ThinkBetter Group LLC d/b/a ThinkBetter (“ThinkBetter” or “Firm”) is an SEC Registered
Investment Advisor. The Firm is located in San Juan, Puerto Rico with a branch office in
Sarasota, Florida.
ThinkBetter advises institutional clients such as registered investment advisers, registered
investment companies, broker-dealers, family offices, trusts, and foundations. ThinkBetter
manages investments on a discretionary basis on behalf of third-party Registered Investment
Advisers and Broker-Dealers for their own clients (“Retail Clients”) through subadvisory
agreements and individual clients through advisory agreements.
Before engaging ThinkBetter as a Subadvisor or an Advisor , Clients are required to enter into an
Agreement setting forth the terms and conditions of the engagement (including termination),
providing ThinkBetter with the discretion to implement an investment strategy, describing the
scope of the services to be provided, and the fee, if any, that is due from the Client. Before
ThinkBetter provides investment advisory services, ThinkBetter will ascertain each Client’s
investment objectives. Where ThinkBetter provides advice to third-party RIAs or Broker-Dealers,
those entities will ascertain each Retail Client’s investment objectives and provide any relevant
information to ThinkBetter.
ThinkBetter is a Sub-Advisor to certain exchange traded funds (“ETFs”), whereby the Firm is hired
by the Advisor to the ETF to provide their expertise in managing a specific strategy. As Sub-
Advisor, ThinkBetter selects a Fund’s investments in accordance with the Fund’s investment
objective, policies, and restrictions. The types of services provided to these Funds include day-to-
day portfolio management, compliance, and board reporting. ThinkBetter has full discretion
regarding investments made on behalf of the Funds. Sub-Advisory services are not tailored to the
individual needs of investors in those Fund(s).
ThinkBetter provides investment models as a signal provider to third-party independent registered
investment advisors and broker-dealers for a fee. As such, ThinkBetter does not have discretion
over the implementation of these models by the third-party advisors, third party i ndependent firms
or broker-dealers. The models offered are implemented at the sole discretion of the third-party
firms.
The Q Consulting Group, LLC (“Q Consulting”), an affiliate of ThinkBetter that is owned by the
principals of ThinkBetter, offers assistance to ThinkBetter in developing investment strategies,
specializing in risk management, portfolio optimization, and allocation that are used in connection
with the provision of investment advisory services and models by ThinkBetter to ThinkBetter’s
Clients.
ThinkBetter has $174,457,757 in regulatory assets under management, of which
$32,708,396 is discretionary and $ 141,749,3387 is non-discretionary as of December 31, 2022.
Exchange Traded Funds
ThinkBetter is sub-advisor to two Exchange Traded Funds (“Fund” or “Funds”) listed on the New
York Stock Exchange (NYSE Arca) and AdvisorShares Investments, LLC, located at 4800
Montgomery Lane, Suite 150, Bethesda, Maryland 20814, serves as investment advisor of
the Funds. For more information on AdvisorShares ETFs, including performance and holdings,
please visit
www.advisorshares.com.
As Sub-Advisor, ThinkBetter selects a Fund’s investments in accordance with the Fund’s
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investment objective, policies, and restrictions. The types of services provided to these Funds
include day-to-day portfolio management, compliance, and board reporting. ThinkBetter has full
discretion regarding investments made on behalf of the Funds. Sub-Advisory services are not
tailored to the individual needs of investors in those Fund(s).
Each Fund is an actively managed ETF that is a “fund of funds.” The Fund invests in ETFs
representing all asset classes, including, but not limited to, treasury bonds, municipal bonds,
investment grade corporate bonds, high-yield U.S. corporate bonds (sometimes referred to as
“junk bonds”), municipal bonds, U.S. and foreign equities, and commodities. These underlying
investments may be of any market capitalization, duration, maturity, and quality. The ETFs are
managed independently from the management of Sub-Advisory accounts and trading signals
provided to client firms. Additional information regarding the ETFs are provided below.
Q Dynamic Growth ETF (QPX)
QPX is an actively managed ETF seeking to target equity market upside while tactically managing
downside risk during abnormal market volatility. Using ETFs, QPX may invest in a broad variety
of equities across market cap, style or sectors and will use various fixed income categories and
commodities to manage risk. QPX applies ThinkBetter’s Q Methodology™ proprietary risk
management program to optimally allocate the fund’s assets against a given level of risk.
Normally, QPX seeks to provide broad-market equity like returns and re-optimizes the portfolio
monthly. However, during periods of high market volatility, QPX can allocate to a more defensive
portfolio and seek short-term fixed income returns. QPX’s market volatility indicator, the Q Implied
Volatility Index™ (QIX), is reviewed daily which may result in mid-month allocation changes. Asset
classes may be added or removed from QPX’s portfolio based on changing risk/reward
characteristics.
Client Imposed Restrictions
For Advisory relationships, other than ETFs, ThinkBetter will consider Client-imposed restrictions
on their accounts, dependent upon the client’s investment objectives However, in most instances,
restrictions will negate the investment objective of the strategy and Restrictions cannot be placed
on the exchange traded funds for which ThinkBetter is the sub-advisor (See Item 16 – Investment
Discretion).
Additional Disclosures
Amplify Platform
ThinkBetter Investment Advisor Representatives utilize the Amplify Platform. The Amplify Platform
provides back-office operational support services such as administrative,
trading and reporting
services and/or gain access to and select from independent third-party managers available through
the Amplify Platform.
Upon executing the Platform Agreement, the investment advisor firm or investment professional
shall be considered a Platform Member. Platform Members may choose to receive certain back-
office services, such as administrative, trading and reporting services and/or to select independent
third-party managers to manage underlying client assets on a sub-advisory basis. Platform
Members may choose to allocate all or a portion of their underlying client’s assets among the
different independent investment managers available through the Amplify Platform on a
discretionary basis.
Platform Members shall have a direct contractual relationship with each of their underlying clients
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and obtain, through such agreements, the authority to engage Amplify Platform for services
rendered through the Platform. ThinkBetter engages unaffiliated investment advisors to service
Platform Members as sub advisors. Sub-advisors available through the Amplify Platform will
perform discretionary investment management services and shall manage, invest and reinvest the
Platform Member’s underlying client assets designated by the Platform Member. As such, a
selected manager(s) shall be authorized, without prior consultation with the Platform Member or
the underlying client, to buy, sell trade or allocate the underlying client’s assets in accordance with
the underlying client’s investment objectives and to deliver instructions in furtherance this
responsibility to the underlying client’s broker-dealer and or custodian.
Platform Members retain responsibility for the underlying client relationship, including the initial and
ongoing suitability determination. Platform Members shall also retain the responsibility for
implementing client investment recommendations in accordance with the Platform Member’s
fiduciary duty to the underlying client. Platform Members are responsible for obtaining and
furnishing information pertaining to sub-advisor selection and underlying client account guidelines
along with any reasonable account restrictions.
ThinkBetter’s investment advisor representatives are required to utilize the various services
available through the Amplify Platform. Therefore, ThinkBetter clients may incur fees in addition to
the fee associated with the advisory services provided to the client.
Marketing and Advertising
ThinkBetter understands the need for fair and balanced marketing and advertising materials.
ThinkBetter does not present performance information in marketing or advertising materials, as
defined in the Investment Advisers Act of 1940. The Firm does not make use of third-party
testimonials or endorsements in connection with its advisory services. Performance information for
the Exchange Traded Fund for which ThinkBetter serves as Sub-Advisor, is presented by the
Adviser on the website of AdvisorShares,
https://advisorshares.com/etfs/qpx/.
Limitations of Sub-Advisory Services
ThinkBetter generally serves as a Sub-advisor to registered investment advisors according to the
terms and conditions of a written Sub-Advisory Agreement. With respect to its Sub-Advisory
services, the investment advisors that engage the Firm’s Sub-Advisory services maintain both the
initial and ongoing day-to-day relationship with the underlying Client, including initial and ongoing
determination of Client suitability for ThinkBetter’s designated investment strategies and/or
programs. The custodian/broker-dealer is determined by the investment advisor and not
ThinkBetter. ThinkBetter will be unable to negotiate commissions and/or transaction costs, and/or
seek better execution. As a result, Clients may pay higher commissions or other transaction costs
or greater spreads, or receive less favorable net prices, on transactions for the account than
would otherwise be the case through alternative clearing arrangements recommended by
ThinkBetter. Higher transaction costs adversely impact account performance. ThinkBetter’s Chief
Compliance Officer, Teresa Koncick, and/or her designee, remains available to address any
questions concerning ThinkBetter’s sub-advisory arrangements.
Trade Error Policy
ThinkBetter shall reimburse accounts solely for losses resulting directly from ThinkBetter’s trade
errors.
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Client Obligations
When ThinkBetter serves as a Sub-Advisor, the Advisor will provide information concerning their
Retail Client’s financial information and investment objectives and any reasonable restrictions
requested on the management of their account. On at least an annual basis, such Advisor is
expected to determine whether there have been any changes in their Client’s financial information
and investment objectives. In performing its services, ThinkBetter shall not be required to verify
any information received from the Client or from the Client’s other professionals and is expressly
authorized to rely on the representations from the Advisor. It remains the Advisor’s responsibility
to promptly notify ThinkBetter if there is ever any change in their Retail Client’s financial situation
or investment objectives for the purpose of reviewing, evaluating, or revising ThinkBetter’s previous
recommendations and/or services. The Advisor maintains the fiduciary relationship with their Retail
Clients.
Disclosure Statement
A copy of ThinkBetter’s written Brochure as set forth on Part 2A of Form ADV (“Brochure”) and
Part 3 (“Form CRS”) shall be provided to each Client prior to, or contemporaneously with, the
execution of the advisory or sub-Advisory Agreement. The Brochure is also available electronically
at
https://thinkbetter.us and at
https://advisoradvisorinfo.sec.gov/firm/brochure/300530 with
respect to the Exchange Traded Funds.