ITEM 1 - COVER PAGE
This Brochure provides information about the qualifiations and business practices of Harvard Avenue Consultants, LLC (“Harvard Avenue” or “Harvard Avenue Investment Advisory”). If you have any questions about the contents of this Brochure, please contact us at 480-236-0714. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser.
Additional information about Harvard Avenue also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Harvard Avenue is 291787.
ITEM 2 – MATERIAL CHANGES
Since the previous annual update, which was on February 5, 2019, the following material changes have happened:
Managed Assets are $31,300,604
ITEM 3 - TABLE OF CONTENTS
Contents
ITEM 5 – FEES AND COMPENSATION 4
Harvard Avenue Annual Advisory Fees 4
ITEM 6 – PERFORMANCE‐BASED FEES AND SIDE‐BY‐SIDE MANAGEMENT 5
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 6
Methods of Analysis and Investment Strategies 6
Analysis of a Client’s Financial Situation 6
ITEM 9 – DISCIPLINARY INFORMATION 8
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 8
ITEM 12 – BROKERAGE PRACTICES 9
ITEM 13 – REVIEW OF ACCOUNTS 9
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 10
ITEM 16 – INVESTMENT DISCRETION 10
ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING) 10
ITEM 18 – FINANCIAL INFORMATION 11
ITEM 19 - MANAGEMENT AND PERSONAL 11
ITEM 4 - ADVISORY BUSINESS
Harvard Avenue has been in business since January 2018 and is owned by Jered & Grace Ann Skousen.
Currently, Harvard Avenue manages $31,300,604 in client assets.
Harvard Avenue provides fee‐only, discretionary portfolio management services to individual investors and retirement plans.
Harvard Avenue offers ongoing portfolio management services based on the individual goals, objectives, time horizon and risk tolerance of each client. Harvard Avenue creates an Investment Policy Statement with each client, which outlines the client’s current situation (contributions, goals and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to the following:
• Investment strategy
• Personal investment policy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring
Harvard Avenue evaluates the current investments of each client with respect to their goals, risk tolerance levels and time horizon. Harvard Avenue will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. It is, however, the policy of Harvard Avenue that whenever reasonable, potential changes are discussed the client prior to implementation. Risk tolerance levels are documented in the Investment Policy Statement and serve as a guide for portfolio construction.
Harvard Avenue primarily recommends the use of no‐load mutual funds and ETFs, like those offered by Dimensional Fund Advisors (DFA), Schwab, and Vanguard which follow a low‐cost, non-predictive, evidence-based investment philosophy with low holdings turnover. DFA‐sponsored funds in particular provide Harvard Avenue clients access to institutional class passively‐managed mutual funds not generally available to the investing public.
Harvard Avenue also may provide advice on corporate debt securities, certificates of deposit, variable investment company products and government bonds. Harvard Avenue provides limited advice on individual equity securities (stocks), which present non‐diversified risks that are generally difficult to quantify, due to their concentrated exposure to industry and company specific factors.
Harvard Avenue may also provide, when desired by the client, specific fixed income services such as direct investment in laddered fixed income securities with date‐certain maturities. Such services are only offered when the size of the client’s fixed income allocation provides benefit in holding date‐certain instruments to better manage interest rate risk, fund planned account withdrawals, and lower investment costs and address other relevant factors versus the allocation to fiixed income mutual funds.
Harvard Avenue may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, rebalancing for over and underweighted asset classes in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance.
Broad based asset allocation using passively‐managed, low turnover investments is the primary way Harvard Avenue attempts to manage clients’ investment risk while providing the returns that the investing markets provide.
Harvard Avenue may conduct educational-based financial class. A nominal fee (less than $20) may be charged for admission. If an attendee is not able to attend and lets us know at least 48 hours prior to the class, we will happily refund the fee. Additionally, if they are not able to attend that class, the fee can be applied to a future class. Those charges defray the cost of holding the event, and the fees are not a profit center for the company.
Harvard Avenue also conducts financial planning as part of the services offered to clients. Using input provided by the client, advisors at Harvard Avenue use software to project cash flow and investment growth in order to help clients understand the money needed for retirement, college savings or other future events.
By way of an Investment Advisory Agreement, clients provide Harvard Avenue written authority to manage their account investments on a discretionary basis. Clients may impose restrictions on investing in certain securities or types of securities. Such restrictions shall be included in the Investment Advisory Agreement. Clients may change or amend these restrictions at any time. All changes or amendments must be in writing.
In the course of providing discretionary investment advisory services, Harvard Avenue does not provide custodial or other such administrative services. AT NO TIME WILL HARVARD AVENUE ACCEPT OR MAINTAIN CUSTODY OF CLIENT FUNDS OR SECURITIES. Custodial services are provided by an independent third party custodian. Harvard Avenue has standing authority for transferring funds on behalf of Firm clients (SLOA). These SLOAs have been put in place upon the client’s written request and signature. However, the discretion to move money from a client’s account to a third-party is outside the Firm’s existing authority, if the request is not submitted by the client, in writing, affirmed by Harvard Avenue and presented to the custodian. For example, the amount or timing of a disbursement request may not be on the SLOA originally submitted to the custodian; however, at a future date, a client may contact Harvard Avenue requesting the adviser submit instructions to the custodian to remit a specific dollar amount from the account to the designated third-party. The process shall require additional consent as outlined by the parties. In addition, Harvard Avenue meets the seven conditions the SEC has set forth that are intended to protect client assets in such situations.
See Item 15 of this brochure regarding Custody and Item 16 regarding Investment Discretion.
ITEM 5 – FEES AND COMPENSATION
Pursuant to Harvard Avenue’s Investment Advisory Agreement signed by each client, the client pays Harvard Avenue an annual advisory fee, which is collected quarterly in advance, based on the value of assets under management as of close of business on the last business day of the prior calendar quarter. The account balance on which Harvard Avenue calculates its fee may vary slightly from the account custodial statement due to rounding or timing differences in how accrued interest is reported, for example (see Item 15 of this brochure regarding Custody). Client provides written authorization to withdraw fee directly from client’s account. Fee withdrawal occurs at the start of the new calendar quarter and is performed by Harvard Avenue’s back office administrator. Harvard Avenue sends client an informational invoice showing the amount of the fee, the value of client’s asset on which the fee is based, and computation of the fee, according to the following schedule attached as Exhibit A to the signed Investment Advisory Agreement:
Harvard Avenue Annual Advisory Fees
Assets Under Management Annual Fee
Up to $1,000,000
0.9%
$1,000,000 to $2,000,000
0.5%
Over $2,000,000
0.3%
Investment accounts initiated or terminated during a calendar quarter will be charged a prorated advisory fee.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded to client, and any earned, unpaid fees will be due and payable to Harvard Avenue. Because quarterly fees are charged in advance, clients will be refunded fees for the prorated portion of the quarter that Harvard Avenue was not the client’s advisor.
Advisory fees are set (see the table above for the current fees) at the time a client signs up with the firm and signs the Investor Advisory Agreement; after the agreement is signed, fees are executed according to that document. Harvard Avenue does not negotiate fees, but does offer discounts to select friends, employees and family. Advisory fees are separate and distinct from expenses charged by mutual fund companies, which are described in each fund’s prospectus and generally include an internal management fee and other fund expenses. A client may be able to invest in these products directly, without the services of Harvard Avenue. In that case, the client would not receive the services provided by Harvard Avenue which are designed, among other things, to assist the client in determining which products or services are most appropriate to each client’s financial condition and investing objectives.
Harvard Avenue may conduct educational-based financial class. A nominal fee (less than $20) may be charged for admission. Admission fees are charged per person, but may include a discount for a couple. If an attendee is not able to attend and lets us know at least 48 hours prior to the class, we will happily refund the fee. Additionally, if they are not able to attend that class, the fee can be applied to a future class. Those charges defray the cost of holding the event, and the fees are not a profit center for the company.
Clients are also responsible for any custodial fees and security transaction fees charged by the independent custodian and executing broker‐dealer. These are also separate from Harvard Avenue’s advisory fee. Harvard Avenue does not receive any portion of these third‐party charges. Also, Harvard Avenue does not accept any commissions for the sale of securities or other investment products, including asset‐based distribution fees from the sale of mutual funds.
The client is encouraged to review third‐party fees, mutual fund fees and the fee charged by Harvard Avenue to fully understand total fees to be paid.
Financial planning is included in the fees paid by clients. Non-clients that would just like a financial plan can pay for that as a one-time $1,500 charge.
Harvard Avenue does not accept compensation for the sale of securities, investments products, or as a placement agent for limited partnership interests.
See Item 12 of this brochure for the factors Harvard Avenue considers in selecting or recommending custodians/broker‐dealers and determining the reasonableness of their charges.
ITEM 6 – PERFORMANCE‐BASED FEES AND SIDE‐BY‐SIDE MANAGEMENT
Harvard Avenue does not charge performance‐based fees of any kind. In addition, Harvard Avenue does not participate in any wrap fee programs.
ITEM 7 – TYPES OF CLIENTS
Harvard Avenue provides portfolio management services to individuals, high‐net‐worth individuals including trusts, as well as pension and profit sharing plans.
Harvard Avenue has a minimum account size of $250,000.00.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis and Investment Strategies
Harvard Avenue’s services are based on long‐term investment strategies incorporating the principles of Modern Portfolio Theory (MPT). Harvard Avenue’s investment approach is firmly rooted in the belief that markets are “efficient” and that investor returns are determined principally by asset allocation decisions, rather than market timing or stock picking. Harvard Avenue recommends diversified portfolios, primarily through the use of non-predictive managed, asset class mutual funds. Nonetheless, Harvard Avenue portfolio recommendations principally hold broadly‐traded open end mutual funds and in some cases conservative date‐certain fixed income securities to implement this investing strategy. Harvard Avenue may also periodically use Exchange Traded Funds (ETFs) to represent an asset class.
Although all investments involve risk, Harvard Avenue’s investment recommendations seek to limit risk through broad diversification in global equity classes and as appropriate for each client, an allocation to conservative fixed income securities for the fixed income class. Harvard Avenue’s investment philosophy is designed for investors who desire a buy and hold strategy, with five and even ten or more years of equity‐investing time horizon. Harvard Avenue’s approach also seeks to minimize the frequent trading of securities which typically decreases portfolio performance due to increased brokerage and other transaction and tax costs borne by clients. Investors who do not commit to a MPT philosophy may not achieve desired long‐term results.
Clients may wish to hold or retain other types of assets as well, such as actively managed funds and individual stocks, for example. Harvard Avenue can offer advice regarding those various assets as part of its service. Advice regarding such assets may not generally involve asset management services, but may help to more generally assist the client with their particular needs. Harvard Avenue will emphasize the increased cost associated with trying to time the market through active management or in holding individual stocks where non‐diversified risks are difficult to quantify due to concentrated exposure to specific industries and companies.
The investment strategies implemented by Harvard Avenue do not utilize securities classified as having significant or unusual risks, beyond that of the general domestic and international equity markets.
Nonetheless, past performance does not guarantee future returns. Investing in securities involves risk of loss that you, as the client, should be prepared to bear.
Harvard Avenue relies on research from multiple resources such as, commercially available investment services, financial newspapers, periodicals and prospectuses. Harvard Avenue also receives research from Dimensional Fund Advisors, Vanguard, and from other consultants, including economists affiliated with Dimensional Fund Advisors (DFA). DFA provides historical market analysis, risk/return analysis and continuing education to Harvard Avenue. Harvard Avenue in turn, seeks to pass this information on, in an ongoing effort to educate and inform clients and prospects on prudent investing strategies and practices to better understand objective risk/return tradeoffs.
Analysis of a Client’s financial Situation
In developing investment plans for clients, including the recommendation of an appropriate asset allocation, Harvard Avenue relies on the client’s financial objective, current and estimated future resources, and their stated tolerance for risk. And in some cases, Harvard Avenue may use Monte Carlo simulation analysis, a standard statistical approach for dealing with uncertainty.
As with any method used to make projections into the future, there are several risks associated with such projections, which may result in client’s not achieving their financial goals. These include, but are not limited to:
The risk that expected future cash flows do not match those used in the analysis
The risk that future rates of return fall short of historical levels or projected estimates
The risk that market volatility exceeds historical levels or projected estimates
The risk that inflation is greater than historical levels or projected estimates
That government tax rates are higher than projected, which adversely impacts both taxable account performance and after‐tax proceeds from deferred account withdrawals
Risk of Loss
Please read this section carefully.
All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment.
The mutual funds and ETFs utilized by Harvard Avenue may include funds invested in domestic and international equities, including real estate investment trusts (REITs), corporate and government fixed income securities and commodities.
Equity securities may include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings.
Among the riskiest mutual funds used in Harvard Avenue’s investment strategies are U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities or TIPS) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer‐term bonds.
Certain funds utilized by Harvard Avenue may contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in emerging countries.
More information about the risks of any particular market sector can be reviewed in representative mutual fund prospectuses managing assets within each applicable sector.
Investing in securities involves risk of loss that you, as the client, should be prepared to bear.
It is the very nature of this future loss uncertainty that produces higher rates of return over time. The key words are “over time.” Meaning that in the course of pursuing a higher return, one has to be able to handle inevitable short‐term volatility surprises. Such volatility translates to the risk of locked‐in investment loss if money must be withdrawn in a down market, which is precisely what makes investing time horizon so critically important.
To make investing more comfortable, volatility must be reduced. One way is to accept much lower rates of return. But lower rates of return expose the investor to inflation risk.
A better way to reduce volatility is to invest consistent with the tenants of MPT and passivity. Invest passively in non‐correlating assets classes across global markets moving in different directions over time.
Diversification works to eliminate non‐compensated specific industry and company risk, leaving only inherent market risk with which to contend.
Therein lies the key to successful MPT investing:
Consistent and methodical saving to fund investment
Allow plenty of investing time horizon as a means to ignore inherent market volatility.
Build a massively diversified portfolio of worldwide holdings constructed to your personal volatility/risk tolerance.
Ignore the market’s inherent volatility
Accepting the market’s inherent volatility is ultimately what earns you a higher rate of return over time.
ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Harvard Avenue or the integrity of Harvard Avenue’s management. Harvard Avenue has never been subject to regulatory, disciplinary or legal action and no one at Harvard Avenue has been the subject of regulatory or disciplinary action.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Harvard Avenue or any its management persons does not have any relationship or arrangements with any of the following: a broker-dealer, municipal securities dealer, or government securities dealer or broker; an investment company or other pooled investment vehicle (e.g. mutual fund, private fund, etc.); a futures commission merchant, commodity pool operator, or commodity trading advisor; a banking or thrift institution; an accountant or accounting firm; a lawyer or law firm; an insurance company or agency; a pension consultant; a real estate broker or dealer; or a sponsor or syndicator of limited partnerships.
Harvard Avenue does not recommend or select other investment advisers for its clients.
ITEM 11 – CODE OF ETHICS
Harvard Avenue ensures securities are conducted in a manner that avoids any actual or potential conflict of interest between Access Persons of Harvard Avenue and clients of Harvard Avenue.
Harvard Avenue does not recommend that clients buy or sell any securities in which a related person to Harvard Avenue has a material financial interest.
Because we “put our money where our mouth is,” representatives of Harvard Avenue will buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Harvard Avenue to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Harvard Avenue will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold.
Due to the relative size and liquidity of the investments used by Harvard Avenue, the timing of trades in client accounts vs. personal accounts is a non-issue. However, representatives of Harvard Avenue will conduct all client transactions for a given day before placing any trades for their personal accounts. This policy virtually eliminates the potential conflict of interest that could arise if representatives of Harvard Avenue were to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients.
Clients and prospective clients having any questions about Harvard Avenue’s ethics may speak to Chief Compliance Officer Jered Skousen at 480-236-0714 or jered@harvardave.com.
ITEM 12 – BROKERAGE PRACTICES
Harvard Avenue selects the custodians/broker‐dealers it recommends to clients based on trading access to investment securities, reliable trade execution, competitive fees, quality of custodial services, customer service ease of access, and reputation in the industry.
Harvard Avenue does not receive research or other products or services (better known as “soft dollar benefits”) in exchange for clients paying higher fees and commissions than those charged by other custodians/broker‐dealers. Harvard Avenue will never charge a premium or commission on transactions, beyond the actual cost imposed by custodian/broker‐dealer. Further, Harvard Avenue does not aggregate orders.
Harvard Avenue will not receive a referral fee or client referrals from custodial in exchange for clients using a recommended custodian/broker‐dealer.
Although Harvard Avenue allows clients to direct brokerage, Harvard Avenue may be unable to achieve most favorable execution of client transactions if client chooses to direct brokerage. Additionally, client may pay higher brokerage commissions or received less favorable prices if client chooses to direct brokerage.
ITEM 13 – REVIEW OF ACCOUNTS
Accounts are reviewed at least quarterly and rebalanced when warranted.
Rebalancing or re‐optimizing can also be triggered in connection with the following events:
Account deposits and withdrawals
Changes in client’s financial situation or risk tolerance (retirement, change or loss of employment, physical relocation, inheritance, unexpected financial burden or windfall, change in marital status, tax law changes impacting client, etc.)
Material market shifts, major economic, or political events
Rebalancing is accomplished by reallocating assets to original allocation target percentages. Re‐optimizing involves setting new asset allocation target percentages.
The client will receive written or electronic statements at least quarterly from their account custodian. Harvard Avenue also provides quarterly portfolio performance reports in written or electronic form.
In addition, the client will receive other supporting reports from Mutual Funds, Trust Companies or Custodians, Insurance Companies, Broker/Dealers and others who are involved with client accounts. See Item 16 of this brochure regarding Custody.
It is the client’s responsibility to notify Harvard Avenue whenever there is a material change in their financial situation or risk tolerance to warrant a change in their investment plan and/or asset allocation.
From time-to-time Harvard Avenue may make an error in submitting a trade order on your behalf. When this occurs, Harvard Avenue may place a correcting trade with the broker-dealer which has custody of your account.
If an investment gain results from the correcting trade, the gain will remain in your account unless the same error involved other client account(s) that should have received the gain, it is not permissible for you to retain the gain, or we confer with you and you decide to forego the gain (e.g., due to tax reasons). If the gain does not remain in your account and Charles Schwab & Co. Inc. (“Schwab”) is the custodian, Schwab will donate the amount of any gain $100 and over to charity.
If a loss occurs greater than $100, Harvard Avenue will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in your account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they may be netted.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Harvard Avenue does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Harvard Avenue clients. Harvard Avenue does not pay client referrals fees, directly or indirectly, to any third parties.
ITEM 15 – CUSTODY
Harvard Avenue does not take custody of a client account or accept or maintain custody of client funds or securities. Custodial services are provided by an independent third party Custodian. Harvard Avenue has standing authority for transferring funds on behalf of Firm clients (SLOA). These SLOAs have been put in place upon the client’s written request and signature. Harvard Avenue’s existing authority regarding client account disbursements is exclusive to the SLOA submitted to the Custodian.
Clients will receive statements at least quarterly from the custodian holding their investment assets. Harvard Avenue urges clients to carefully review such statements and compare these custodial records with the quarterly reports provided by Harvard Avenue.
Harvard Avenue reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
ITEM 16 – INVESTMENT DISCRETION
By way of the Investment Advisory Agreement, client grants Harvard Avenue written limited power of attorney to select the identity and amount of securities to be bought and sold in their account as well as the custodian/broker-dealer to execute transactions. In all cases, this discretion is exercised in a manner consistent with the investment objectives for the particular client account.
When selecting securities and determining amounts, Harvard Avenue observes any limitations imposed by client. Such limitations shall be included in the Investment Advisory Agreement. Client may change or amend these limitations at any time. All changes or amendments must be provided to Harvard Avenue in writing.
ITEM 17 – VOTING CLIENT SECURITIES (PROXY VOTING)
Harvard Avenue does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Also, Harvard Avenue does not give any advice or take any action with respect to the voting of these proxies. Clients and Harvard Avenue agree to this in writing pursuant to the signed Investment Advisory Agreement.
Clients will receive applicable proxies directly from the issuer of securities held in clients’ investment portfolios. Clients should direct all proxy questions to the issuer of the security.
Note that Harvard Avenue will neither advise nor act on behalf of clients in legal proceedings involving companies whose securities are held or previously were held in clients’ account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements.
ITEM 18 – FINANCIAL INFORMATION
Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about Harvard Avenue’s financial condition. Harvard Avenue has no financial commitment that impairs its current or future ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
ITEM 19 - MANAGEMENT AND PERSONAL
A | Principal Executive Officers and Management Persons; Their Formal Education and Business Background
Harvard Avenue currently has only one management person/executive officer: Jered Skousen. Mr Skousen’s education and business background can be found on the Supplemental ADV Part 2B form.
B | Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)
Mr. Skousen’s other business activities can be found on the Supplemental ADV Part 2B form.
C | How Performance-based Fees are Calculated and Degree of Risk to Clients
Harvard Avenue does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client.
D | Material Disciplinary Disclosures for Management Persons of this Firm
No management person at Harvard Avenue or Harvard Avenue itself has been involved in an arbitration claim or been found liable in a civil, self-regulatory organization, or administrative proceeding that is material to the client’s evaluation of the firm or its management.
E | Material Relationships That Management Persons Have With Issuers of Securities (If Any) Neither
Harvard Avenue, nor its management persons, has any relationship or arrangement with issuers of securities.