This Brochure describes the investment advisory services by the Digital Advisory Solutions group (“DAS”) of Goldman Sachs & Co. LLC (“GS&Co.”). DAS provides advisory services to individuals and helps clients build and preserve their financial wealth through its technology platform. DAS’s services are available through its websites and and its mobile applications (collectively, the “Site”). Unless otherwise specified, references in this Brochure to “clients” mean DAS clients and references to the advisory services provided by GS&Co. mean the advisory services provided by DAS.

GS&Co.’s principal owner is The Goldman Sachs Group, Inc., a publicly traded bank holding company and financial holding company under the Bank Holding Act of 1956, as amended (“BHCA”), and a worldwide, full-service financial services organization. GS&Co. has been a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) since 1981. The Goldman Sachs Group, Inc., GS&Co. and their respective affiliates, directors, partners, trustees, managers, members, officers and employees are referred to collectively as “Goldman Sachs.”
Program Description

DAS offers individuals the ability to open investment advisory accounts (“Advisory Accounts”) for themselves individually, including Traditional Individual Retirement Accounts (“IRA”), Roth IRAs, and, in the case of a self-employed individual or independent contractor, a Simplified Employee Pension (“SEP”) IRAs (collectively, “Retirement Accounts”), as well as jointly with other individuals through an online platform (the “Program”). The Program is designed to provide a way for individuals to regularly invest money and access DAS’s advisory services, along with brokerage and custody services, for a single fee. The number and type of Advisory Accounts that an individual can open under the Program may be limited based on the channel by which that individual accessed the Program. The Program was previously offered by GS&Co.’s affiliate, Honest Advisors, LLC (“Honest Advisors”), which assigned its client agreements to GS&Co. in September 2018.

The Program provides investment advice and delivers advisory services to clients primarily through the Portfolio Recommendation Tool (as defined below) and the Site, and does not generally provide investment advice in person, over the phone, in live chat, or in any other manner other than through the advisory services available on the Site.

Clients establish Advisory Accounts and enter into an agreement with a financial institution (the “Custodian”) designated by DAS appointing the Custodian to serve as custodian with respect to their Advisory Accounts and provide the client with brokerage services. With respect to Retirement Accounts, the Custodian will also act as the client’s IRA custodian. The Custodian will establish and carry an account that holds the client’s cash and securities and records the transactions in such account. Subject to the terms of its agreement with the Custodian, DAS may remove or replace the Custodian at any time. The current Custodian is Apex Clearing Corporation (“Apex”), a New York corporation. Apex is a registered broker-dealer that is not affiliated with GS&Co. or its affiliates.
Portfolio Recommendation and Management
The Program is designed to prompt investing and saving behaviors and provide access to portfolios that invest through exchange-traded funds (“ETFs”) that track indices. Through the Program, DAS offers model portfolios developed by GS&Co.’s Investment Strategy Group (“ISG”) that are designed to allocate assets among ETFs representing different asset classes. DAS is currently using Portfolios that invest in unaffiliated ETFs, as well as cash, held as a free credit balance by the Custodian. ISG’s model construction process is designed to offer multi-asset class portfolios that are diversified across asset classes, regions, and the risk spectrum. In its role as sponsor of the Program, DAS does not manage the underlying ETFs. However, DAS reserves the right to change, in its sole discretion and from time to time, without prior notice to clients: (i) the number of Portfolios that it deems appropriate to address the investment objectives, investment time horizons, and risk tolerances of its clients; (ii) the selection of the ETFs that comprise each of the Portfolios; and (iii) the relative weightings of the ETFs and cash within each of the Portfolios. DAS further reserves the right, in its sole discretion and from time to time, upon providing prior notice to clients, to utilize model portfolios constructed by affiliates or third parties (“Model Providers”), and to make additional Model Providers available through the Program. Through the Program, DAS does not currently offer affiliated ETFs or other affiliated investment products. In the future, DAS may offer affiliated ETFs and other affiliated investment products through the Program.

The Program uses an algorithm that functions as a portfolio recommendation tool (the “Portfolio Recommendation Tool”) to recommend a Portfolio based on certain information that a client provides through the Site (the “Suggested Portfolio”). While DAS’s investment advisory personnel oversee the current operation of, and are responsible for any enhancements to, the Portfolio Recommendation Tool’s algorithm, such personnel do not override the Portfolio Recommendation Tool’s algorithm to recommend a different Suggested Portfolio to any particular client, whether based on any additional criteria (including, without limitation, current market conditions) or otherwise. Clients should understand that the Portfolio Recommendation Tool currently relies on the client’s investment time horizon and risk tolerance for each Advisory Account maintained by the client in recommending a Suggested Portfolio. Clients who previously enrolled in the Program prior to consideration of this particular combination of factors may update their investment profile and, if applicable, select a new Portfolio for any of their Advisory Accounts. The Portfolio Recommendation Tool asks a series of questions to assess a client’s current age and liquidity needs as well as their investment time horizon and risk tolerance for each Advisory Account in connection with the account opening process. The Portfolio Recommendation Tool does not consider the entire range of information a client provides for purposes of recommending a Suggested Portfolio. DAS uses the information clients provide through the Site regarding liquidity to make an initial determination whether the Program is appropriate for the client. The Portfolio Recommendation Tool only considers the answers to the questions regarding investment time horizon and risk tolerance for each Advisory Account, the values for which are weighted in accordance with DAS’s methodology (which does not weight them equally) and are then mapped to one of various Suggested Portfolios which is recommended to the client. Clients are not bound by the Suggested Portfolio recommended by the Portfolio Recommendation Tool and may, at the time when they initially receive a Suggested Portfolio, select either of the Portfolios adjacent to the Suggested Portfolio on the risk spectrum of Portfolios available through the Program. Clients may cause the Portfolio Recommendation Tool to generate a new Suggested Portfolio for a particular Advisory Account at any time by revising the information they provide through the Site. The Portfolio Recommendation Tool is solely responsible for determining which of the Portfolios available in the Program to recommend to each client based on certain information provided by such client. Clients who maintain multiple Advisory Accounts may receive different Suggested Portfolios from the Portfolio Recommendation Tool for such Advisory Accounts if the client provides different information regarding investment time horizon and risk tolerance for each Advisory Account.

The selection and relative weighting of the ETFs in each of the Portfolios has been designed by ISG to pursue specific investment objectives, including diversification. Although clients may select a different Portfolio for a particular Advisory Account at any time, subject to certain limitations, they are not able to change the underlying ETFs that comprise each Portfolio, except by requesting a reasonable investment restriction on the management of their Advisory Accounts. Clients may request an investment restriction for an Advisory Account by contacting us as follows: if you utilize the GS Site, call 1-833-474-6837 or sending an e-mail to, if you utilize the HD Site, call 1-855-783-7283 or send an e-mail to DAS is solely responsible for determining whether the restriction is reasonable. DAS may, in its discretion, hold the amount that would be invested in the restricted security in cash, invest in substitute securities, or invest it on a pro rata basis across the other securities in the Portfolio that are not restricted. Clients should be aware that the performance of an Advisory Account with restrictions will differ from, and may be lower than, the performance of Advisory Accounts without restrictions. As part of Goldman Sachs, a global financial services organization that is subject to a number of legal and regulatory requirements, GS&Co. is subject to, and has itself adopted, internal guidelines, restrictions and policies that may restrict investment decisions and activities on behalf of Advisory Accounts under certain circumstances. See Item 9, Additional Information. The Portfolio a client ultimately selects, taking into account any reasonable investment restrictions, is the client’s selected Portfolio (the “Selected Portfolio”), and all investment transactions are executed with the goal of aligning the holdings of the Advisory Account with the Selected Portfolio’s target allocation, including by rebalancing, as further described below. Clients may change their Selected Portfolio for an Advisory Account at any time by revising the information they submit through the Site and thereby causing the Portfolio Recommendation Tool to generate a new Suggested Portfolio for that Advisory Account, but they may not have more than one Selected Portfolio for an Advisory Account. Clients are solely responsible for the decision to invest in their Selected Portfolio. Clients should carefully review and consider the information available on our Site about the Suggested Portfolio as well as any other Portfolios made available to the client and their constituent ETFs before choosing a Selected Portfolio for an Advisory Account. Clients who choose a Selected Portfolio other than the Suggested Portfolio should understand that such a Selected Portfolio may not be suitable based on their risk tolerance and investment time horizon, and that the Selected Portfolio may perform worse for the client over any time period than the Suggested Portfolio or any other investment.

Under the terms of the Investment Advisory Agreement with DAS that governs the client’s Advisory Account (the “Client Agreement”), clients authorize the rebalancing of holdings and acknowledge that any dividends will be received in cash and invested in accordance with the client’s Selected Portfolio as part of the rebalancing process. The Advisory Accounts are monitored by DAS’s portfolio management system (“PM System”) to determine if the holdings have drifted beyond a pre-determined percentage from the target allocation and that the Advisory Accounts are otherwise eligible to trade. DAS will review such deviations and will periodically rebalance the Advisory Accounts to bring the holdings back into line with the Selected Portfolio. The rebalancing process is effected through the PM System, and rebalancing orders are reviewed and initiated by DAS’s investment advisory personnel. Advisory personnel have the ability to override or delay rebalancing in the event of volatile market conditions or other circumstances that DAS determines may negatively affect Advisory Accounts. DAS may, at any time and in its sole discretion, modify the manner or frequency with which rebalancing occurs. Clients should understand that there is no guarantee that the holdings in their Advisory Account will match the allocations of their Selected Portfolio at all times, and that various factors (including the timing and frequency of deposits and withdrawals, market volatility and disruptions, the timing and frequency of a client’s choice of or changes to their Selected Portfolio, reasonable restrictions, access interruptions, and hardware or software failures) can impact the extent to which holdings in a client’s Advisory Account will replicate the Selected Portfolio at any particular point in time. The Program includes strategic asset allocation models that are based on DAS’s long-term view. The Program does not provide tactical advice and clients should not expect to see tactical changes to their Selected Portfolios in response to market movements or market volatility events.

The ETF shares purchased or sold on behalf of a client and held in a client Advisory Account may be either whole shares or fractional shares, depending upon the amounts a client contributes to its Advisory Account. To the extent that DAS trades fractional shares of any ETF on behalf of Program clients, it does so by allocating any excess fractional shares to the Custodian’s fractional facilitation account, and the Custodian in turn accumulates fractional shares and manages their fractional facilitation account through trades in whole share quantities in accordance with their own policies as they pertain to management of such accounts and positions. DAS and the Custodian each reserves the right, at any time and each in its sole discretion, without prior notice to Program clients, to change the details of the policies and procedures governing the mechanics of trading fractional shares, including, without limitation, allocation calculation and rounding procedures. Fractional shares are typically unrecognized and illiquid outside of a client’s Advisory Account and, as a result, fractional shares may not be marketable or transferrable to another brokerage account. In the event of a liquidation or transfer of the assets in a client’s Advisory Account to another account, DAS may convert such fractional shares to cash. Dividends received in connection with assets in a client’s Advisory Account will be allocated pro-rata based on the fractional shares held and clients will not receive a dividend if the pro-rata amount of such dividend is less than $0.01.
Risk Factors
This Brochure does not include every potential risk associated with the Program, or all of the risks applicable to a particular Advisory Account. Rather, it is a general description of certain risks inherent in the Program. Clients should refer to their Client Agreement and the underlying prospectuses for the ETFs offered through the Program for additional information. Clients should understand that all investment strategies and the investments made when implementing those investment strategies involve risk of loss and clients should be prepared to bear the loss of assets invested. The investment performance and the success of any investment strategy or particular investment cannot be predicted or guaranteed, and the value of a client’s investments fluctuates due to market conditions and other factors. The investment decisions made and the actions taken for Advisory Accounts are subject to various market, liquidity, currency, economic, and political risks, and will not necessarily be profitable. The types of risks to which an Advisory Account is subject, and the degree to which any particular risks impact an Advisory Account, may change over time depending on various factors, including the investment strategies, investment techniques and asset classes utilized by the Advisory Account, the timing of the Advisory Account’s investments, prevailing market and economic conditions, reputational considerations, and the occurrence of adverse social, political, regulatory or other developments. Past performance of Advisory Accounts is not indicative of future performance.
Asset Allocation and Rebalancing Risk – The risk that an Advisory Account’s assets may be out of balance with the Selected Portfolio allocation. Any rebalancing of such assets may be infrequent and, even if achieved, may have an adverse effect on the performance of the Advisory Account’s assets. The rebalancing process is currently effected through the PM System, which is overseen manually by DAS’s investment advisory personnel who have the ability to override the system’s determination whether to rebalance under certain circumstances, and is thus subject to both technological and human error.

Cybersecurity Risk – The risk of actual and attempted cyber-attacks, including denial-of-service attacks, harm to technology infrastructure and data from misappropriation or corruption, and reputational harm. Due to Goldman Sachs’ interconnectivity with third-party vendors, central agents, exchanges, clearing houses, and other financial institutions (including the Custodian), Goldman Sachs, and thus indirectly the Advisory Accounts, could be adversely impacted if any of them is subject to a cyber-attack or other information security event. Although Goldman Sachs takes protective measures and endeavors to modify them as circumstances warrant, its computer systems, software, and networks may be vulnerable to unauthorized access, misuse, computer viruses or other malicious code, and other events that could have a security impact, or render Goldman Sachs unable to transact business on behalf of Advisory Accounts.

Diversification Risk – The risk that the Program assumes the beneficial nature of diversification. While using a diversified portfolio to reduce risk is a widely accepted investment principle, diversification cannot reduce risk to zero, and the returns on a diversified portfolio during any given time period may be lower than the returns on one or more investments concentrated in an industry, sector, or geographic region that was profitable during that time period.

Equity and Equity-Related Securities and Instruments Risk – The value of common stocks of U.S. and non-U.S. issuers may be affected by factors specific to the issuer, the issuer’s industry and the risk that stock prices historically rise and fall in periodic cycles.
ETF Investment Risk – The risk that: (i) ETFs may trade at a discount or premium to their underlying net asset value (“NAV”); (ii) ETFs may not fully track the market segment or index that underlies their investment objective, resulting in performance that differs from expectations; (iii) investors purchasing an ETF at a premium may underperform the ETF NAV, while the redemption of shares may result in the ETF trading at a discount to NAV; (iv) an active trading market for an ETF’s shares may not develop or be maintained; and (v) the requirements of the exchange necessary to maintain the listing of an ETF will be changed or otherwise not met.
Frequent Trading and Portfolio Turnover Rate Risks – The risk that high turnover and frequent trading in an Advisory Account could result in, among other things, higher transaction costs and, to the extent applicable, adverse tax consequences.
Hypothetical Performance and Projected Returns – The risk arising from reliance on hypothetical performance information and projected returns. Projected returns are hypothetical, do not reflect actual investment results, and are not guarantees of future results. Such projected performance is subject to a number of limitations and assumptions designed to determine the probability or likelihood of a particular investment outcome based on a range of possible outcomes. It is possible that any of those assumptions, including retirement age, may prove not to be accurate. In addition, performance of the Suggested Portfolio, a client’s Selected Portfolio, other Portfolios, or a client’s Advisory Account may differ materially from investment gains and avoidance of investment losses projected, described, or otherwise referenced in forward-looking statements, and the projected returns associated with any Portfolio may not materialize.

Index/Tracking Error Risks – The risk that the performance of an Advisory Account that tracks an index may not match, and may vary substantially from, the index for any period of time and may be negatively impacted by any errors in the index, including as a result of an Advisory Account’s inability to invest in certain securities as a result of legal and compliance restrictions, regulatory limits or other restrictions applicable to the Advisory Account, reputational considerations or other reasons. As an index may consist of relatively few securities or issuers, tracking error may be heightened at times when an Advisory Account is limited by restrictions on investments that the Advisory Account may make.

Limited Nature of the Portfolio Recommendation Tool and PM System – In addition to the risks described in “Cybersecurity Risk” above and “Limited Nature of the Program” and “Reliance on Data Risk” below, the use of algorithms such as the ones underlying the Portfolio Recommendation Tool and PM System to provide investment advisory services carries the risk that changes to the algorithm’s code, although subject to compliance controls and testing, may not have the desired effect with respect to client accounts. While this risk increases if changes to an algorithm are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The Portfolio Recommendation Tool uses a limited universe of inputs to recommend a Suggested Portfolio for each Advisory Account maintained by a client from a limited universe of possible outputs. In particular, the Portfolio Recommendation Tool currently recommends a Suggested Portfolio based on a client’s responses to questions relating to investment time horizon and risk tolerance for a particular Advisory Account, in each case as provided by the client through the Site, and does not verify the completeness or accuracy of such information or consider any information regarding outside assets, concentration, debt, or other accounts a client may have with GS&Co., any of its affiliates, or with any third party. The Portfolio Recommendation Tool uses this information regarding the client’s investment time horizon and risk tolerance for a particular Advisory Account to recommend a Suggested Portfolio for that Advisory Account from a limited number of asset allocation models, profiles, and underlying instruments. The Portfolio Recommendation Tool assumes that each combination of relevant responses either maps to one of the Portfolios available in the Program or means that such client should be prevented from opening an Advisory Account. The Portfolio Recommendation Tool does not take into account changes in market conditions, and DAS does not override the Portfolio Recommendation Tool’s recommendation of a Suggested Portfolio under any circumstances, whether due to market conditions or otherwise, although each client may, subject to the procedures and limitations described above, select a different Portfolio for an Advisory Account. The functionality of the PM System is partly dependent upon information provided by the Custodian, third parties, and other external sources, meaning that performance of the PM System could be impacted by issues with the delivery or the accuracy of the information provided.
Limited Nature of the Program – The risk arising from the limited nature and scope of the Program. The Program is designed to offer individuals the ability to invest in Advisory Accounts by providing a simple, efficient solution. The Program does not provide comprehensive financial or tax planning or legal advice unless explicitly agreed to in writing between you and GS&Co., and clients are advised and afforded the opportunity to seek the advice and counsel of their own tax, financial, and legal advisers. Neither GS&Co. nor any of its affiliates is responsible for establishing or maintaining any Advisory Account’s compliance with the requirements of the Internal Revenue Code for a Traditional IRA, Roth IRA, SEP IRA, or any other type of account that may be offered through the Program or determining any client’s individual tax treatment regarding such account. Furthermore, neither GS&Co. nor any of its affiliates is responsible for withholding any tax penalties that may apply to clients’ accounts or for any state or federal income tax withholding, except as may otherwise be required by applicable law. DAS’s recommendations are limited based on the information clients provide through the Site and the Program’s use of the Portfolio Recommendation Tool, the limitations of which are further discussed above. Clients should take into consideration the limited nature of the Program in evaluating the investment advice and recommendations provided through the Site. Furthermore, the Program: (a) is not a complete investment program; (b) does not account for multiple investment goals within an Advisory Account; (c) does not consider outside assets, concentration, debt, or other accounts a client may have with GS&Co., any of its affiliates, or with any third party; (d) offers a limited number of asset allocation models, profiles, and underlying instruments; (e) is not suitable for all investors; and (f) relies on the information provided by clients in providing investment advice, and does not verify the completeness or accuracy of such information. There could be one or more products available in the investment community that are more appropriate than the investment products made available through the Program. Given the inherent limitations of the Program, clients should carefully consider whether the Program is the right investment solution for their needs.

Low Trading Volume Risk – The risk that a client may not be able to monetize his/her investment or will have to do so at a loss as a result of generally lower trading volumes of the securities compared to other types of securities or financial instruments.

Market/Volatility Risk – The risk that the value of the assets in which an Advisory Account invests may decrease (potentially dramatically) in response to the prospects of individual companies, particular industry sectors or governments, changes in interest rates, and national and international political and economic events and policies due to increasingly interconnected global economies and financial markets.

Model Portfolio Risk – The management of a client’s Advisory Accounts by DAS in its advisory capacity includes the use of various quantitative or investment models –the Portfolios. There may be deficiencies in the design or operation of these Portfolios, including as a result of shortcomings or failures of processes, people or systems. Investments selected using the Portfolios may perform differently than expected as a result of the factors used in the Portfolios, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the Portfolios (including, for example, data problems and/or software issues). Moreover, the effectiveness of a Portfolio may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. A Portfolio’s return mapping is based on historical data regarding particular asset classes, which may not be predictive of future price movements, particularly if unusual or disruptive events cause market movements, the nature or size of which are inconsistent with the historical performance of individual markets and their relationship to one another or to other macroeconomic events. Operation of a Portfolio may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-forma. Additionally, commonality of holdings across Portfolios may amplify losses. There is no guarantee that the use of the Portfolios will result in effective investment decisions for a client’s Advisory Account.
Multiple Levels of Fees and Expenses—Subject to applicable law, Advisory Accounts investing in underlying funds generally bear any asset-based fees and performance-based fees or allocations and expenses at the Advisory Account level and at the underlying fund level (although there may be circumstances in which Advisory Accounts bear such fees at only the Advisory Account level).
Operational Risk – The risk of loss arising from shortcomings or failures in internal processes or systems of Goldman Sachs, GS&Co., the Custodian, vendors, external events impacting those systems, and human error. Operational risk can arise from many factors ranging from routine processing errors to potentially costly incidents such as major system failures.

Passive Investing – The risk arising from passive investing. The Program assumes a preference for passive over active investing. Passive investing may yield lower returns than active investing during a particular time period, because passive investing is based on the theory that consistently outperforming an efficient market is impossible, and thus passive investors do not attempt to outperform the market at all, thereby foregoing any potential gains that could result from outperforming the market in the short term.

Reliance on Data Risk – The risk arising from reliance on data. The Program relies on data from third parties and other external sources. DAS will in its discretion determine what third-party and external data to use in connection with the Program. The data used in the Program is obtained or derived from sources believed to be reliable, but DAS does not verify such data and cannot guarantee its accuracy and completeness. In addition, the Portfolio Recommendation Tool relies on information provided by clients in recommending a Suggested Portfolio for an Advisory Account. There is no guarantee that any specific data or type of data will be used in generating recommendations.

Tax, Legal and Regulatory Risks – The risk of loss due to increased costs and reduced investment and trading opportunities resulting from unanticipated legal, tax and regulatory changes. Regulations, including regulations such as the Volcker rule contained within the Dodd- Frank Act and comprehensive tax reform, may affect the types of transactions that certain clients may enter into with Goldman Sachs and ultimately the performance of the Advisory Accounts or the commercial benefits the client may obtain from Goldman Sachs. In addition, the California Consumer Privacy Act (the “CCPA”) was enacted in June 2018 and is scheduled to take effect on January 1, 2020. The CCPA will impose privacy compliance obligations with regard to the personal information of California residents. Other states may, in the future, impose similar privacy compliance obligations. Increased regulatory oversight may also impose additional compliance and administrative obligations on GS&Co. and Goldman Sachs, including, without limitation, responding to investigations and implementing new policies and procedures. Additional information regarding such matters may also be available in the current public SEC filings made by Goldman Sachs.

The Program charges a “wrap” fee, which is currently structured as a single per-account fee that covers investment advisory services provided by DAS and the custodial and brokerage services provided by Custodian (“Advisory Fee”). The Advisory Fee applicable to each Advisory Account maintained by a client is 25 basis points per year on the entire value of the Advisory Account or as otherwise specified to you in writing by GS&Co. The Advisory Fee is determined based on the average daily value of the assets in the applicable Advisory Account and is deducted from the Advisory Account. The Advisory Fee, in either case, is subject to any applicable discounts, or waivers, as discussed below. The fee is paid quarterly in arrears. The Advisory Fee is generally not negotiable, and DAS reserves the right to discount or waive any fees associated with the Program in its sole discretion. Any fee waivers or discounts, or terminations of such waivers or discounts, will be communicated to clients where applicable. The Advisory Fee for certain clients, including employees of the firm or an affiliate, or clients of an affiliate, may be lower than, but in no case shall exceed, 25 basis points per year on the entire value of the Advisory Account. Clients should understand that the Program was designed with frequent investing in mind, and therefore the fee structure might not be economical or appropriate for individuals intending to make few or infrequent small-dollar investments. Clients should further understand that the Advisory Fee may exceed the aggregate cost of purchasing separately the investment products and individual services that comprise the advisory and brokerage services offered through the Program. The Advisory Fee includes most of the investment expenses that are typically paid by investors, such as: account establishment/maintenance expenses, investment advisory fees, and brokerage fees. However, the Advisory Fee does not include fees charged by each ETF’s investment manager, or other fees and expenses that are reflected in the price of each ETF’s shares. Expenses that are charged in addition to the Advisory Fee and for which clients are independently responsible to the Custodian, if incurred, are listed on Schedule A, which is attached to this Brochure. DAS reserves the right to assume the expense of any fees set forth on Schedule A in its sole discretion.

DAS does not charge performance fees on Advisory Accounts.
Brokerage and Custody Services

In order to participate in the Program, clients must enter into an agreement directly with Custodian to serve as the custodian for client’s assets invested through the Program and provide brokerage services. Under the terms of the Client Agreement, clients authorize and direct DAS to execute orders to buy and sell ETFs with Custodian. DAS may combine orders for purchases or sales for multiple Advisory Accounts. please register to get more info

Open Brochure from SEC website

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