Marble Harbor was founded in November 2005 by Managing Member and Principal Owner, Paul R.
Davis. Marble Harbor is wholly owned by five members: four current employees and one retiree of
Marble Harbor.
Marble Harbor provides continuous investment advisory services to our clients based on their individual
needs. We work closely with each client to become and remain familiar with the client’s financial
circumstances, investment objectives, time horizons, risk tolerance, and liquidity needs. As appropriate,
we also review and discuss a client’s prior investment history, as well as family composition and
background. In addition, we ask our clients to promptly notify us in writing of any material changes to
their financial condition including, but not limited to investment objectives, risk tolerance, investment
time horizon, net worth, and annual income. Please see Item 7-Types of Clients for further information
regarding Marble Harbor’s clients.
Marble Harbor also provides investment advisory services to MHIC Devereux Partners, LLC, MHIC Fort
Sewall Partners, LLC and MHIC Ventures I, LLC (together, the “Private Funds”).
Typically, Marble Harbor advises client portfolios on a discretionary basis, although some client
portfolios may be on a non-discretionary basis.
Account supervision is guided by the client’s individual needs, stated objectives (i.e., maximum capital
appreciation, growth, income, or growth and income), as well as tax considerations and risk tolerance.
Each client is required to enter into an Investment Advisory Agreement with Marble Harbor (the
“Advisory Agreement”) that describes the overall terms of the advisory relationship. Clients may impose
reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service and generally will
include advice regarding the following securities:
Exchange-listed securities
Securities traded over-the-counter
Foreign issuers
Warrants
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Mutual fund shares
Exchange-traded funds
United States governmental securities
Options contracts on securities
Interests in partnerships investing in real estate
Interests in partnerships investing in oil and gas interests
Because all the above referenced investments involve certain additional degrees of risk, they will only be
recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity,
suitability, and eligibility. Investing in securities involves risk of loss that all clients should understand
and be prepared to bear.
We may also recommend to appropriate advisory clients:
Investments in private placement offerings and/or limited investment partnerships (i.e., hedge
funds and venture capital funds); and/or
Other pooled investment vehicles including those organized and sponsored by Marble Harbor.
Investments in these types of private investment vehicles:
Are not registered with or regulated by the SEC;
Are available only to
clients that are deemed to be an “accredited investor” or a “qualified client”
or a “qualified purchaser” in accordance with the requirements set forth in applicable laws, rules
and regulations;
Typically require investors to lock-up their assets for a period of time;
Can have limited or no liquidity;
Involve different risks than investing in registered funds and other publicly offered and traded
securities; and
Are only recommended when consistent with the client’s stated investment objectives, tolerance
for risk, liquidity, and suitability.
Additional information about the fees related to such investments is included in the private offering
documents provided to prospective investors. We rely on the evaluation and performance data provided
directly from the private investment vehicles. Private investment vehicles are often delayed in providing
us with this information, which will delay us in reporting this information to clients.
Please see Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for further information
regarding our investment strategies.
Retirement Account Rollover Considerations: Marble Harbor owes a fiduciary duty to its clients under
the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and when we provide investment
advice to you regarding your retirement plan accounts or individual retirement accounts (IRAs), we are a
fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”)
and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts.
The way we earn money can conflict with your interests, so we operate under a rule that requires us to act
in your best interest and not put our own interest ahead of yours. Under this rule’s provision, we must:
Meet a professional standard of care when making investment recommendations
(give prudent advice);
Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
Avoid misleading statements about conflicts of interest, fees and investments;
Follow policies and procedures designed to ensure we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
A recommendation to roll over your assets from a retirement account to an account to be managed by
Marble Harbor creates a conflict of interest. This is because we will earn additional advisory fees as a
result of the roll over. There is no obligation for you to roll over your retirement account to an account
managed by Marble Harbor.
Marble Harbor is not a financial planner. We do not offer tax, insurance, or legal advice, but will gladly
work with a client’s tax, insurance, financial planning and/or legal advisor to discuss individual needs and
develop investment recommendations.
Currently, Marble Harbor does not participate in any wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2023, the total amount of regulatory assets under management by Marble Harbor was
$1,127,302,147 all of which was on a discretionary basis.