHB and all of our clients.
These services include investment research and performance tracking/measurement
software. Absent this arrangement, the commission rates might be lower. Soft dollar
benefits are not limited to those clients who may have generated a particular benefit and
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are not proportionally allocated to any accounts that may generate different amounts of the
soft dollar benefits.
In our roles as fiduciaries we seek to achieve best execution for our clients and believe that
our custodial and related soft dollar benefit arrangements provide clients brokerage and
clearing services at good value as well as the benefit of substantial research.
Trade Aggregation & Allocation
We generally execute transactions for our many clients on an account-by-account basis.
We may aggregate certain transactions for multiple accounts where practical and
advantageous to clients. The aggregation of client trades may allow us to execute
transactions in a more timely, equitable and efficient manner. In these instances clients
participating in aggregated trades receive the average share price for the entire
transaction. To the extent that aggregated trades involve multiple custodians or brokers,
we attempt simultaneous execution in an effort to be equitable to all clients. If a full block
order is not completely filled, the trade will be allocated on a pro-rata basis.
Item 13 – Review of Accounts
Portfolios and underlying securities are continuously monitored. For personal asset
management clients, one of the firm’s portfolio managers reviews each account at least
quarterly. Each portfolio manager is assisted by one or more employees in the execution of
their responsibilities. For many client relationships portfolio managers may work as
teams. The number of accounts assigned will never exceed the number that would
compromise our high standards of quality and personal attention.
You receive quarterly reports consisting of a portfolio appraisal including the current value
of holdings and performance reports to determine if investment objectives are being
achieved. Additional reports are available upon request for more specific analysis and
review.
Item 14 – Client Referrals and Other Compensation
We receive an economic benefit from Pershing and Schwab in the form of support products
and services. These include research and compliance updates and information that they
make available to us and other independent investment advisors whose clients maintain
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their assets with them. The availability of these products and services is not based on YHB
giving particular investment advice to its clients.
From October 2002 through June 2009, we received client referrals from Schwab through
our participation in the Schwab Advisor Network (SAN). SAN is designed to help investors
find an independent investment advisor. Schwab is a broker-dealer independent of and
unaffiliated with YHB. Schwab does not supervise YHB and has no responsibility for our
management of clients’ portfolios or YHB’s other advice or services. As of July 2009, YHB
is no longer an active participant in the SAN and no longer accepts SAN client referrals from
Schwab. YHB, however, continues to serve a small number of clients referred in past years
subject to the policies herein described. We pay Schwab participation fees on all referred
SAN clients’ accounts that are maintained in custody at Schwab. As noted in Item 5,
Schwab charges clients referred through SAN fees or costs greater than the fees or costs
YHB charges clients with similar portfolios who were not referred through SAN.
YHB also makes a quarterly payment to a former part owner of the firm.
In September 2020, YHB entered into a promoter’s agreement with Michael E. Miller. Mr.
Miller is a consultant and independent contractor, not an employee of YHB, and will use
best efforts to promote and refer clients to YHB which he believes are suitable and
appropriate for the investment advisory services provided by YHB. For his promotion
services, he will be paid a fee based on an agreed upon schedule for as long as the
agreement remains in effect. This fee arrangement is disclosed to applicable clients. This
arrangement has no impact on existing clients.
Item 15 – Custody
YHB does not generally maintain custody of your assets, except, 1) as a consequence of our
authority to make withdrawals from your accounts to pay advisory fees with your
authorization, 2) in circumstances where a portfolio manager serves as a trustee, 3) when
YHB manages charitable endowment funds, and 4) per recent SEC designation, where
clients have signed standing letters of authorization for disbursing funds to third parties.
We have adopted policies and procedures to provide reasonable assurance that YHB does
not inadvertently obtain further custody over your assets. At least quarterly you will
receive statements from your qualified custodian (generally Pershing or Schwab) holding
and maintaining your investment assets. We urge you to carefully review custodial
statements and compare them to the account statements that we provide to you. Our
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statements may vary from custodial statements based on accounting procedures, reporting
dates, or valuation methodologies of certain securities.
For funds held in trustee and charitable endowment accounts, YHB undergoes an
independent custody audit each year. YHB is in compliance with all related SEC
regulations.
YHB has engaged a third-party service provider, Chicago Clearing Corporation (CCC), to
monitor and file securities class action litigation claims on behalf of the Firm’s clients.
When a claim is settled and payments are awarded to YHB clients, it may be necessary to
share client information, such as name and account number, with CCC in connection with
this service. YHB does not receive any fees or remuneration in connection with this service
nor does it receive any fees from the third-party provider(s). CCC earns a fee based on a flat
percentage of all claims it collects on behalf of YHB’s clients. This fee is collected and
retained by CCC out of the claims paid by the claim administrator. Clients may opt out of
this service at any time. If a client opts out, YHB does not have an obligation to advise or
take any action on behalf of a client with regard to class action litigation involving
investments held in or formerly held in a client’s account.
Item 16 – Investment Discretion
YHB almost always receives discretionary authority from clients through the Investment
Advisory Contract to purchase and sell securities on your behalf. In all cases, however,
such discretion is to be exercised in a manner consistent with the stated investment
objectives for your account. When selecting securities and determining amounts, we
observe related account investment policies, limitations and restrictions.
Item 17 – Voting Client Securities
The voting of proxies is an important part of portfolio management. As required under Rule
206(4)-6 under the Advisers Act, YHB has adopted proxy voting policies and procedures
that we believe are reasonably designed to ensure that proxies are voted in the best
interests of our clients. YHB has authority to vote proxies with respect to securities owned
by the portfolios. Generally, YHB, when granted proxy voting authority by a client, will
fulfill its obligations by voting in a manner that is in the best interest of its client. Under
these policies, YHB does not have authority to vote proxies with respect to any ETFs held in
an underlying investor’s account. YHB subscribes to a proxy monitor and voting agent
service which includes access to proxy analyses with research and vote recommendations
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from Glass, Lewis & Co. (“Glass Lewis”). YHB’s procedure is to vote all proxies for specific
issues the same way for all clients absent qualifying restrictions from a particular client.
YHB will generally vote in accordance with the recommendations of Glass Lewis, but may
vote in a different fashion on particular votes if our firm determines that such actions are in
the best interest of our clients. Should a conflict of interest arise between YHB and the
client’s best interest, the proxy will be voted in accordance with the recommendation of
Glass Lewis. For each proxy, we maintain all related records as required by applicable
regulations. You may obtain more information or details of how proxies were voted on
your behalf by contacting Mark Everette, Chief Compliance Officer, at 860-561-7050.
Item 18 – Financial Information
YHB has no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding. We do
not require prepaid management fees for more than the current quarter in which they are
collected.
Item 19 – Requirements for State-Registered Advisors
N/A
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