Firm Description
WAO Advisory, LLC (“WAO Advisory” or the “Firm”) was organized as a Limited Liability
Company formed on March 3, 2022. The principal owner of WAO Advisory is WAO Fintech,
LLC, as of October 9, 2023.
Types of Advisory Services
WAO Advisory provides investment advisory services primarily through an interactive WAO
Advisory web platform and mobile application. As an “Internet Advisor” the Firm provides
investment advice solely through its web and / or mobile applications. WAO Advisory provides
discretionary asset management services and utilizes a separately managed account structure to
direct investments on behalf of its Clients. WAO Advisory’s platform allows each Client to be
provided individual accounts held with a qualified custodian (opened by WAO Advisory for the
benefit of the Client), through which WAO Advisory manages the Client’s assets pursuant to each
Client’s Advisory Agreement.
Clients access the platform and provide information about their investment objectives and financial
situations, including their investment philosophy and preferences. Clients can also impose
reasonable restrictions on the management of the account by indicating any assets that should not
be traded in their accounts. Based on this information, WAO Advisory’s algorithms provide
recommended allocations among various model portfolios (“Strategies”) which Clients can accept,
reject, or modify. Each Strategy is comprised of a set of digital assets and baskets of digital assets
that are chosen and weighted to fit particular investment goals of a Strategy as a whole. For
example, a Strategy may be allocated a certain percentage of their assets to the Layer 1 Basket,
DeFi Basket, among other baskets depending on the Client’s investment objectives, financial
situation, risk tolerance and time horizon. Once a Client selects a Strategy, the Strategy’s allocation
to any basket may change over time depending on a number of factors including but not limited to
macro market conditions, risk profile and the performance of a basket. When a Client selects the
autopilot feature in the platform their allocation will automatically update if there are allocation
changes made to the underlying Strategy. WAO Advisory evaluates investment strategy
recommendations both quarterly, and in the event of significant market developments. If a Client
does not select the autopilot feature in the platform, their preset allocation to the baskets will not
change over time unless they take action to change the basket allocation; however, their portfolio
will still be subject to periodic rebalancing. Client allocations can also potentially change whether
or not they opt into autopilot based upon Tiers that are reached within their account. See Item 8 of
this Brochure for more detail on the baskets and Strategies. See Item 7 for more information on
the Tiers. Clients are not required to follow or invest in the recommendations of any of WAO
Advisory’s algorithms. Once Clients select their Strategy allocations, Clients may update Strategy
selections at will through the platform’s account portal. Clients invest directly in the assets that
make up each Strategy and some assets may be included in multiple Strategies.
If a Client does not use WAO Advisory’s recommendation and selects their own Strategy or does
not select the autopilot feature, this may negatively impact the Client’s ability to achieve their
goals. The advisory fee described in Item 5 of this Brochure is still applied to your account if all
or a portion of your account is selected by the Client. A Client that wants to self-direct their
investments will likely incur lower fees in an account outside of WAO Advisory. WAO Advisory
provides additional information on each strategy on the platform; investors should review that
information before investing.
WAO Advisory enables Clients to invest through the Strategies described under Item 8. WAO
Advisory does not permit individual self-directed trades of digital assets or cryptocurrencies.
Account Maintenance and Trade Execution
WAO Advisory’s proprietary algorithm also uses system-generated checks to monitor for
inconsistencies
and red flags in trading. WAO Advisory reserves the right to delay execution of
trades in the event that unusual activity is detected in order to determine the validity of the trade
or allocation request. If such situation arises, WAO Advisory will attempt to provide notice to the
Client of the reason for the delay. WAO Advisory will not delay or attempt to delay any trades
based on any opinion or estimation regarding the profitability, market price predictions or
projected outcome of the trade. If the Client is seeking advisory services on individual trading
decisions, they should not use WAO Advisory’s offerings.
As the value of a Client’s investments fluctuates, the assets in their chosen portfolios may diverge
from originally assigned preferences. WAO Advisory will automatically rebalance the model
“portfolios” or “Strategies” in accordance with each Strategy’s predetermined schedule, as
described below and on the platform. A programmatic rebalance may result in the addition of one
or more digital assets, the removal of one or more assets, or a change to the relative holdings of
each asset within a Strategy. Clients may not opt-out of a programmed Strategy rebalance. WAO
Advisory will undertake to notify clients of any additions or deletions of digital assets from a
Strategy; however, the Firm has the discretionary authority to make such decisions without consent
from the Client. An addition or deletion of a digital asset will occur for a number of reasons
including but not limited to the Firm’s reassessment of the digital asset based on changes in market
conditions, regulatory risk, liquidity risk, digital asset leverage risk, tactical opportunities, among
others. Clients may withdraw their allocation from any Strategy or digital asset if they do not wish
to hold the rebalanced Strategy and reallocate to other digital assets. In this situation the Client’s
portfolio holdings could diverge significantly from the model Strategy over time. WAO Advisory
manages Client accounts and the portfolios using proprietary software owned and operated by
WAO Advisory. Rebalances are executed programmatically using WAO Advisory’s software.
WAO Advisory is not an exchange and unlike an exchange, WAO Advisory Clients do not place
individual buy and sell orders, nor do they specify a time window for the trades to be executed.
WAO Advisory does not guarantee a market for all requested trades but maintains a general
approach of best efforts to execute all actions requested.
Clients can log into their account portal (or “dashboard”) to monitor their investments in real time.
The account portal also provides access to details relating to each model Strategy.
WAO Advisory will communicate to Clients via email and through the notification center available
on the dashboard.
WAO Advisory does not provide advisory services outside the Strategy-based program described
in this Form ADV.
Tailored Relationships
WAO Advisory selects a curated portfolio that is most appropriate to the Client based on.
Information provided about their investment objectives and financial situation as well as any
reasonable restrictions on their investing through the platform. WAO Advisory prompts clients to
revisit the information and restrictions provided on an annual basis and reaches out to confirm
there have been no changes to the information provided or any changes to a Client’s account
preferences annually.
As noted above, Clients may impose reasonable restrictions on the digital assets WAO Advisory
includes in a Client’s account through the model portfolios by indicating any assets the Client does
not want purchased for his or her account. This occurs during the onboarding process and through
the dashboard.
Wrap Fee Programs
WAO Advisory does not offer a wrap fee program. Clients are charged certain administrative
fees outlined below in addition to a Management Fee, as also described below.
Assets under Management
As/of December 31, 2023, WAO Advisory currently has $6,382 of assets under management on a
discretionary basis. The Firm does not currently have any assets under management managed on
a non-discretionary basis.