TRUEHAVEN CAPITAL, LLC

TrueHaven Capital, LLC ITEM 1 Cover Page Form ADV Part 2A Firm Brochure March 6, 2025 This Brochure provides information about the qualifications and business practices of . If you have any questions about the contents of this Brochure, please contact us at 210-260-8668, or via e-mail at mwakefield@truehaven.net. 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. is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training. Additional information about is also available on the SEC’s website at www.adviserinfo.sec.gov. IARD#332005 7901 4th St N, #19626 St. Petersburg, FL 33702 210-260-8668 https://www.truehaven.net/ mwakefield@truehaven.net  ITEM 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of our Firm Brochure. This Item discusses only specific material changes made to this Brochure and provides our clients with a summary of such changes. Material Changes since the Last Update TrueHaven Capital, LLC has made material changes since our last filing on February 4, 2025. Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 10: Other Financial Activities and Affiliations • • • • • • Full Brochure and Additional Information Full Brochure and additional information about TrueHaven Capital, LLC are available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered or are required to be registered as investment adviser representatives (“IAR”). 2  ITEM 3 Table of Contents ITEM 1 Cover Page .................................................................................................................. 1 ITEM 2 Material Changes ......................................................................................................... 2 ITEM 3 Table of Contents ........................................................................................................ 3 ITEM 4 Advisory Business ........................................................................................................ 4 ITEM 5 Fees and Compensation ............................................................................................... 6 ITEM 6 Performance-Based Fees and Side-By-Side Management ............................................... 10 ITEM 7 Types of Clients ......................................................................................................... 10 ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss ......................................... 10 ITEM 9 Disciplinary Information ............................................................................................. 13 ITEM 10 Other Financial Activities and Affiliations ...................................................................... 13 ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading ......................... 14 ITEM 12 Brokerage Practices ................................................................................................... 15 ITEM 13 Review of Accounts .................................................................................................... 17 ITEM 14 Client Referrals and Other Compensation ..................................................................... 18 ITEM 15 Custody .................................................................................................................... 18 ITEM 16 Investment Discretion ................................................................................................ 19 ITEM 17 Voting Client Securities .............................................................................................. 20 ITEM 18 Financial Information ................................................................................................. 20 3  ITEM 4 Advisory Business FIRM INFORMATION TrueHaven Capital, LLC (“TrueHaven,” “we,” “us,” “our”), a LLC formed in 2022 is a registered investment advisory firm located in Bradenton and St Petersburg, Florida. We have been a registered investment advisory firm since July 2024. PRINCIPAL OWNERS TrueHaven is owned and controlled by its owner and Chief Compliance Officer, Micah Wakefield. INVESTMENT ADVISORY SERVICES Asset Management Services: We provide asset management services in which we manage your custodial accounts and provide you with continuous and ongoing supervision of your custodial accounts. Our services provide additional investment opportunities among stocks, bonds, mutual funds, exchange-traded funds (ETFs), Variable Annuities, Real Estate Investment Trusts (REITs), options, pooled investment vehicles, and additional securities. Financial Planning and Consulting Services: We provide various financial planning and consulting services that find ways to help you understand your overall financial situation and help you set financial objectives. We accomplish this by helping you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis. Generally, such financial planning and consulting services will involve preparing a financial plan or rendering a financial consultation based on your financial goals and objectives. We will summarize our services to you in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by you. Implementation of the recommendations will be at your discretion. We provide our financial planning and consulting services hourly or on a project basis, or as part of a broader range of services. Ongoing Financial Planning and Consulting Services Upon completion of the client’s financial plan or consulting engagement, we will revisit all or some of the following areas of analysis: financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis throughout the course of a year via scheduled meetings, calls, or follow-up emails to ensure that the initial recommendations in the financial plan or consulting engagement are implemented or to make adjustments to the Client’s financial plan and/or the Client’s objectives. Retirement Plan Consulting Services: We provide advisory services to plan sponsors of employer-sponsored retirement plans for which it has been specifically engaged, in addition to supporting affiliated companies through other non-advisory services to retirement plans for corporations and other business entities either as a 3(21) and 3(38) 4  fiduciary. Such advisory services can include selection and/or de-selection and replacement of individual investment options pursuant to agreed investment criteria. In choosing and monitoring investment options for employer-sponsored retirement plans, we look for reliable fund companies that have a consistent track record and steady performance. Once a fund company is identified for possible selection for a particular retirement plan product, we conduct an in- depth review of the company’s operations, funds, and personnel before determining if the company’s funds as investment options. Quantitative and qualitative factors, such as regional exposure, fund management, and asset size/growth, are also evaluated. The fund companies are monitored on a continuous basis at the firm level. We will assist in the construction of the portfolio by ensuring that all core asset classes are covered to offer full diversification opportunities. However, the final decision of which funds to select is up to the plan sponsor and/or consultant. IRA Rollover Considerations/Conflicts of Interest: When recommending an existing or potential client roll over employer sponsored plan assets, or their self-managed IRA, the Firm will make the following disclosures: • As a fiduciary, TrueHaven will mitigate any conflicts of interest by making sure the best interest of the client is the utmost importance when making recommendations to rollover any employer- based plan, not for generating fee-based compensation. • TrueHaven will offer multiple options to clients when recommending rolling over an IRA, such as: 1. leave the money in an employer’s retirement plan, if permitted; 2. roll over the assets to their new employer’s plan, if available and permitted; 3. cash out the account value (which could result in adverse tax consequences) • TrueHaven will advise that any recommendation to rollover an IRA or employer-based plan may result in additional fees and expenses. Family Office Services TrueHaven provides family office services which consist of various services for personal and business financial matters. The scope of such services will be outlined in an agreement between TrueHaven and the client prior to services being provided. In providing the agreed upon Family Office Services, TrueHaven Capital, LLC which is owned by Micah Wakefield, provides investment, wealth management, consulting services, and family office advisory services. TrueHaven Capital, LLC also operates under a fictitious name of TrueHaven Consulting. The agreed upon services, fee, terms, and conditions will be outlined in a written agreement and fully executed by TrueHaven and client prior to TrueHaven providing any services. In addition, TrueHaven may recommend the services of other specialists and professionals outside of TrueHaven as necessary to provide the agreed upon services to clients. TrueHaven does not receive referral fees for the recommendations made to other specialists and professionals. The client is free to accept or reject any recommendation from TrueHaven. Although TrueHaven may have experience with these service providers, TrueHaven is not responsible for the services provided by these other service 5  providers and is not responsible for any losses caused by the actions of any third parties. Our firm has negotiated exclusive access and/or fee discounts with certain hedge funds for the benefit of our clients. These arrangements are structured to provide suitable clients with lower fees and/or enhanced investment terms. We do not receive compensation, commissions, or revenue-sharing from these funds. We maintain our fiduciary duty to act in our clients’ best interests at all times and provide initial due diligence and ongoing monitoring of these private fund investments for the private fund advisory fee detailed in Item 5 below. Third-Party Money Management Services: We can recommend third-party money managers (“TPMMs”) to manage part or the client’s entire portfolio. TPMMs will be recommended when the TPMMs’ philosophy, investment strategy, and style meets the client's financial situation, investment objectives, and risk tolerance. The asset management services provided by the TPMMs, the compensation to be paid, and other terms of the relationship between the client and the TPMMs will be described in the TPMMs’ disclosure documents and its managed account agreement. TAILORED INVESTMENT ADVISORY SERVICES AND RESTRICTIONS TrueHaven offers the same suite of services to all our clients; however, specific recommendations and their implementation are dependent upon the individual client’s current financial situation, such as income, net worth, and risk tolerance levels and on the level of services they select. Some clients are only involved separately managed accounts or in other investment strategies. On a case-by-case basis, our clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. We can request additional information and documentation, such as current investments, tax returns, insurance policies, and estate plans. We will discuss your investment objectives, needs, and goals, but you must inform us of any changes. Unless directed by you, we do not independently verify any information provided to us by you or your attorney, accountant, or other professionals. WRAP FEE PROGRAMS TrueHaven does not participate in, recommend, or offer wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2024, TrueHaven manages $ 95,000,000 on a discretionary basis and/or $ 22,200,200 on a non-discretionary basis. ITEM 5 Fees and Compensation ANNUAL FEES FOR ADVISORY SERVICES TrueHaven is either compensated for providing asset management services by charging a negotiable fee based on the total assets under management or via a flat fee arrangement for family office services that is defined in an agreement based on scope of services and assets under advisement and/or management. 6  The fees and billing will be pre-determined in writing in the Investment Advisory Agreement executed by you and TrueHaven. These fees are disclosed on the below tiered fee schedule. Assets under Management Annualized Fee Negotiated Fee $500,000 - $1m $1m - $5m $5m – $10m $10m - $15m $15m - $20m $20m+ 1.25% 1.00% 0.90% 0.80% 0.70% Negotiable Optimal Cash Management accounts have a different fee schedule beginning at 0.25% ($1m minimum). Fees for retirement plan services are negotiated before the signing of the Retirement Plan Advisory and Consulting Agreement. The agreement language includes the negotiated fee, which can be charged as a percentage of the total retirement plan assets and/or a flat annual fee. The below ranges are the standard fee ranges that are typically charged. We can waive the agreed-upon financial planning fees if you engage our asset management services. Financial Planning and Consulting Fee Schedule Hourly $200 per hour Fixed Fee Varies TrueHaven clients who do not desire to pay fees on the basis of a flat percentage of assets under management may select to pay advisory and/or consulting fees on the basis of an hourly rate or a fixed fee. All hourly rate fees and fixed fees will be paid in arrears on a monthly basis. Fixed fees are negotiable. Fixed/flat fees are based on investable assets and the complexity of the relationship, and the scope of the work required. All fixed or hourly fee arrangements must be agreed upon in writing, in advance, between TrueHaven Capital and the client after full disclosure. Because fixed or hourly fees would be charged in arrears, no refund policy is necessary. Fixed fees are negotiable, and the final fee schedule would be set forth in and attached as an exhibit to the Investment Advisory Contract or attached as an addendum via a separate family office advisory and consultation services agreement. Clients may terminate their contracts without penalty at any time, and fixed or hourly fees due will be prorated as of the date of termination of the contract. Invoices must be issued to Clients for fixed or hourly fees. These fees are negotiable depending upon the needs of the client, complexity of the client’s financial condition and objectives, and other pertinent factors. This service will automatically renew annually unless terminated by either the Client or TrueHaven in accordance with the terms set forth in the Agreement. This fee will be disclosed on the signed client agreement. Retirement plan consulting fees will be billed on a quarterly basis, in arrears, at the end of each calendar quarter, due within thirty (30) days after the date of invoice, unless otherwise agreed to by the parties. 7  The fee will either be billed directly to the plan sponsor or paid directly from the plan assets if authorized by the plan fiduciary. Clients of TrueHaven’s Family Office Services (“FOS”) who are also clients of TrueHaven Capital will pay lower fees as indicated below (assuming RAUM of $10,000,000 or more): Negotiated Fee Family Office Services Quarterly Annual Fee Fee .1875% .75% Fees are negotiable and may be less for family office clients. In certain situations, we may recommend the purchase of an interest in a private investment vehicle, including hedge funds and private investment pools, to qualified clients. We do not share management or performance fees charged by these funds; any such fees we receive will be outlined in our written advisory agreement with clients. We will charge a fee of 0.5% for all assets invested in private funds we recommend. Management retains the right, at its sole discretion, to negotiate lower fees for investments in private investment vehicles depending upon the circumstances of the investment and/or the client. Fees paid to the investment managers of the private investment vehicle will be disclosed separately in the organization documents of any private investment vehicle. Not all vehicles will have a performance fee and performance fees can vary depending on investment opportunity and with each client, depending on the level of services they receive or other factors. Clients that do not have an FOS agreement will pay a higher performance fee. FEE BILLING & PAYMENT For separately managed accounts and asset management, annual fees are based on the tiered schedule. Asset management fees are paid monthly in arrears. Payments are due on the first day of the calendar month and are based on the account’s asset value as of the last business day of the month multiplied by the applicable annual rate and divided by twelve (12). The fee for the prior month is billed and payable within ten (10) days after the end of the prior month. We will deduct our asset management fee only when in receipt of your written authorization by executing an investment advisory agreement permitting the fees to be paid directly from your account. We will send a copy of your invoice to the custodian at the same time that we send a copy to you. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. Your account at the custodian can also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., variable annuities, mutual funds, 401(k)s). Financial planning, alternatives advisory services fees, and consulting fees are assessed on an hourly basis, as a one-time project fee, or as an annual fee payable either monthly or quarterly. An estimate for total hours will be determined at the start of the relationship in order to determine whether hourly planning or a project-based plan is in the Client’s best interest. Hourly fees will be invoiced upon completion of the financial plan or the rendering of consulting services with a thirty (30) day written notice. For one-time 8  projects, the Client agrees to pay one-half of the total fee upon signing the Financial Planning and Consulting Agreement and the remaining fee upon delivery of the plan. For ongoing financial planning or consulting services, the Client agrees to pay a one-time initial planning fee in addition to an annual fee paid out either monthly or quarterly in arrears. Hedge fund advisory fees will be charged at the end of the following month after statements have been received for prior month. We will not require a fee of $500 or more to be paid six months or more in advance. Monthly or quarterly fees can be paid via wire, check (made payable to TrueHaven Capital) or by direct invoicing via electronic payment processor, or by direct withdrawal from account. In TPMM accounts, the adviser will not deduct advisory fees from the client’s account. We urge our clients to refer to the selected TPMM’s disclosure documents for exact fees and expenses charged by each such TPMM, as well as minimum account requirements, refund, and termination provisions. A complete description of each program can be found in disclosure materials prepared by the TPMM, which we will provide to the client at the time we recommend the program. You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). These fees are separate and distinct from the fees and expenses charged by TrueHaven. TERMINATION OF AGREEMENT Either party can terminate the agreement by providing 30-day advance written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable up to and including the effective date of termination. Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract without penalty within five (5) business days after entering into the contract. OTHER EXPENSES AND FEES The fees discussed above include payment solely for the investment advisory services provided by us and are separate from certain fees or charges that are imposed by third parties in connection with investments made on your behalf for your account. Third-party fees can include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees. All fees paid to us for asset management services are separate from the expenses charged by exchange- traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay management fees for the funds, other fund expenses, account administration, and a possible distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services. However, you would not receive our services to assist you in determining which products or services are most suitable for your financial situation and objectives. You should review both the fees we charge and the fees charged by the fund(s) to understand the total fees to be paid fully. Please refer to Item 12 of this brochure for a more detailed explanation of brokerage practices. OTHER COMPENSATION Neither TrueHaven nor its supervised persons accept any compensation for the sale of securities or other investment products. 9  ITEM 6 Performance-Based Fees and Side-By-Side Management Any performance allocation for SPV investments is a performance-based fee that is a fee based on a share of capital gains on or capital appreciation of the assets of a client. Our performance-based fee schedule is only available for those that meet the qualified client definition under federal and state securities rules and regulations. The specific performance allocations are outlined above in Item 5. Receiving a performance-based fee creates an incentive for TrueHaven to make investments that are riskier or more speculative than would be the case in the absence of those performance-based arrangements. Such fee arrangements could also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. However, TrueHaven has procedures designed and implemented to ensure that all clients are treated fairly to mitigate this conflict from influencing the allocation of investment opportunities among clients. We do not charge any fees based on a share of capital gains on or capital appreciation of the assets of a client. ITEM 7 Types of Clients We provide our investment advisory services to: - High Net Worth Individuals - Pooled Investment Vehicles - Corporations/and or Business - Other RIA Our minimum account size requirements for opening an account with us are as follows: Family office services - $5,000,000 Separately Managed Accounts - $500,000 Advisory Services - $250,000 TrueHaven may, on occasion, waive these requirements. ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss METHODS OF ANALYSIS We use various methods of analysis and investment strategies, including the following: Fundamental Analysis – We evaluate economic and financial factors to determine if a security can be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing the fundamental analysis is to determine a value that an investor can use to 10  determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments can result in significant price fluctuations that can lead to investor losses. Technical Analysis – This method involves the evaluation of securities by performing an analysis of statical information that is generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value but instead use charts and other tools to determine the patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. A substantial risk in relying upon technical analysis is that spotting historical trends cannot help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that we will be able to accurately predict such a reoccurrence. INVESTMENT STRATEGIES When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies. Long-Term Strategy - A long-term strategy cannot take advantage of short-term gains or can experience more volatility over the life of the portfolio. Income Strategy – An income strategy will seek to maximize income relative to a client’s risk profile and is pursued typically to provide a steady stream of income that can either be reinvested or be used at the Client’s discretion. An income strategy generally utilizes fixed income products that are subject to interest rate risk, prepayment risk, market risk, and, in the case of bonds issued by municipalities and corporations, depending on the type of bond, the potential of default risk. Hedging Strategy – A hedging strategy uses certain instruments such as options and certain ETFs to limit or reduce investment risk; however, this strategy can also be expected to limit or reduce the potential for profit or result in losses. Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment management agreement. POTENTIAL RISKS Investing involves different levels of risk that can result in loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in securities involves the risk of loss that clients should be prepared to bear. Investing involves the assumption of risk, including: 11  Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affects the price of your investment. Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we recommend to you with it. Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock. Political and Governmental Risk: which is the risk that the value of your investment will is affected by the introduction of new laws or regulations. Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if interest rates rise. Call Risk: which is the risk that your investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you. Default Risk: which is the risk that the issuer is unable to pay the contractual interest or principal on the investment promptly or at all. Manager Risk: which is the risk that an actively managed mutual fund’s investment adviser will fail to execute the fund’s stated investment strategy. Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. Alternative Investments Risk: which is the risk associated with investing in alternative investments that are speculative, not suitable for all clients, and are intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment. Investing in alternative investments include the following economic risks: • loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices • lack of liquidity in that there a lack of a secondary market for the investment and none expected to develop; • the volatility of returns; • restrictions on transferring interests in the investment; • potential lack of diversification and resulting in higher risk due to concentration of trading authority when a single adviser is utilized; • absence of information regarding valuations and pricing; • delays in tax reporting; • less regulation and higher fees than mutual funds; and • risks associated with the operations, personnel, and process of the manager funds investing in alternative investments. Portfolio Turnover Risk: Under normal circumstances, the anticipated portfolio turnover rate for most of private hedge fund strategies may be more than 100%. High rates of portfolio turnover could lower performance of the strategy due to increased costs and may result in the realization of capital gains. If the strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk: Because some of our hedge fund and investment strategies are non- diversified, it will invest a greater percentage of its assets in a particular issuer and will own fewer 12  securities than a diversified strategy. Accordingly, each strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk: Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. Our hedge fund investment managers may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. Liquidity Risk: Liquidity is the ability to convert readily an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Correlation Risk: Correlation measures how much one asset moves in connection with another asset. Correlations are typically calculated using historical relationships. There is no assurance the historical relationship will persist. As correlations change, the integrity of hedging and diversification strategies becomes suspect. Your account may buy or sell options based upon a given correlation with an underlying asset(s). This relationship may not hold and can result in adverse financial consequences. Option prices may move more or less than the price of your asset or portfolio. This failure to track your asset or portfolio may result in a loss or greater loss than was expected. Short-selling and Hedging Risk: Certain investment strategies, including hedge funds recommended by us, may employ short selling, options trading, and other derivative or “hedging” transactions that can, in some circumstances, substantially increase the impact of adverse price movements. Tax Risks: The investments recommended by Adviser may generate taxable income and realized capital gains or losses, and Clients should consult with their tax advisors about the tax consequences of their investments. Adviser does not offer tax advice to Clients. ITEM 9 Disciplinary Information As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There has been no disciplinary, legal, or regulatory events related to us or any of our management persons. ITEM 10 Other Financial Activities and Affiliations FINANCIAL INDUSTRY ACTIVITIES Neither TrueHaven nor its management persons are registered or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer. 13  Neither TrueHaven nor its management persons are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. AFFILIATIONS Neither TrueHaven nor any TrueHaven management person is registered, or has an application pending to register, as a broker- dealer or a registered representative of a broker-dealer. Neither TrueHaven nor any TrueHaven management person is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor, or an associated person of the foregoing entities. TrueHaven does not have any related parties. As a result, we do not have a relationship with any related parties. TrueHaven only receives compensation directly from Clients. We do not receive compensation from any outside source. We do not have any conflicts of interest with any outside party. SELECTION OF OTHER INVESTMENT ADVISERS We may recommend certain private investment vehicles, including hedge funds and private pools, with which we have negotiated special investment terms and fee deductions for our clients. In such situation, we have an incentive to recommend the investment vehicles that have negotiated special terms for our clients in order to provide clients with lower overall costs. Not all private investment vehicles will negotiate such terms with TrueHaven, and the failure to obtain preferential terms for our clients may impact our recommendation of any individual private vehicle. We do not share any fees with private investment vehicles, but charge a management fee for assets invested in vehicles we have recommended. We also recommend or select TPMMs, other than hedge fund managers, for our clients but do not receive compensation from the third-party via a fee share; thus, there is not a material conflict of interest between our interests and those of our clients in that TrueHaven does not have an incentive to direct clients to TPMMs that provide us with a larger fee split. TrueHaven will always act in the best interest of our clients when making recommendations or selecting TPMMs. The client always has the right to decide whether to act on our recommendations and whether to utilize the services of the recommended TPMM. The client always has the right to utilize the professional of his or her choice. All TPMMs will be properly licensed and registered as investment advisers in the proper jurisdictions. No referral fees, commissions, or shared fees are paid or accepted by any TPMMs. ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading CODE OF ETHICS TrueHaven has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. TrueHaven has a fiduciary duty to all clients. 14  This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics. Our Code of Ethics is available to clients and prospective clients upon request. RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities in which we or a related person has a material financial interest. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients can also have a position or interest. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order. PERSONAL TRADING Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to TrueHaven and our clients. TrueHaven monitors and controls personal trading through pre-approval of all personal securities transactions or blackout periods imposed upon employees trading in the same securities as TrueHaven. We forbid any officer or employee, either personally or on behalf of others, to trade on material, nonpublic information or communicate such information to others in violation of the law. ITEM 12 Brokerage Practices We recommend broker-dealers for our clients to use in order to custody their accounts. The firms we recommend will be independent SEC-registered broker-dealers and members of FINRA and SIPC. We currently have arrangements with Charles Schwab & Co. (“Schwab”) and Interactive Brokers, LLC. As a fiduciary, we are obligated to seek out the best execution of client transactions for accounts that we manage. In general, the execution of securities transactions is at a total cost to process each transaction and are the most favorable under the circumstances. However, we do not limit the best execution to the lowest available price. Additional factors are taken into consideration when determining the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review consists of reviewing the commission and fee structures of various broker-dealers, research platforms, and execution services. Accordingly, while we consider competitive rates, we do not necessarily obtain the lowest possible commission rates for account transactions. Therefore, the overall services provided by unaffiliated broker- dealers and qualified custodians are evaluated to determine the best execution. You can pay trade 15  execution charges and higher commissions through the trading platforms approved by us than through platforms that have not been approved by us. RESEARCH AND OTHER BENEFITS Products & Services Available to Us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed description of Schwab’s support services: Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but cannot directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We can use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); • facilitates trade execution and allocates aggregated trade orders for multiple client accounts; • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and • assists with back-office functions, recordkeeping, and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. 16  Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. BROKERAGE FOR CLIENT REFERRALS We do not receive client referrals from broker-dealers. DIRECTED BROKERAGE We do not recommend, request, require, or permit clients to direct us to executed transactions through a specific broker-dealer other than those we recommend. TRADE AGGREGATION We attempt to allocate trade executions in the most equitable manner possible, taking into consideration current asset allocation and availability of funds using price averaging, proration, and consistently non- arbitrary methods of allocation. We can aggregate orders in order to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. In aggregated orders, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. ITEM 13 Review of Accounts PERIODIC REVIEWS We review asset management and retirement plan accounts no less than quarterly. These accounts will be reviewed by Investment Advisor Representative (“IAR”) of the account. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current investment trends. Financial plans created utilizing our ongoing financial planning services will be reviewed quarterly by the IAR on the account. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. Project-based financial planning clients are provided a one-time plan or consulting session and receive no additional reviews unless a new financial planning and consulting agreement is executed. REVIEW TRIGGERS We conduct periodic reviews to evaluate the current market, economic and political events and how these can affect client accounts. Additional reviews can be triggered by these events or by events in the client’s financial or personal status. REGULAR REPORTS 17  Asset management clients will receive advisory account reports no less than quarterly from the custodian. These reports show asset value by cash balances, security, unit cost, total cost, current per share values, etc. Clients are urged to review the quarterly reports. Clients are encouraged to phone or e-mail us as often as they deem necessary to receive information regarding the investment tactics and strategies being followed. Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during plan reviews. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. Project-based financial planning and consulting clients are provided a one-time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Retirement plan clients can create and/or review the plan’s Investment Policy Statement (“IPS”). The plan client can also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks set forth in the IPS or as otherwise determined in our judgment. The information used to generate the reports will be derived from statements provided by the plan fiduciary or third party. This review will include a quantitative and qualitative analysis of investment selections included within the plan and provide third-party commentary on investment options whenever available. The plan client may also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks or as otherwise determined in our judgment. The information used to generate the reports will be derived from a third party. ITEM 14 Client Referrals and Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest). You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). Please see Item 12 Brokerage Practices for information regarding the benefits we receive from our custodian. We do not pay a referral fee to third-party promoters. ITEM 15 Custody We are deemed to have custody as a result of our Standing Letters of Authorization (“SLOA(s)”) to transfer funds from their account to third parties. In such instances where we act under such an SLOA, it is our policy to only initiate these transactions when directed by the client to transfer funds to a third party the 18  client designates for a designated amount and at a designated time, all of their choosing. A surprise examination is not required in this circumstance where we are deemed to have custody due to SLOAs, as we are relying on the conditions set forth in the No-Action letter issued by the Securities and Exchange Commission on February 21, 2017. Pursuant to the conditions set forth in the No-Action Letter, we confirm that in those situations • you provide an instruction to the qualified custodian, in writing, that includes your signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed; • you authorize us, in writing, either on the qualified custodian’s form or separately, to direct • transfers to the third party either on a specified schedule or from time to time; the qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify your authorization, and the qualified custodian provides a transfer of funds notice to you promptly after each transfer; • you have the ability to terminate or change the instruction to the qualified custodian; • we have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in your instruction; • we maintain records showing that the third party is not a related party of TrueHaven or located • at the same address as TrueHaven; and the qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16 Investment Discretion DISCRETIONARY AUTHORITY FOR TRADING If you are participating in our asset management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account and can also implement trades on a discretionary basis. When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction. If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, and whether the security should be bought or sold before implementing changes in your account. Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price. On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be purchased or sold in your account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement. 19  ITEM 17 Voting Client Securities We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account. The responsibility for voting your securities places increased liability to us and does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting your securities. Therefore, you are responsible for voting all proxies for securities held in accounts managed by us. Typically, our qualified custodian will forward you your proxy information. Although we do not vote your proxies, you can contact us if you have a question about a particular proxy. ITEM 18 Financial Information We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. We are currently not in, nor have we been historically, in a financially precarious situation or the subject of a bankruptcy petition. 20 

TrueHaven Capital, LLC ITEM 1 Cover Page Form ADV Part 2A Firm Brochure March 26, 2025 This Brochure provides information about the qualifications and business practices of . If you have any questions about the contents of this Brochure, please contact us at 210-260-8668, or via e-mail at mwakefield@truehaven.net. 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. is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training. Additional information about is also available on the SEC’s website at www.adviserinfo.sec.gov. IARD#332005 7901 4th St N, #19626 St. Petersburg, FL 33702 210-260-8668 https://www.truehaven.net/ mwakefield@truehaven.net  ITEM 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of our Firm Brochure. This Item discusses only specific material changes made to this Brochure and provides our clients with a summary of such changes. Material Changes since the Last Update TrueHaven Capital, LLC has made material changes since our last filing on March 6, 2025. Item 5: Fees and Compensation • Full Brochure and Additional Information Full Brochure and additional information about TrueHaven Capital, LLC are available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered or are required to be registered as investment adviser representatives (“IAR”). 2  ITEM 3 Table of Contents ITEM 1 Cover Page .................................................................................................................. 1 ITEM 2 Material Changes ......................................................................................................... 2 ITEM 3 Table of Contents ........................................................................................................ 3 ITEM 4 Advisory Business ........................................................................................................ 4 ITEM 5 Fees and Compensation ............................................................................................... 6 ITEM 6 Performance-Based Fees and Side-By-Side Management ............................................... 10 ITEM 7 Types of Clients ......................................................................................................... 10 ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss ......................................... 10 ITEM 9 Disciplinary Information ............................................................................................. 13 ITEM 10 Other Financial Activities and Affiliations ...................................................................... 14 ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading ......................... 15 ITEM 12 Brokerage Practices ................................................................................................... 15 ITEM 13 Review of Accounts .................................................................................................... 17 ITEM 14 Client Referrals and Other Compensation ..................................................................... 18 ITEM 15 Custody .................................................................................................................... 19 ITEM 16 Investment Discretion ................................................................................................ 19 ITEM 17 Voting Client Securities .............................................................................................. 20 ITEM 18 Financial Information ................................................................................................. 20 3  ITEM 4 Advisory Business FIRM INFORMATION TrueHaven Capital, LLC (“TrueHaven,” “we,” “us,” “our”), a LLC formed in 2022 is a registered investment advisory firm located in Bradenton and St Petersburg, Florida. We have been a registered investment advisory firm since July 2024. PRINCIPAL OWNERS TrueHaven is owned and controlled by its owner and Chief Compliance Officer, Micah Wakefield. INVESTMENT ADVISORY SERVICES Asset Management Services: We provide asset management services in which we manage your custodial accounts and provide you with continuous and ongoing supervision of your custodial accounts. Our services provide additional investment opportunities among stocks, bonds, mutual funds, exchange-traded funds (ETFs), Variable Annuities, Real Estate Investment Trusts (REITs), options, pooled investment vehicles, and additional securities. Financial Planning and Consulting Services: We provide various financial planning and consulting services that find ways to help you understand your overall financial situation and help you set financial objectives. We accomplish this by helping you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis. Generally, such financial planning and consulting services will involve preparing a financial plan or rendering a financial consultation based on your financial goals and objectives. We will summarize our services to you in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by you. Implementation of the recommendations will be at your discretion. We provide our financial planning and consulting services hourly or on a project basis, or as part of a broader range of services. Ongoing Financial Planning and Consulting Services Upon completion of the client’s financial plan or consulting engagement, we will revisit all or some of the following areas of analysis: financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis throughout the course of a year via scheduled meetings, calls, or follow-up emails to ensure that the initial recommendations in the financial plan or consulting engagement are implemented or to make adjustments to the Client’s financial plan and/or the Client’s objectives. Retirement Plan Consulting Services: We provide advisory services to plan sponsors of employer-sponsored retirement plans for which it has been specifically engaged, in addition to supporting affiliated companies through other non-advisory services to retirement plans for corporations and other business entities either as a 3(21) and 3(38) 4  fiduciary. Such advisory services can include selection and/or de-selection and replacement of individual investment options pursuant to agreed investment criteria. In choosing and monitoring investment options for employer-sponsored retirement plans, we look for reliable fund companies that have a consistent track record and steady performance. Once a fund company is identified for possible selection for a particular retirement plan product, we conduct an in- depth review of the company’s operations, funds, and personnel before determining if the company’s funds as investment options. Quantitative and qualitative factors, such as regional exposure, fund management, and asset size/growth, are also evaluated. The fund companies are monitored on a continuous basis at the firm level. We will assist in the construction of the portfolio by ensuring that all core asset classes are covered to offer full diversification opportunities. However, the final decision of which funds to select is up to the plan sponsor and/or consultant. IRA Rollover Considerations/Conflicts of Interest: When recommending an existing or potential client roll over employer sponsored plan assets, or their self-managed IRA, the Firm will make the following disclosures: • As a fiduciary, TrueHaven will mitigate any conflicts of interest by making sure the best interest of the client is the utmost importance when making recommendations to rollover any employer- based plan, not for generating fee-based compensation. • TrueHaven will offer multiple options to clients when recommending rolling over an IRA, such as: 1. leave the money in an employer’s retirement plan, if permitted; 2. roll over the assets to their new employer’s plan, if available and permitted; 3. cash out the account value (which could result in adverse tax consequences) • TrueHaven will advise that any recommendation to rollover an IRA or employer-based plan may result in additional fees and expenses. Family Office Services TrueHaven provides family office services which consist of various services for personal and business financial matters. The scope of such services will be outlined in an agreement between TrueHaven and the client prior to services being provided. In providing the agreed upon Family Office Services, TrueHaven Capital, LLC which is owned by Micah Wakefield, provides investment, wealth management, consulting services, and family office advisory services. TrueHaven Capital, LLC also operates under a fictitious name of TrueHaven Consulting. The agreed upon services, fee, terms, and conditions will be outlined in a written agreement and fully executed by TrueHaven and client prior to TrueHaven providing any services. In addition, TrueHaven may recommend the services of other specialists and professionals outside of TrueHaven as necessary to provide the agreed upon services to clients. TrueHaven does not receive referral fees for the recommendations made to other specialists and professionals. The client is free to accept or reject any recommendation from TrueHaven. Although TrueHaven may have experience with these service providers, TrueHaven is not responsible for the services provided by these other service 5  providers and is not responsible for any losses caused by the actions of any third parties. Our firm has negotiated exclusive access and/or fee discounts with certain hedge funds for the benefit of our clients. These arrangements are structured to provide suitable clients with lower fees and/or enhanced investment terms. We do not receive compensation, commissions, or revenue-sharing from these funds. We maintain our fiduciary duty to act in our clients’ best interests at all times and provide initial due diligence and ongoing monitoring of these private fund investments for the private fund advisory fee detailed in Item 5 below. Third-Party Money Management Services: We can recommend third-party money managers (“TPMMs”) to manage part or the client’s entire portfolio. TPMMs will be recommended when the TPMMs’ philosophy, investment strategy, and style meets the client's financial situation, investment objectives, and risk tolerance. The asset management services provided by the TPMMs, the compensation to be paid, and other terms of the relationship between the client and the TPMMs will be described in the TPMMs’ disclosure documents and its managed account agreement. TAILORED INVESTMENT ADVISORY SERVICES AND RESTRICTIONS TrueHaven offers the same suite of services to all our clients; however, specific recommendations and their implementation are dependent upon the individual client’s current financial situation, such as income, net worth, and risk tolerance levels and on the level of services they select. Some clients are only involved separately managed accounts or in other investment strategies. On a case-by-case basis, our clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. We can request additional information and documentation, such as current investments, tax returns, insurance policies, and estate plans. We will discuss your investment objectives, needs, and goals, but you must inform us of any changes. Unless directed by you, we do not independently verify any information provided to us by you or your attorney, accountant, or other professionals. WRAP FEE PROGRAMS TrueHaven does not participate in, recommend, or offer wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2024, TrueHaven manages $ 95,000,000 on a discretionary basis and/or $ 22,200,200 on a non-discretionary basis. ITEM 5 Fees and Compensation ANNUAL FEES FOR ADVISORY SERVICES TrueHaven is either compensated for providing asset management services by charging a negotiable fee based on the total assets under management or via a flat fee arrangement for family office services that is defined in an agreement based on scope of services and assets under advisement and/or management. 6  The fees and billing will be pre-determined in writing in the Investment Advisory Agreement executed by you and TrueHaven. These fees are disclosed on the below tiered fee schedule. Assets under Management Annualized Fee Negotiated Fee $500,000 - $1m $1m - $5m $5m – $10m $10m - $15m $15m - $20m $20m+ 1.25% 1.00% 0.90% 0.80% 0.70% Negotiable Optimal Cash Management accounts have a different fee schedule beginning at 0.25% ($1m minimum). Fees for retirement plan services are negotiated before the signing of the Retirement Plan Advisory and Consulting Agreement. The agreement language includes the negotiated fee, which can be charged as a percentage of the total retirement plan assets and/or a flat annual fee. The below ranges are the standard fee ranges that are typically charged. We can waive the agreed-upon financial planning fees if you engage our asset management services. Financial Planning and Consulting Fee Schedule Hourly $200 per hour Fixed Fee Varies TrueHaven clients who do not desire to pay fees on the basis of a flat percentage of assets under management may select to pay advisory and/or consulting fees on the basis of an hourly rate or a fixed fee. All hourly rate fees and fixed fees will be paid in arrears on a monthly basis. Fixed fees are negotiable. Fixed/flat fees are based on investable assets and the complexity of the relationship, and the scope of the work required. All fixed or hourly fee arrangements must be agreed upon in writing, in advance, between TrueHaven Capital and the client after full disclosure. Because fixed or hourly fees would be charged in arrears, no refund policy is necessary. Fixed fees are negotiable, and the final fee schedule would be set forth in and attached as an exhibit to the Investment Advisory Contract or attached as an addendum via a separate family office advisory and consultation services agreement. Clients may terminate their contracts without penalty at any time, and fixed or hourly fees due will be prorated as of the date of termination of the contract. Invoices must be issued to Clients for fixed or hourly fees. These fees are negotiable depending upon the needs of the client, complexity of the client’s financial condition and objectives, and other pertinent factors. This service will automatically renew annually unless terminated by either the Client or TrueHaven in accordance with the terms set forth in the Agreement. This fee will be disclosed on the signed client agreement. Retirement plan consulting fees will be billed on a quarterly basis, in arrears, at the end of each calendar quarter, due within thirty (30) days after the date of invoice, unless otherwise agreed to by the parties. 7  The fee will either be billed directly to the plan sponsor or paid directly from the plan assets if authorized by the plan fiduciary. Clients of TrueHaven’s Family Office Services (“FOS”) who are also clients of TrueHaven Capital will pay lower fees as indicated below (assuming RAUM of $10,000,000 or more): Negotiated Fee Family Office Services Quarterly Annual Fee Fee .1875% .75% Fees are negotiable and may be less for family office clients. In certain situations, we may recommend the purchase of an interest in a private investment vehicle, including hedge funds and private investment pools, to qualified clients. We do not share management or performance fees charged by these funds; any such fees we receive will be outlined in our written advisory agreement with clients. We will charge a fee up to 0.5% for all assets invested in private funds we recommend. Management retains the right, at its sole discretion, to negotiate lower fees for investments in private investment vehicles depending upon the circumstances and asset level of the investment and/or the client. Fees paid to the investment managers of the private investment vehicle will be disclosed separately in the organization documents of any private investment vehicle. Not all vehicles will have a performance fee and performance fees can vary depending on investment opportunity and with each client, depending on the level of services they receive or other factors. Clients that do not have an FOS agreement will pay a higher performance fee. FEE BILLING & PAYMENT For separately managed accounts and asset management, annual fees are based on the tiered schedule. Asset management fees are paid monthly in arrears. Payments are due on the first day of the calendar month and are based on the account’s asset value as of the last business day of the month. For Schwab, calculations use this value and are then multiplied by the applicable annual rate after dividing by twelve. Interactive Brokers calculates using this value multiplied by the applicable annual rate and then multiplied by the pro-rated days in the month (example $100,000 x 1% = $1,000 x 30/365 = $82.19). The fee for the prior month is billed and payable within ten (10) days after the end of the prior month. We will deduct our asset management fee only when in receipt of your written authorization by executing an investment advisory agreement permitting the fees to be paid directly from your account. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. Your account at the custodian can also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., variable annuities, mutual funds, 401(k)s). Financial planning, alternatives advisory services fees, and consulting fees are assessed on an hourly basis, as a one-time project fee, or as an annual fee payable either monthly or quarterly. An estimate for total hours will be determined at the start of the relationship in order to determine whether hourly planning 8  or a project-based plan is in the Client’s best interest. Hourly fees will be invoiced upon completion of the financial plan or the rendering of consulting services with a thirty (30) day written notice. For one-time projects, the Client agrees to pay one-half of the total fee upon signing the Financial Planning and Consulting Agreement and the remaining fee upon delivery of the plan. For ongoing financial planning or consulting services, the Client agrees to pay a one-time initial planning fee in addition to an annual fee paid out either monthly or quarterly in arrears. Hedge fund advisory fees will be charged at the end of the following month after statements have been received for prior month. We will not require a fee of $500 or more to be paid six months or more in advance. Monthly or quarterly fees can be paid via wire, check (made payable to TrueHaven Capital) or by direct invoicing via electronic payment processor, or by direct withdrawal from account. In TPMM accounts, the adviser will not deduct advisory fees from the client’s account. We urge our clients to refer to the selected TPMM’s disclosure documents for exact fees and expenses charged by each such TPMM, as well as minimum account requirements, refund, and termination provisions. A complete description of each program can be found in disclosure materials prepared by the TPMM, which we will provide to the client at the time we recommend the program. You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). These fees are separate and distinct from the fees and expenses charged by TrueHaven. TERMINATION OF AGREEMENT Either party can terminate the agreement by providing 30-day advance written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable up to and including the effective date of termination. Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract without penalty within five (5) business days after entering into the contract. OTHER EXPENSES AND FEES The fees discussed above include payment solely for the investment advisory services provided by us and are separate from certain fees or charges that are imposed by third parties in connection with investments made on your behalf for your account. Third-party fees can include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees. All fees paid to us for asset management services are separate from the expenses charged by exchange- traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay management fees for the funds, other fund expenses, account administration, and a possible distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services. However, you would not receive our services to assist you in determining which products or services are most suitable for your financial situation and objectives. You should review both the fees we charge and the fees charged by the fund(s) to understand the total fees to be paid fully. Please refer to Item 12 of this brochure for a more detailed explanation of brokerage practices. 9  OTHER COMPENSATION Neither TrueHaven nor its supervised persons accept any compensation for the sale of securities or other investment products. ITEM 6 Performance-Based Fees and Side-By-Side Management Any performance allocation for SPV investments is a performance-based fee that is a fee based on a share of capital gains on or capital appreciation of the assets of a client. Our performance-based fee schedule is only available for those that meet the qualified client definition under federal and state securities rules and regulations. The specific performance allocations are outlined above in Item 5. Receiving a performance-based fee creates an incentive for TrueHaven to make investments that are riskier or more speculative than would be the case in the absence of those performance-based arrangements. Such fee arrangements could also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. However, TrueHaven has procedures designed and implemented to ensure that all clients are treated fairly to mitigate this conflict from influencing the allocation of investment opportunities among clients. We do not charge any fees based on a share of capital gains on or capital appreciation of the assets of a client. ITEM 7 Types of Clients We provide our investment advisory services to: - High Net Worth Individuals - Pooled Investment Vehicles - Corporations/and or Business - Other RIA Our minimum account size requirements for opening an account with us are as follows: Family office services - $5,000,000 Separately Managed Accounts - $500,000 Advisory Services - $250,000 TrueHaven may, on occasion, waive these requirements. ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss METHODS OF ANALYSIS We use various methods of analysis and investment strategies, including the following: Fundamental Analysis – We evaluate economic and financial factors to determine if a security can be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and 10  quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing the fundamental analysis is to determine a value that an investor can use to determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments can result in significant price fluctuations that can lead to investor losses. Technical Analysis – This method involves the evaluation of securities by performing an analysis of statical information that is generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value but instead use charts and other tools to determine the patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. A substantial risk in relying upon technical analysis is that spotting historical trends cannot help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that we will be able to accurately predict such a reoccurrence. INVESTMENT STRATEGIES When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies. Long-Term Strategy - A long-term strategy cannot take advantage of short-term gains or can experience more volatility over the life of the portfolio. Income Strategy – An income strategy will seek to maximize income relative to a client’s risk profile and is pursued typically to provide a steady stream of income that can either be reinvested or be used at the Client’s discretion. An income strategy generally utilizes fixed income products that are subject to interest rate risk, prepayment risk, market risk, and, in the case of bonds issued by municipalities and corporations, depending on the type of bond, the potential of default risk. Hedging Strategy – A hedging strategy uses certain instruments such as options and certain ETFs to limit or reduce investment risk; however, this strategy can also be expected to limit or reduce the potential for profit or result in losses. Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment management agreement. POTENTIAL RISKS Investing involves different levels of risk that can result in loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and 11  suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in securities involves the risk of loss that clients should be prepared to bear. Investing involves the assumption of risk, including: Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affects the price of your investment. Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we recommend to you with it. Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock. Political and Governmental Risk: which is the risk that the value of your investment will is affected by the introduction of new laws or regulations. Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if interest rates rise. Call Risk: which is the risk that your investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you. Default Risk: which is the risk that the issuer is unable to pay the contractual interest or principal on the investment promptly or at all. Manager Risk: which is the risk that an actively managed mutual fund’s investment adviser will fail to execute the fund’s stated investment strategy. Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. Alternative Investments Risk: which is the risk associated with investing in alternative investments that are speculative, not suitable for all clients, and are intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment. Investing in alternative investments include the following economic risks: • loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices • lack of liquidity in that there a lack of a secondary market for the investment and none expected to develop; • the volatility of returns; • restrictions on transferring interests in the investment; • potential lack of diversification and resulting in higher risk due to concentration of trading authority when a single adviser is utilized; • absence of information regarding valuations and pricing; • delays in tax reporting; • less regulation and higher fees than mutual funds; and • risks associated with the operations, personnel, and process of the manager funds investing in alternative investments. Portfolio Turnover Risk: Under normal circumstances, the anticipated portfolio turnover rate for most of private hedge fund strategies may be more than 100%. High rates of portfolio turnover could lower performance of the strategy due to increased costs and may result in the realization of capital gains. If the strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held 12  in a taxable account. Non-Diversified Strategy Risk: Because some of our hedge fund and investment strategies are non- diversified, it will invest a greater percentage of its assets in a particular issuer and will own fewer securities than a diversified strategy. Accordingly, each strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk: Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. Our hedge fund investment managers may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. Liquidity Risk: Liquidity is the ability to convert readily an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Correlation Risk: Correlation measures how much one asset moves in connection with another asset. Correlations are typically calculated using historical relationships. There is no assurance the historical relationship will persist. As correlations change, the integrity of hedging and diversification strategies becomes suspect. Your account may buy or sell options based upon a given correlation with an underlying asset(s). This relationship may not hold and can result in adverse financial consequences. Option prices may move more or less than the price of your asset or portfolio. This failure to track your asset or portfolio may result in a loss or greater loss than was expected. Short-selling and Hedging Risk: Certain investment strategies, including hedge funds recommended by us, may employ short selling, options trading, and other derivative or “hedging” transactions that can, in some circumstances, substantially increase the impact of adverse price movements. Tax Risks: The investments recommended by Adviser may generate taxable income and realized capital gains or losses, and Clients should consult with their tax advisors about the tax consequences of their investments. Adviser does not offer tax advice to Clients. ITEM 9 Disciplinary Information As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There has been no disciplinary, legal, or regulatory events related to us or any of our management persons. 13  ITEM 10 Other Financial Activities and Affiliations FINANCIAL INDUSTRY ACTIVITIES Neither TrueHaven nor its management persons are registered or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither TrueHaven nor its management persons are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. AFFILIATIONS Neither TrueHaven nor any TrueHaven management person is registered, or has an application pending to register, as a broker- dealer or a registered representative of a broker-dealer. Neither TrueHaven nor any TrueHaven management person is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor, or an associated person of the foregoing entities. TrueHaven does not have any related parties. As a result, we do not have a relationship with any related parties. TrueHaven only receives compensation directly from Clients. We do not receive compensation from any outside source. We do not have any conflicts of interest with any outside party. SELECTION OF OTHER INVESTMENT ADVISERS We may recommend certain private investment vehicles, including hedge funds and private pools, with which we have negotiated special investment terms and fee deductions for our clients. In such situation, we have an incentive to recommend the investment vehicles that have negotiated special terms for our clients in order to provide clients with lower overall costs. Not all private investment vehicles will negotiate such terms with TrueHaven, and the failure to obtain preferential terms for our clients may impact our recommendation of any individual private vehicle. We do not share any fees with private investment vehicles, but charge a management fee for assets invested in vehicles we have recommended. We also recommend or select TPMMs, other than hedge fund managers, for our clients but do not receive compensation from the third-party via a fee share; thus, there is not a material conflict of interest between our interests and those of our clients in that TrueHaven does not have an incentive to direct clients to TPMMs that provide us with a larger fee split. TrueHaven will always act in the best interest of our clients when making recommendations or selecting TPMMs. The client always has the right to decide whether to act on our recommendations and whether to utilize the services of the recommended TPMM. The client always has the right to utilize the professional of his or her choice. All TPMMs will be properly licensed and registered as investment advisers in the proper jurisdictions. No referral fees, commissions, or shared fees are paid or accepted by any TPMMs. 14  ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading CODE OF ETHICS TrueHaven has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. TrueHaven has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics. Our Code of Ethics is available to clients and prospective clients upon request. RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities in which we or a related person has a material financial interest. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients can also have a position or interest. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order. PERSONAL TRADING Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to TrueHaven and our clients. TrueHaven monitors and controls personal trading through pre-approval of all personal securities transactions or blackout periods imposed upon employees trading in the same securities as TrueHaven. We forbid any officer or employee, either personally or on behalf of others, to trade on material, nonpublic information or communicate such information to others in violation of the law. ITEM 12 Brokerage Practices We recommend broker-dealers for our clients to use in order to custody their accounts. The firms we recommend will be independent SEC-registered broker-dealers and members of FINRA and SIPC. We currently have arrangements with Charles Schwab & Co. (“Schwab”) and Interactive Brokers, LLC. 15  As a fiduciary, we are obligated to seek out the best execution of client transactions for accounts that we manage. In general, the execution of securities transactions is at a total cost to process each transaction and are the most favorable under the circumstances. However, we do not limit the best execution to the lowest available price. Additional factors are taken into consideration when determining the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review consists of reviewing the commission and fee structures of various broker-dealers, research platforms, and execution services. Accordingly, while we consider competitive rates, we do not necessarily obtain the lowest possible commission rates for account transactions. Therefore, the overall services provided by unaffiliated broker- dealers and qualified custodians are evaluated to determine the best execution. You can pay trade execution charges and higher commissions through the trading platforms approved by us than through platforms that have not been approved by us. RESEARCH AND OTHER BENEFITS Products & Services Available to Us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed description of Schwab’s support services: Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but cannot directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We can use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); • facilitates trade execution and allocates aggregated trade orders for multiple client accounts; • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and • assists with back-office functions, recordkeeping, and client reporting. 16  Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. BROKERAGE FOR CLIENT REFERRALS We do not receive client referrals from broker-dealers. DIRECTED BROKERAGE We do not recommend, request, require, or permit clients to direct us to executed transactions through a specific broker-dealer other than those we recommend. TRADE AGGREGATION We attempt to allocate trade executions in the most equitable manner possible, taking into consideration current asset allocation and availability of funds using price averaging, proration, and consistently non- arbitrary methods of allocation. We can aggregate orders in order to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. In aggregated orders, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. ITEM 13 Review of Accounts PERIODIC REVIEWS We review asset management and retirement plan accounts no less than quarterly. These accounts will be reviewed by Investment Advisor Representative (“IAR”) of the account. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current investment trends. Financial plans created utilizing our ongoing financial planning services will be reviewed quarterly by the IAR on the account. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. 17  Project-based financial planning clients are provided a one-time plan or consulting session and receive no additional reviews unless a new financial planning and consulting agreement is executed. REVIEW TRIGGERS We conduct periodic reviews to evaluate the current market, economic and political events and how these can affect client accounts. Additional reviews can be triggered by these events or by events in the client’s financial or personal status. REGULAR REPORTS Asset management clients will receive advisory account reports no less than quarterly from the custodian. These reports show asset value by cash balances, security, unit cost, total cost, current per share values, etc. Clients are urged to review the quarterly reports. Clients are encouraged to phone or e-mail us as often as they deem necessary to receive information regarding the investment tactics and strategies being followed. Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during plan reviews. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. Project-based financial planning and consulting clients are provided a one-time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Retirement plan clients can create and/or review the plan’s Investment Policy Statement (“IPS”). The plan client can also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks set forth in the IPS or as otherwise determined in our judgment. The information used to generate the reports will be derived from statements provided by the plan fiduciary or third party. This review will include a quantitative and qualitative analysis of investment selections included within the plan and provide third-party commentary on investment options whenever available. The plan client may also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks or as otherwise determined in our judgment. The information used to generate the reports will be derived from a third party. ITEM 14 Client Referrals and Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial, or other interests in us (or in which we have such an interest). You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). 18  Please see Item 12 Brokerage Practices for information regarding the benefits we receive from our custodian. We do not pay a referral fee to third-party promoters. ITEM 15 Custody We are deemed to have custody as a result of our Standing Letters of Authorization (“SLOA(s)”) to transfer funds from their account to third parties. In such instances where we act under such an SLOA, it is our policy to only initiate these transactions when directed by the client to transfer funds to a third party the client designates for a designated amount and at a designated time, all of their choosing. A surprise examination is not required in this circumstance where we are deemed to have custody due to SLOAs, as we are relying on the conditions set forth in the No-Action letter issued by the Securities and Exchange Commission on February 21, 2017. Pursuant to the conditions set forth in the No-Action Letter, we confirm that in those situations • you provide an instruction to the qualified custodian, in writing, that includes your signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed; • you authorize us, in writing, either on the qualified custodian’s form or separately, to direct • transfers to the third party either on a specified schedule or from time to time; the qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify your authorization, and the qualified custodian provides a transfer of funds notice to you promptly after each transfer; • you have the ability to terminate or change the instruction to the qualified custodian; • we have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in your instruction; • we maintain records showing that the third party is not a related party of TrueHaven or located • at the same address as TrueHaven; and the qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16 Investment Discretion DISCRETIONARY AUTHORITY FOR TRADING If you are participating in our asset management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account and can also implement trades on a discretionary basis. When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction. If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, and whether the security should be bought or sold before implementing changes in your account. 19  Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price. On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be purchased or sold in your account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement. ITEM 17 Voting Client Securities We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account. The responsibility for voting your securities places increased liability to us and does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting your securities. Therefore, you are responsible for voting all proxies for securities held in accounts managed by us. Typically, our qualified custodian will forward you your proxy information. Although we do not vote your proxies, you can contact us if you have a question about a particular proxy. ITEM 18 Financial Information We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. We are currently not in, nor have we been historically, in a financially precarious situation or the subject of a bankruptcy petition. 20