Star Harbor Investments Inc

Star Harbor Investments Inc is an SEC‑registered investment adviser, founded in early 2025, that provides portfolio management and investment analysis services intended for pooled vehicles and institutional-type clients rather than a broad base of individual retail accounts; the firm’s ADV reports no assets under management as of March 31, 2026. The brochure describes the firm’s services as customized investment management, ongoing performance and exposure reviews, and the ability to place trades on a discretionary basis through a qualified custodian under limited trading authority.

The firm’s stated investment process combines technical, quantitative, fundamental, cyclical and economic analysis to drive model-informed allocation and trading decisions, and it emphasizes strategic asset allocation with both long‑ and short‑term positions. The adviser notes it may favor equity and ETF instruments in practice (and uses model outputs alongside professional judgment) and executes trades under limited power of attorney or standing letters of authorization with custodians for operational purposes.

What distinguishes this firm among its peers is that it sponsors a wrap fee program that explicitly bundles transaction, custodial and administrative “Covered Costs” into a single asset‑based advisory fee—a structure that is uncommon for investment managers of this type and creates incentives to use lower‑transaction‑cost securities. The brochure also discloses a prior employment termination of a firm principal in 2023 related to an alleged failure to escalate a client complaint (the prior firm later denied the complaint), and it documents operational practices (fee debit via custodian and SLOA procedures) that prospective institutional clients may wish to review.