Description of FirmVise AI Advisors, LLC is a registered investment adviser primarily based in New York City, NY. We are
organized as a limited liability company ("LLC") under the laws of the State of Delaware. We have
been providing investment advisory services since May 2019. We are owned by Artificial Intelligence
Labs, Inc..
Vise AI Advisors is a financial technology company focused on creating model portfolios for registered
investment advisers. Our mission is to help investment advisers grow their client's wealth by providing
access to diverse investment options.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Vise AI Advisors and the
words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Web-Based Investment Advisory ServicesWe offer discretionary investment advisory services that are delivered through an automated and
interactive web-based investment management system to registered investment advisers ("RIAs"). The
investment advice rendered is tailored to meet with your investment needs and objectives and is
delivered exclusively based upon information you submit via a web-based investment questionnaire.
Your responses to the electronic investment questionnaire are used by the web-based system to
create a model portfolio based on your client's risk profile. After submission of the online investment
questionnaire, our technology platform will provide automated model portfolios to you. It is then your
responsibility to determine whether the model is appropriate for your client. Once you pick the model
for your client, the program will automatically process the transaction. In providing investment advisory
services through the system, all information will be provided through our web-based system. Our firm
does not verify any information we receive from you or your agent(s) for accuracy, and we will rely on
the information you provide. It is your responsibility to promptly update your client's account application
through the web-based portal if there are ever any changes in your client's financial situation or
investment objectives.
We will periodically monitor your client's investments, and based on different client risk profiles, we
may recommend changes (if appropriate) through the web-based system based on your client's
particular risk profile.
If you participate in our discretionary web-based investment advisory services, we require you to grant
us discretionary authority to trade your client's account(s). Subject to a grant of discretionary
authorization, we have the authority and responsibility to formulate investment strategies on your
client's behalf. Discretionary authorization will allow us to determine the specific securities, and the
amount of securities, to be purchased or sold for your client's account without obtaining your client's
approval prior to each transaction. We will also have discretion over the broker or dealer to be used for
securities transactions in your client's account. Discretionary authority is typically granted by the
investment advisory agreement you sign with our firm, a power of attorney, or trading authorization
forms.
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Sub-Advisory Services to Registered Investment AdvisersWe offer sub-advisory services to unaffiliated third party money managers (the "Primary Investment
Adviser"). As part of these services, we will provide model portfolios, which the Primary Investment
Adviser selects for their clients. We will not directly manage the Primary Investment Adviser's individual
client accounts. The Primary Investment Adviser will be responsible for selecting the appropriate model
for its clients.
Types of InvestmentsWe primarily offer advice on exchange-listed securities, and exchange traded funds ("ETFs"). Refer to
the
Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on
this topic.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Assets Under ManagementAs of December 31, 2019, we provide continuous management services for $4,000,000 in client assets
on a discretionary basis and $0 in client assets on a non-discretionary basis.
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Web- Based Investment Advisory ServicesOur fee for web-based investment advisory services is billed and payable, quarterly in arrears, based
on the average daily balance of the assets under management in your client's account. In other words,
we will receive a portion of the advisory fee paid to you by your client. If the portfolio management
agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on
a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in
the quarter for which you are a client. Depending on the arrangements made at the inception of the
engagement, we may at our discretion discount the first quarter fees. Our fee is set forth in the
following annual fee schedule:
Annual Fee Schedule
Assets Under Management Annual Fee Up to $100,000,000 0.25%
$100,000,000 or more 0.20%
Fees and payment arrangements are negotiable and will vary on a case-by-case basis. At our
discretion, we may combine the account values of your client's accounts to determine the applicable
advisory fee. Combining account values may increase the asset total, which may result in your paying
a reduced advisory fee based on the available breakpoints in our fee schedule stated above.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. We will send you an invoice showing the
amount of the fee. Further, the qualified custodian will deliver an account statement to you at least
quarterly. These account statements will show all disbursements from your account. You should review
all statements for accuracy.
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We encourage you to reconcile our invoices with the investment advisory agreement upon written
notice to statement(s) you receive from the qualified custodian. If you find any inconsistent information
between our firm invoice and the statement(s) you receive from the qualified custodian call our main
office number located on the cover page of this brochure.
Our agreement for services will continue in effect until terminated by either party. You may terminate
the investment advisory agreement upon thirty (30) days written notice to our firm.
Sub-Advisory Services for Registered Investment AdvisersFees and payment arrangements are negotiable and will vary on a case-by-case basis.
Additional Fees and ExpensesAs part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
refer to the
Brokerage Practices section of this brochure.
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We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the
Fees and Compensation section above, and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
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We offer investment advisory services to other investment advisers.
We charge a minimum fee in the amount of $500 per month. At our discretion we may waive the
minimum fee.
We may also combine account values of your client's to meet the stated minimum for your firm.
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We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
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Algorithm specifics - The portfolio allocation algorithm will be based on the following factors but not
limited to: Age, Household Income, Risk Tolerance information, Marital Status, Retirement Goals,
Investment Time Horizon, Investment account type, household expenses, Employment Status, Target
Portfolio Value, Asset classes and sectors, and Initial Investment Value.
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected
return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected
return, by carefully diversifying the proportions of various assets.
Risk: Market risk is that part of a security's risk that is common to all securities of the same
general class (stocks and bonds) and thus cannot be eliminated by diversification.
Long-Term Purchases - securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in
the long-term which may not be the case. There is also the risk that the segment of the market
that you are invested in or perhaps just your particular investment will go down over time even if
the overall financial markets advance. Purchasing investments long-term may create an
opportunity cost - "locking-up" assets that may be better utilized in the short-term in other
investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-
term price fluctuations.
Risk: Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short-term which may be very difficult and will incur a disproportionately
higher amount of transaction costs compared to long-term trading. There are many factors that
can affect financial market performance in the short-term (such as short-term interest rate
changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer
periods of times.
Trading - As part of our primary investment strategy when managing your account(s), we will use
frequent trading (in general, selling securities within 30 days of purchasing the same securities). Short-
term trading is not appropriate for all investors and we only use it if we have determined that it is
suitable for you. Short-term trading includes buying and selling securities frequently in an attempt to
capture significant market gains and avoid significant losses.
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Risk: When a frequent trading policy is in effect, there is a risk that investment performance within
your account may be negatively affected, particularly through increased brokerage and other
transactional costs and taxes.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio. It is important that you
notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, oremployment status.Tax ConsiderationsOur strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your
custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis
of your investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is more
advantageous, provide written notice to our firm immediately and we will alert your account custodian
of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Risk of LossInvesting in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Other Risk ConsiderationsWhen evaluating risk, financial loss may be viewed differently by each client and may depend on many
different risks, each of which may affect the probability and magnitude of any potential loses. The
following risks may not be all-inclusive, but should be considered carefully by a prospective client
before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high
volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell
the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and
sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair
or erase the value of an issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client's future interest payments and principal. Inflation also
generally leads to higher interest rates which may cause the value of many types of fixed income
investments to decline.
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Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an
unforeseen event, for example, the loss of your job. This may force you to sell investments that you
were expecting to hold for the long term. If you must sell at a time that the markets are down, you may
lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for
people who are retired, or are nearing retirement.
Recommendation of Particular Types of SecuritiesWe primarily recommend exchange-listed securities, and exchange traded funds. However, we may
advise on other types of investments as appropriate for you since each client has different needs and
different tolerance for risk. Each type of security has its own unique set of risks associated with it and it
would not be possible to list here all of the specific risks of every type of investment. Even within the
same type of investment, risks can vary widely. However, in very general terms, the higher the
anticipated return of an investment, the higher the risk of loss associated with the investment.
Money Market Funds: A money market fund is technically a security. The fund managers attempt to
keep the share price constant at $1/share. However, there is no guarantee that the share price will stay
at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S.
Securities and Exchange Commission ("SEC") notes that "While investor losses in money market
funds have been rare, they are possible." In return for this risk, you should earn a greater return on
your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured
savings account (money market funds are not FDIC insured). Next, money market fund rates are
variable. In other words, you do not know how much you will earn on your investment next month. The
rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes
down and you earn less than you expected to earn, you may end up needing more cash. A final risk
you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments like stocks, long-term average returns on money market
funds tends to be less than long term average returns on riskier investments. Over long periods of
time, inflation can eat away at your returns.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as
"equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the
company issuing it. However, stock prices can be affected by many other factors including, but not
limited to the class of stock (for example, preferred or common); the health of the market sector of the
issuing company; and, the overall health of the economy. In general, larger, better established
companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the
mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are
professionally managed collective investment systems that pool money from many investors and invest
in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any
combination thereof. The fund will have a manager that trades the fund's investments in accordance
with the fund's investment objective. While mutual funds and ETFs generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a
significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing
the fund with different types of securities. ETFs differ from mutual funds since they can be bought and
sold throughout the day like stock and their price can fluctuate throughout the day. The returns on
mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual
funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds
do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open
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end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas
"closed end" funds have a fixed number of shares to sell which can limit their availability to new
investors.
ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to
cause the ETF's performance to match that of its Underlying Index or other benchmark, which may
negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track
the performance of their Underlying Indices or benchmarks on a daily basis, mathematical
compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an
ETF may not have investment exposure to all of the securities included in its Underlying Index, or its
weighting of investment exposure to such securities may vary from that of the Underlying Index. Some
ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but
which are expected to yield similar performance.
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We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. We do not have any required
disclosures under this item.
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We have not provided information on other financial industry activities and affiliations because we do
not have any relationship or arrangement that is material to our advisory business or to our clients with
any of the types of entities listed below.
1. broker-dealer, municipal securities dealer, or government securities dealer or broker;
2. investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or "hedge fund," and
offshore fund);
3. other investment adviser or financial planner;
4. futures commission merchant, commodity pool operator, or commodity trading adviser;
5. banking or thrift institution;
6. accountant or accounting firm;
7. lawyer or law firm;
8. insurance company or agency;
9. pension consultant;
10.real estate broker or dealer; and/or
11.sponsor or syndicator of limited partnerships.
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Personal Trading Description of Our Code of EthicsWe strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
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to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client TransactionsNeither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading PracticesOur firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities.
Aggregated TradingOur firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. We may also combine
our orders to purchase securities with your orders to purchase securities ("aggregated trading"). Refer
to the
Brokerage Practices section in this brochure for information on our aggregated trading practices.
A conflict of interest exists in such cases because we have the ability to trade ahead of you and
potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is
our policy that neither our firm nor persons associated with our firm shall have priority over your
account in the purchase or sale of securities.
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We recommend the brokerage and custodial services of TD Ameritrade, Inc. and Charles Schwab &
Co., Inc. (whether one or more "Custodian"). Your assets must be maintained in an account at a
"qualified custodian," generally a broker-dealer or bank. In recognition of the value of the services the
Custodian provides, you may pay higher commissions and/or trading costs than those that may be
available elsewhere.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, the most favorable compared to other available providers and their services.
We consider various factors, including:
•Capability to buy and sell securities for your account itself or to facilitate such services.
•The likelihood that your trades will be executed.
•Availability of investment research and tools.
•Overall quality of services.
•Competitiveness of price.
•Reputation, financial strength, and stability.
•Existing relationship with our firm and our other clients.
Research and Other Soft Dollar BenefitsWe do not have any soft dollar arrangements.
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Economic BenefitsAs a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products may include financial publications, information
about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker who did
not provide research services or products might charge.
Schwab - Your Custody and Brokerage CostsFor our clients' accounts it maintains, Schwab generally does not charge you separately for custody
services but is compensated by charging you commissions or other fees on trades that it executes or
that settle into your Schwab account. Schwab's commission rates and/or asset-based fees applicable
to our client accounts were negotiated based on our commitment to maintain $250 million of our
clients' assets statement equity in accounts at Schwab. This commitment benefits you because the
overall commission rates and/or asset-based fees you pay are lower than they would be if we had not
made the commitment. In addition to commission rates and/or asset-based fees Schwab charges you
a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a
different broker-dealer but where the securities bought or the funds from the securities sold are
deposited (settled) into your Schwab account. These fees are in addition to the commissions or other
compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading
costs, we have Schwab execute most trades for your account.
Schwab Adviser ServicesSchwab Advisor Services (formerly called Schwab Institutional) is Schwab's business serving
independent investment advisory firms like us. They provide us and our clients with access to its
institutional brokerage - trading, custody, reporting and related services - many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients' accounts while others help us
manage and grow our business. Schwab's support services are generally are available on an
unsolicited basis (we don't have to request them) and at no charge to us.
Services that Benefit You
Schwab's institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab's services described in this
paragraph generally benefit you and your account.
Services that May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering our
clients' accounts. They include investment research, both Schwab's own and that of third parties. We
may use this research to service all or some substantial number of our clients' accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available
software and other technology that:
•provide access to client account data (such as duplicate trade confirmations and account
statements);
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•facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
•provide pricing and other market data; o facilitate payment of our fees from our clients'
accounts; and
•assist with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
•educational conferences and events;
•technology, compliance, legal, and business consulting;
•publications and conferences on practice management and business succession;
•access to employee benefits providers, human capital consultants and insurance providers; and
•discount of up to $4,250 on PortfolioCenter® Reporting Software.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party's fees. Schwab may also provide us with other benefits such as
occasional business entertainment of our personnel.
Our Interest in Schwab's ServicesThe availability of these services from Schwab benefits us because we do not have to produce or
purchase them. These services may give us an incentive to recommend that you maintain your
account with Schwab based on our interest in receiving Schwab's services that benefit our business
rather than based on your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a potential conflict of interest. We believe, however,
that our selection of Schwab as custodian and broker is in the best interests of our clients. It is
primarily supported by the scope, quality and price of Schwab's services (based on the factors
discussed above - see "The Custodian and Broker We Use") and not Schwab's services that benefit
only us. We do not believe that maintaining our client's assets at Schwab for services presents a
material conflict of interest.
Brokerage for Client ReferralsWe do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed BrokerageWe routinely require that you direct our firm to execute transactions through TD Ameritrade, Inc.. As
such, we may be unable to achieve the most favorable execution of your transactions and you may
pay higher brokerage commissions than you might otherwise pay through another broker-dealer that
offers the same types of services. Not all advisers require their clients to direct brokerage.
Aggregated TradesWe combine multiple orders for shares of the same securities purchased for discretionary advisory
accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then
distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally,
participating accounts will pay a fixed transaction cost regardless of the number of shares transacted.
In certain cases, each participating account pays an average price per share for all transactions and
pays a proportionate share of all transaction costs on any given day. In the event an order is only
partially filled, the shares will be allocated to participating accounts in a fair and equitable manner,
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typically in proportion to the size of each client's order. Accounts owned by our firm or persons
associated with our firm may participate in aggregated trading with your accounts; however, they will
not be given preferential treatment.
We do not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts
may pay different costs than discretionary accounts pay. If you enter into non-discretionary
arrangements with our firm, we may not be able to buy and sell the same quantities of securities for
you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into
discretionary arrangements with our firm.
Mutual Fund Share ClassesMutual funds are sold with different share classes, which carry different cost structures. Each available
share class is described in the mutual fund's prospectus. When we purchase, or recommend the
purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's
best interest, taking into consideration cost, tax implications, and other factors. When the fund is
available for purchase at net asset value, we will purchase, or recommend the purchase of, the fund at
net asset value. We also review the mutual funds held in accounts that come under our management
to determine whether a more beneficial share class is available, considering cost, tax implications, and
the impact of contingent deferred sales charges.
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Runik Mehrotra, Chief Technology Officer, will monitor your client's accounts on an ongoing basis and
will conduct account reviews at least annually, to ensure the advisory services provided to you are
consistent with your client's investment needs and objectives. Additional reviews may be conducted
based on various circumstances, including, but not limited to:
•contributions and withdrawals;
•year-end tax planning;
•market moving events;
•security specific events; and/or
•changes in your risk/return objectives.
The individuals conducting reviews may vary from time to time, as personnel join or leave our firm.
We will not provide you with regular written reports. You will receive trade confirmations and monthly or
quarterly statements from your account custodian(s).
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Charles Schwab & Co., Inc - InstitutionalIn addition, we receive an economic benefit from Schwab in the form of the support products and
services it makes available to us and other independent investment advisors whose clients maintain
their accounts at Schwab. These products and services, how they benefit us, and the related conflicts
of interest are described above (see
Item 12 - Brokerage Practices). The availability to us of Schwab's
products and services is not based on us giving particular investment advice, such as buying particular
securities for our clients.
Revenue Sharing and Referral Arrangements with Riskalyze, Inc.Vise AI Advisors, LLC has entered into a revenue sharing agreement with Riskalyze, Inc. (hereinafter
referred to as "Riskalyze"). Riskalyze will provide access to specified application programming
interfaces for Vise AI, Advisors, LLC utilize in the integration of its products and services with Riskalyze
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products and services. Vise AI Advisors, LLC will distribute 0.0005% of the assets under management
fee charged to the client to Riskalyze, Inc., payable on a quarterly basis via standard account billing,
for all client assets on the platform, except Riskalyze clients who signed an engagement for services
with Vise AI Advisors, LLC first.
Vise AI Advisors, LLC does not increase advisory fees to offset these charges.
We do not receive any compensation from any third party in connection with providing investment
advice to you nor do we compensate any individual or firm for client referrals.
Refer to the
Brokerage Practices section above for disclosures on research and other benefits we may
receive resulting from our relationship with your account custodian.
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As paying agent for our firm, your independent custodian will directly debit your account(s) for the
payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our
firm to exercise limited custody over your funds or securities. We do not have physical custody of any
of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or
other qualified custodian. You will receive account statements from the qualified custodian(s) holding
your funds and securities at least quarterly. The account statements from your custodian(s) will
indicate the amount of our advisory fees deducted from your account(s) each billing period. You should
carefully review account statements for accuracy.
We will also provide statements to you reflecting the amount of the advisory fee deducted from your
account. You should compare our statements with the statements from your account custodian(s) to
reconcile the information reflected on each statement. If you have a question regarding your account
statement, or if you did not receive a statement from your custodian, contact us immediately at the
telephone number on the cover page of this brochure.
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Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
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We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitations to vote proxies.
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Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200
in fees six or more months in advance. Therefore, we are not required to include a financial statement
with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information Trade ErrorsIn the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action LawsuitsWe do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
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