Star Harbor Investments is a investment adviser based in Tampa, FL, that holds a 94.6/100 Fidelon TransparencyScore (90th percentile among SEC-registered advisers), with 1 registered advisor. Score based on public SEC and FINRA filings.
Star Harbor Investments
Star Harbor Investments INC · CRD #335139
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Star Harbor Investments INC is an SEC-registered investment adviser in Tampa, FL. It has one registered advisor. It charges a yearly percentage of your account that gets smaller as the account grows, and it does not report earning commissions. Its services include financial planning. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
1,065th of 10,815
SEC-registered advisers
Top 10%
83rd of 799
SEC-registered advisers in FL
Top 11%
4th of 55
SEC-registered advisers in Tampa, FL
Top 7%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Does not earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $500,001 - $2,000,000.
This fee is negotiable
“Advisor may negotiate fees based upon factors such as account size, a Client’s relationship with the firm, workload and complexity of assets being managed.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Custodian fees may include wires, account transfers, transfer agent services, margin account interest, late settlement and postage fees.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $0 - $100,000 | 2.00% |
| $100,001 - $500,000 | 1.75% |
| $500,001 - $2,000,000 | 1.50% |
| $2,000,001 and above | 1.25% |
Billed quarterly in advance
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“As your asset base changes, you will see an increase in the fee if your value has increased. Therefore, the firm may have an incentive to encourage you to increase the assets in your account or manage them in a way where we receive higher fees.”
“Third-Party Payments: While we do not receive compensation from third parties when we recommend investments, our supervised persons or affiliates may recommend insurance products in their individual capacities.”
Source: the firm’s own Form CRS, filed 2025-03-31 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
100/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
68/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 75/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 64/100
- Can you tell what you would pay?
- What you pay
- 85/100
- Is it written in plain English?
- Plain language
- 90/100
This firm's Form CRS averages 78 out of 100 and adds 4.62 points to the score above.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Fees for individually managed accounts are tier priced as follows:p. 5
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Advisor may negotiate fees based upon factors such as account size, a Client’s relationship with the firm, workload and complexity of assets being managed.p. 5
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
All asset-based fees are deducted by the qualified custodian of record on a quarterly basis in Advance, or as otherwise indicated in the client agreement.p. 5
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Adviser's Investment management fees are payable quarterly in advance, based on the value of the account on the first day of the current quarter.p. 6
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Custodian fees may include wires, account transfers, transfer agent services, margin account interest, late settlement and postage fees.p. 6
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client by check issued to the customer as soon as practicable.p. 6
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity70/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If its people can earn insurance commissions, does it explain them?
Insurance commissions
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Members of the Firm are licensed insurance agents and may from time to time offer clients advice or products from those activities.p. 13
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
When an insurance policy is purchased by the client, the investment advisor representative is paid a commission for servicing as the agent on record.p. 13
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser.p. 13
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether anyone at the firm earns a commission on insurance recommended to you, and whether it lowers your fee.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation60/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
This practice presents a conflict of interest because persons providing investment advice on behalf of the firm who are insurance agents will have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs.p. 7
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
These representatives will earn commission-based compensation for selling insurance products, including insurance products they sell to you.p. 7
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?Not found in the brochureItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
What to askAsk whether any commission the firm earns is credited against your advisory fee.
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes no research or services from brokers
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
1 advisor
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Elizabeth J McMullen | 7350229 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #335139