Referral and other Incentive Programs

Altruist LLC and its affiliates (together, “Altruist”) make available certain referral and other incentive programs that provide cash or non-cash compensation to participating Registered Investment Advisers (“RIAs”) and their affiliated Investment Advisor Representatives (“advisors”). This can present a conflict of interest because the promoting advisor’s participation (either directly, or indirectly as an affiliate of a participating RIA) in the following referral or incentive program(s) may affect their experience with Altruist and incentivize them to promote Altruist or otherwise provide Altruist with positive feedback.

– “Altruist Match” is Altruist’s client matchmaking program that allows prospective clients to screen and identify participating RIAs and their affiliated advisors based on criteria specified by the prospective client. The RIA receives client referrals from Altruist as a participant in this program.

– “Ambassador” is Altruist’s referral program that rewards participating RIAs compensation equivalent to five basis points (0.05%) of the total qualifying assets each referred advisor adds to Altruist Financial LLC’s brokerage platform within a specified timeframe.

– “Advisor Tech Collection” is a program in which Altruist offers certain benefits to RIAs by either paying for or reimbursing the costs of certain technology solutions to help facilitate the RIA’s practices and to streamline their operations. The payments may be substantial and are based on the advisor’s clients adding and/or transferring to and maintaining a certain amount (currently five million dollars [$5,000,000]) in assets on Altruist’s platform.

– “Advisor Council Program” is an Altruist Corp program that invites participating RIAs to engage certain prospective RIAs and share their experience with Altruist. If the prospective RIA agrees to join Altruist within a specified timeframe following the initial engagement, Altruist pays the participating RIA a one-time fee that is an equivalent to two basis points (0.02%) of the prospective RIA’s total Assets Under Management (AUM) custodied through Altruist Financial LLC within a specified timeframe following the initial date of engagement.

– “Onyx Advisor Network” is a program in which advisors who are current Onyx Advisor Network members are eligible to receive a discounted Altruist Software Subscription rate of their first 500 accounts free and $1 for each additional account per month thereafter.

– “Altruist Academy” is an advisor practice management workshop hosted by Altruist. RIAs currently using Altruist that meet certain AUM and/or platform engagement thresholds, or prospective new RIAs may be deemed eligible, at Altruist’s sole discretion, to receive complimentary attendance to Altruist Academy ($1500 value).

– “Waived PAS fees” From time to time, Altruist may waive its Software Subscription (“Portfolio Accounting Software” or “PAS”) fees for certain advisors. Such offers are made with or without contingencies, at Altruist’s sole discretion.

– “Freelance Authors” From time to time, Altruist may contract advisors to write contributed articles, for which cash compensation is provided.

– “Incentivized Surveys” From time to time, Altruist may conduct user surveys for product development, research or other purposes and may provide advisors with gift cards as incentivization for completing such surveys (approximately $10 – $50 value).

The terms of the above programs are subject to change without notice, at Altruist’s sole discretion. For more details on a promoting advisor’s specific situation, arrangements and conflicts of interest when expressing its views about Altruist or Altruist’s affiliates, please refer to the promoting advisor’s advisory program brochures available at https://adviserinfo.sec.gov/. For additional information on Altruist, please see our agreements and disclosures at https://altruist.com/legal/.