A. Description of the Advisory Firm
Pine Valley Investments (hereinafter “PVI”) is a Limited Liability Company organized in the State of
New Jersey. The firm was formed in October 2014, and the Managing Member is Harry Morad.
Harry Morad, Joseph Duncan, and Michael Modica are founding partners at Pine Valley Planning,
PV Capital, LLC, and Pine Valley Consulting. PV Capital, LLC is the manager to PV Opportunity Fund
Series I, LLC, a private investment fund. PV Capital, LLC may serve as manager to one or more
private investment funds in the future. PV Capital, LLC is owned by Harry Morad, Joseph Duncan,
Michael Modica, and others. Pine Valley Planning is a licensed insurance producer through which
Pine Valley Investments investment adviser representatives may be licensed to sell insurance.
B. Types of Advisory Services
Portfolio Management Services - (PVI-introduced clients)
PVI renders investment advice to clients through its investment adviser representatives. PVI often
refers to these clients as “PVI-introduced clients”. For these clients, PVI offers ongoing portfolio
management services based on the individual goals, objectives, time horizon, and risk tolerance of
each client. PVI uses information collected from clients in its Client Profile Sheet (which is an
exhibit to its Investment Advisory Contract), which outlines the client’s current situation (income,
net worth, investment experience, and risk tolerance levels) and then constructs a plan to aid in
the selection of a portfolio that matches each client's specific situation. Portfolio management
services include, but are not limited to, the following:
Investment Strategy
Asset Allocation
Risk Tolerance
Performance Reporting
Asset Selection
Regular Portfolio Monitoring
PVI evaluates the current investments of each client with respect to their risk tolerance levels
and time horizon. In its Investment Advisory Contract, PVI requests discretionary authority
from clients in order to select securities and execute transactions without permission from the
client prior to each transaction. Risk tolerance levels are determined by a questionnaire which
is given to each client, along with on-going correspondence.
Investment Management Services through Tri-Party Agreements (Referred Clients)
PVI may also enter into Tri-Party Agreements with other investment advisers and their clients.
PVI refers to these clients as “Referred Clients”. These Tri-Party agreements delegate services
between the other investment adviser (referred to in the Tri-Party Agreement as an “Adviser”
and PVI (referred to in the Tri-Party Agreement as the “Manager”)). The Adviser is engaged by
the Referred Client to assist the Referred Client with the day-to-day interactions related to the
management of the Referred Client’s investment assets. Among other responsibilities, the
Adviser is responsible for (1) assisting the Referred Client with completing a Client Profile
Sheet, (2) developing the referred Client’s investment objectives, (3) serving as the Referred
Client’s primary contact with respect to their
account, (4) assisting the Referred Client with the
selection of an investment strategy, and (5) communicating any restrictions to PVI. PVI is
responsible for the investing activities of each Referred Client’s account.
Pension Consulting Services
PVI offers ongoing consulting services to pension or other employee benefit plans (including
but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon,
and/or risk tolerance of the plan’s participants.
Subadvisor Services
PVI may also act as a subadvisor to advisers unaffiliated with PVI. These third-party advisers
would outsource portfolio management services to PVI. This relationship will be memorialized
in each contract between PVI and the third-party advisor.
Selection of Other Advisers
PVI has discretion to choose third-party investment advisers to manage all or a portion of the
client's assets. These investments may be allocated either through the third-party adviser's
fund or through a separately managed account managed by such third-party adviser on behalf
of PVI's client. PVI may also allocate among one or more private equity funds or private equity
fund advisers. PVI will review the ongoing performance of the third-party adviser as a portion
of the client's portfolio.
Selection of another adviser may come at the request of the client.
C. Client Tailored Services and Client Imposed Restrictions
For PVI-introduced clients, PVI will tailor a program for each individual client. This will include
necessary communication to get to know the client’s specific needs and requirements as well
as a plan that will be executed by PVI on behalf of the client. PVI may use “model portfolios”
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the
restrictions prevent PVI from properly servicing the client account, or if the restrictions would
require PVI to deviate from its standard suite of services, PVI reserves the right to end the
relationship. For Referred Clients, PVI generally manages the Referred Client’s account
according to the investment strategy or model portfolio selected by the Referred Client and
their Adviser. Referred Clients may impose restrictions on investing in certain securities or
types of securities, subject to PVI’s acceptance.
D. Wrap Fee Programs
A wrap fee program is an investment program wherein the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. PVI does
not currently participate in any wrap fee programs.
E. Assets Under Management
PVI has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 1,742,507,212 $ 0 December 31, 2023
PVI has the following assets under advisement:
AUA:
$ 118,341,908