SoFi Wealth LLC (“SoFi Wealth”) is an internet based (or “online”) investment advisor registered with the Securities and Exchange Commission (“SEC”) since 2013. SoFi Wealth provides investment advice to individual investors utilizing proprietary software, self-service tools, and through an experienced investment team that provides financial planning services and advice on general asset allocation. SoFi Wealth is owned by SoFi Hold Co., a holding company with no direct operations. SoFi Hold Co. is a direct, wholly owned subsidiary of SoFi Technologies, Inc. and under common ownership with Social Finance, LLC (formerly Social Finance, Inc.) (“SoFi”), a Delaware limited liability company, which is a wholly owned subsidiary of SoFi Technologies, Inc., a Delaware corporation. SoFi Technologies, Inc. is a publicly traded company (NASDAQ: SOFI).
The Services We Provide SoFi Wealth provides clients online investment advisory services pursuant to a computer model over the internet and through a mobile application (“Automated Investing” or “Automated Asset Management Services”).
Wrap Fee Program Automated Asset Management Services SoFi Wealth offers its clients the opportunity to establish Automated Investing under the SoFi Invest brand name. To establish Automated Investing, a client must accept and enter into a SoFi Wealth Advisory Agreement.
In accordance with the SoFi Wealth Advisory Agreement, SoFi Wealth allows the customer to establish an automated recurring deposit into an investment account, offers recommended asset allocation portfolios, manages portfolios, and performs certain advisory functions with respect to each portfolio.
This includes recommending asset allocated portfolios and providing automated portfolio rebalancing services.
SoFi Wealth is authorized to, among other things:
•Recommend one of five asset allocation models to investors - aggressive, moderately aggressive, moderate, moderately conservative, and conservative. The system evaluates user risk profiles through our online risk-evaluation system, also referred to as the Goals, Risk and Objectives Exercise. Through a series of questions with user-input responses (goal, time horizon and risk tolerance), SoFi Wealth identifies appropriate risk profiles based on a set of criteria and automatically assigns the recommended asset allocation for our clients, which is designed to tailor client risk to the profile supplied by the user;
•Identify security choices for our clients in order to attempt to reduce trading costs and other fees; we periodically evaluate the performance of a range of indices and securities to determine if we should replace an asset class or implement an additional asset class in our clients’ portfolios;
•Determine appropriate times for portfolio rebalancing, based on market factors that return the client to the target risk profile and attempt to lower trading costs and other fees;
•Identify asset classes and securities which are appropriate according to certain pre-programmed rules related to a client’s account type and tax status: for instance, the election of a non-qualified vs qualified account will result in different underlying holdings, but models with a like risk tolerance will have similar target risk and return characteristics;
•Identify and evaluate the timing and method of disposition or liquidation of portfolio investments, select and determine investments to be disposed of or liquidated, and cause an investor to dispose of or liquidate investments in accordance with the terms of the Advisory Agreement in order to facilitate allocation remodeling;
•Engage personnel to assist the Investment Adviser in providing investment advisory services, including, without limitation, counsel, consultants, accountants, financial advisors and sub-investment advisers;
•Open, maintain and close accounts, including custodial accounts, but excluding collection accounts, with banks, including banks located outside the United States, and draw checks or other orders for the payment of monies;
•Incur expenses as the Investment Adviser determines to be appropriate in the best interest of investors, and, to the extent that the funds of an investor are available, pay all expenses, debts and obligations;
•Perform such other duties, activities, functions and all other similar things necessary to achieve, implement or facilitate any of the foregoing provisions in the United States as well as foreign jurisdictions as per contractual agreements; and
•Invest investor funds into ETFs, including Sofi-branded ETFs.
There is no limitation or restriction on the ability of the Investment Advisor or any of its Affiliates to act as an investment manager (or in a similar role) for other persons. This and other future activities of the Investment Adviser and its Affiliates raise conflicts of interest.
Wrap Fee Program Overview Automated Investing assets are managed as part of SoFi Wealth’s Wrap Program. A wrap account is a professionally managed investment plan in which expenses, including brokerage commissions, management fees, and administrative costs, are “wrapped” into a single charge. SoFi Wealth’s Wrap Program provides clients with investment guidance, portfolio management, and brokerage services. SoFi Wealth currently does not charge an advisory fee for this service, but clients will be responsible for brokerage and ETF fees.
SoFi Wealth buys and sells securities consistent with analysis designed to seek an investment return the adviser believes to be suitable to the investment objectives and goals of each distinct client account.
SoFi Wealth’s proprietary computer algorithm determines a recommended portfolio with limited, if any, human interaction by performing an analysis of certain information provided by the client when establishing an account. The information analyzed includes the goal of the account, risk tolerance, and time horizon. The higher the risk tolerance and longer the time horizon indicated, the more growth-oriented or aggressive the recommended portfolio will be. Lower risk tolerance and shorter time horizon will result in a more income-oriented or conservative recommendation. Goals are considered to the extent that the account value is expected to be withdrawn in a lump sum, or over time, resulting in a more conservative or aggressive portfolio.
Client accounts are managed on a discretionary basis. See Item 16 ofSoFi Wealth’s Form ADV Part 2A Disclosure Brochurefor more details. Clients are responsible for notifying SoFi of any changes to their financial situation or investment objectives by contacting a SoFi agent at (855) 525-7634. SoFi Wealth will periodically notify clients in writing how to update their financial information or request reasonable investment restrictions. Clients may independently modify their target asset allocation at any time through the SoFi Wealth website. Clients may establish a new Automated Investing account and provide the requested financial information to obtain an updated computer-generated portfolio recommendation from the algorithm.
Clients must appoint SoFi Wealth as their investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under the client’s name. The qualified custodian maintains physical custody of all funds and securities of the Account, and the client retains all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. Please see Item 12 of SoFi Wealth’s Form ADV Part 2A Disclosure Brochure for more information. Apex Clearing acts as the qualified custodian for all accounts enrolled in the SoFi Wealth Wrap Fee Program, and clients may not elect a different custodian.
It is important for a client to understand that we manage investments for other clients. The advice we give to any client might be different from

the advice we give other clients and different from the actions taken on our personal accounts, which presents the potential for a conflict of interest. SoFi Wealth is not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) based on the information you have provided, and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner.
If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit.
Termination of our Advisory Agreement The Advisory Agreement may be terminated by either party at any time, and without cause, in accordance with the applicable Advisory Agreement. Upon termination of any account any earned, unpaid fees will be due and payable in accordance with the applicable Advisory Agreement.
Brokerage Practices SoFi Wealth clients who purchase securities through the SoFi Wealth platform are required to utilize the brokerage services of our affiliate, SoFi Securities, a member of FINRA and SIPC, which acts as an introducing broker-dealer effecting securities transactions for clients’ accounts for which Apex Clearing provides trade execution and clearing services. Apex Clearing is broker-dealer, member FINRA and SIPC.
Not all investment adviser firms require the use of a particular broker/dealer. However, for operational and compliance purposes, we have made the decision to provide all asset management services through one brokerage and custodial platform. You are not required or obligated to utilize our services and therefore you are not required or obligated to open an account with SoFi Securities and Apex Clearing. However, if you do not want to use SoFi Securities or Apex Clearing, we are unable to provide our asset management services to you.
SoFi Wealth seeks the best overall execution of transactions for client accounts. Using an affiliated broker presents a conflict of interest, as it results in additional compensation for the firm. SoFi Wealth obtains information as to the general level of commission rates being charged by the brokerage community from time to time and will periodically evaluate the overall reasonableness of brokerage commissions paid on client transactions by reference to such data to ensure competitive commission rates. “Best execution” means the best overall qualitative execution, not necessarily the lowest possible commission cost. Accordingly, the factors that SoFi Wealth considers when selecting or recommending brokers are matters that directly benefit client accounts, and are consistent with obtaining the best execution of their transactions. These factors include: speed of execution, price improvement, commission, quality of overall execution services, expertise, financial condition, and skill.
SoFi Securities earns revenue from lending securities and earning interest on uninvested cash, via a sweep mechanism, in client accounts. Share lending programs benefit SoFi Wealth’s affiliated broker-dealer, but will only benefit clients to the extent that such revenue is shared with clients.
SoFi Wealth aggregates securities sale and purchase orders for a client with similar orders being made contemporaneously for other client accounts. Using this trading method, the average price of the securities purchased or sold in such a transaction is calculated, and a client charged or credited, as the case may be, the average transaction price. As a result, however, the price may be less favorable to the client than it would be if similar transactions were not being executed concurrently for other accounts.
SoFi Securities earns revenue from their role as introducing broker-dealer, including payments for order flow and securities lending. SoFi Securities does not charge commissions on trades.
Fees and Compensation SoFi Wealth offers asset management services under the brand “Automated Investing,” under the broader SoFi Invest umbrella. SoFi Wealth does not currently charge a management fee for Automated Investing, but its broker-dealer affiliate, SoFi Securities LLC (“SoFi Securities”), earns revenue in two main ways when clients invest with SoFi Wealth. One way is payment for order flow (PFOF) which is the practice of wholesale market makers paying brokers for routing their clients’ orders to the market maker for execution. By acquiring order flow in this way, market makers are able to trade profitably against client orders, while clients may benefit from reduced trading costs. SoFi Securities also earns revenue through Apex Clearing by lending clients’ ETF shares held in brokerage accounts to short-sellers in an activity commonly called “Share Lending.” SoFi Wealth will likely introduce other products or services for which it charges a fee in the future. SoFi Wealth may make changes to fees from time to time and will notify you of any such changes.
SoFi Wealth does not currently receive any sales commissions, 12b-1 fees or other fees from ETFs or other products for investing such funds on behalf of advisory clients. If this changes in the future, clients will be appropriately notified and disclosures updated.
As a general matter, clients who invest in an ETF pay ETF fees. An ETF typically includes embedded expenses that reduce the fund's net asset value, directly affecting the fund's performance and therefore also a Client’s portfolio performance or an index benchmark comparison. Examples of ETF expenses are management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses change from time to time at the sole discretion of the ETF issuer. These ETF fees do not flow back to SoFi Wealth.
SoFi-branded ETFs include the SoFi Select 500 ETF, SoFi Next 500 ETF, SoFi Social 50 ETF, SoFi Enhanced Yield ETF. SoFi-branded ETFs are distributed by Foreside Fund Services, LLC. Not all SoFi-branded ETFs are included in the model portfolios. None of SoFi Wealth or any of its affiliates is an affiliated person of the Funds, the Adviser, the Sub-Adviser, the distributor, or any of their affiliates. The Fund’s investment adviser agreed to waive its Management Fees for the SoFi-branded ETFs used in Automated Investing (SFY and SFYX) until at least June 30, 2024. At such time, the fee waivers end, client holdings will be subject to the management fees, and SoFi Wealth will earn revenue from these ETFs based on the investments made by SoFi Wealth clients.
Investors are charged incidental brokerage account fees for services provided by Apex Clearing such as IRA administration, maintaining inactive accounts, transferring funds or securities to another firm via ACAT, wires, and sending paper statements/confirmations. These fees will change from time to time and can be found at the following website:www.sofi.com/invest/fee-schedule.
A single, all-inclusive fee for brokerage, custodial, and recordkeeping services may cost more or less than purchasing these services separately. The primary factor affecting the comprehensive fee is the provision by SoFi Wealth of individualized investment advice and portfolio management services tailored to the needs of each individual.
SoFi Wealth does not receive transaction-based compensation for the sale of securities to SoFi Wealth investors. SoFi Wealth’s Automated Investing clients are also clients of SoFi Securities and will purchase securities through them which represents a conflict of interest more fully described in Item 9 of this document.