A. Description of the Advisory Firm Investment Advisory Services Financial Choice Inc. (hereinafter“FC”) provides discretionary portfolio management to separately managed account clients under a wrap fee program (“Wrap Program”) as sponsor and portfolio manager. FC provides robo-advisory portfolio management to clients under this Wrap Program as sponsor and portfolio manager exclusively via an online interface. This entails the use of algorithm-based portfolio management advice, and does not include in-person investment advice.
Clients receiving Investment Advisory Services from FC can choose whether or not to use FC’s Cash Management services (see description below).
FC provides investment advisory services on a continuous basis and in accordance with the investment objectives and risk tolerance provided by the client. FC typically provides investment management services for portfolios assembled by FC. These portfolios will typically be comprised of stocks, bonds, exchange traded funds (“ETF’s”), and money market funds. The ETFs are typically invested in stocks, and bonds.
Client managed account assets are invested in FC’s investment strategies based on investments that appear to be most suitable to the client’s investment objectives determined for those account assets. Factoring in individual client characteristics, such as the client’s age, risk tolerance, income, and current assets, among others. Several clients will be invested in the same or similar investment strategy at any given time. Further details on FC’s investment strategies, including the risks pertaining to the securities comprising such strategies is found in Item 6.
FC provides robo-advisory, discretionary portfolio management services via an online interface. Under FC’s Wrap Program, the client receives advisory and brokerage execution services plus account reporting and custodial services, for one all-inclusive fee.
Once the appropriate portfolio has been determined by FC’s proprietary algorithm (based on information received from the client), FC monitors the investments regularly, conducts account reviews periodically, and will consider an appropriate rebalance of a portfolio as necessary, based upon the client’s stated goals and objectives.
Client assets in the Wrap Program managed by FC are held in accounts at a registered broker/dealer and qualified custodian, who will provide clearing, custody and other brokerage services for client accounts. Each client is ultimately responsible for providing all of the necessary information to establish their own account. Clients will retain all rights of ownership in such accounts, including vote proxies, and receive transaction confirmations.
Cash Management Services FC provides its clients Cash Management Services in connection with its advisory services. Clients receiving investment advisory services are not required to use FC’s Cash Management services. Please note that FC’s Cash Management services are not available to persons that are not investment advisory clients of FC.
Clients that elect to use the Cash Management Services will be required to open a demand deposit account (“DDA”) at Evolve Bank & Trust (“Bank”). The DDA will be connected to a client’s investment account (“Investment Account”) managed by FC.
Under this arrangement, FC, through the use of its proprietary algorithm, has the ability to determine when to transfer monies deposited into the DDA through aggregating accounts at the Bank and at the Custodian (defined below) to the client’s Investment Account. Once in the client’s Investment Account, those monies will be invested by FC based on output generated by FC’S algorithm and according to the client’s investment strategy.
Each client has a specified amount of money that is kept in their DDA. When a client seeks to withdraw money from the DDA, FC’s algorithm will attempt to meet the withdrawal request with cash held in the DDA. In addition, FC’s algorithm may initiate a sale transaction in the client’s Investment Account to cover the withdrawal amount, and get the DDA balance back to the customer’s specified amount. When a client deposits money in the DDA, FC’s algorithm will initiate the investment of the applicable portion of funds to get the DDA’s balance back to the amount specified by the client. Due to limitations relating to banking and financial market operations, FC may not always be able to initiate transactions in order to keep the DDA at the client’s specified amount in real time (e.g. Depending on the timing of when your withdrawal request is received, it may not be possible for the algorithm to initiate sale transactions until the next business day due to market cut-off trading times and the time necessary to identify and enter the necessary transactions). Accordingly, a client might experience a temporary delay in withdrawing some or a portion of the desired withdrawal amount. FC may, at its full discretion, approve such withdrawals, even while a user is experiencing a delay.
Clients have to be investment advisory clients of FC in order to receive Cash Management Services. FC’s fees may be higher or lower than those available from other professional providers for similar cash management services. This arrangement creates a conflict of interest as FC receives revenue from a client’s use of the debit card associated with the DDA (see discussion in the “Fees and Compensation” section below). FC believes that the services provided by the Bank and the associated fees of the Bank are reasonable, and notes that there may be other bank partners who offer similar services for lower fees.
Fees and Compensation: Investment Advisory Services FC charges a flat $10/month fee (“Advisory Fee”) for its advisory services and execution of transactions within its Wrap Program. Clients do not pay brokerage commissions, markups or transaction charges for execution of transactions in addition to the Advisory Fee.
The Advisory

Fee is withdrawn directly from the client’s accounts with client’s written authorization on a monthly basis.
The Advisory Fee is paid monthly in advance. A monthly Advisory Fee paid in advance but not yet earned will not be refunded if a client terminates on a day other than the last day of a calendar month. FC expects to lower or waive the Advisory Fee for certain clients, friends of family members, in FC’s sole discretion. FC’s Advisory Fee is not negotiable. Although FC believes its Advisory Fee is competitive, clients should be aware that lower fees for comparable services may be available from other sources.
Clients may terminate their agreement without penalty, for full refund of FC’s fees, within five business days of signing the Investment Advisory Agreement. Thereafter, clients may terminate the Investment Advisory Agreement in accordance with the provisions of thereof.
Cash Management Services FC does not charge a separate service fee for its Cash Management Services.
Please note that, in connection with a client’s use of the debit card associated with the DDA linked to the client’s investment advisory account, FC will earn an industry standard interchange fee (which can generally range from 0.5% to 1.5%, depending on factors, which include, among other things, the merchant category, user location, and applicable bank rates). The interchange fee is paid by the merchant, not the card user (i.e.
not by the client). Additionally, the client will earn industry standard interest on balances in a client’s DDA (which has been between 0% and 0.5% in recent years, depending on the applicable bank rate), if the user chooses not to have their funds automatically invested. The interest rate provided to users is expected to be in line with the national interest average. FC expects the interchange fee to be a material source of revenue for the Firm.
B. Contribution Cost Factors Participating in the Wrap Program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the Wrap Program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers).
A Wrap Program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services can include portfolio management and the fee is not based directly upon transactions in your account. Your fee is bundled with FC’s costs for executing transactions in your account(s). This generally results in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we could have an incentive to limit our trading activities in your account(s) when FC is charged for executed trades.
By participating in a Wrap Program, you could end up paying more or less than you would through a non-wrap fee program where, generally, a lower advisory fee is charged, and trade execution costs are passed directly through to you by the executing broker.
C. Additional Fees and Costs FC will wrap some third-party fees (i.e., custodian fees, brokerage fees, and transaction fees) for wrap fee portfolio management accounts. FC will charge clients one fee, and pay all transaction fees (if any) using the fee collected from the client. Accounts participating in the Wrap Program are not charged higher advisory fees based on trading activity.
Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund (“ETF”), fees associated with “step out” transactions if the account uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Further information regarding fees assessed by a mutual fund or ETF is available in the appropriate prospectus, which is available upon request from us or from the product sponsor directly.
In addition, the Advisory Fee does not include or cover transfer taxes, fees and or taxes assessed by state and federal governments or agencies thereof, internal fees and expenses charged by the investments used in the Account(s) (if any), the United States Securities Exchange Commission Section 31 fee (“SEC fee”) and the FINRA Trading Activity Fee (“TAF”) and ADR fees (charged by each ADR in accordance with the terms of the applicable ADR prospectus). You will be charged the mandatory SEC fee on the trades executed in the Account(s). The SEC Fee is set by the SEC and subject to change. As of the date of this Brochure, the SEC Fee per transaction is $5.10 per million dollars. See theSEC Websitefor additional information on the SEC Fee. The TAF is set by FINRA and subject to change. As of the date of this Brochure, the TAF per transaction is $0.000119 per share for each sale of a covered equity security, with a maximum charge of $5.95 per transaction. See theFINRA Websitefor additional information on the TAF.
D. Compensation of Client Participation Neither FC nor any representatives of FC receive any additional compensation beyond advisory fees for the participation of clients in the Wrap Program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, FC has a financial incentive to recommend the Wrap Program to clients.