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Dash Investments | ADV 2A Brochure
3.2026
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Dash Acquisitions Inc.
Dash Investments
21600 Oxnard Street, Suite 1755
Woodland Hills, CA 91367
800-549-3227
www.dashinvestments.com
FORM ADV BROCHURE
March 27, 2026
the content of
This brochure provides information about the qualifications and business practices of Dash Investments. If you have
any questions about
this brochure, please contact us at 800-549-3227 or at
info@dashinvestments.com. The information in this brochure has not been approved or verified by the U.S.
Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration does not imply a
certain level of skill or training. Additional information about Dash Investments also is available on the SEC’s website
at www.adviserinfo.sec.gov.
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________________
ITEM 2 - MATERIAL CHANGES TO ADV BROCHURE SINCE LAST ANNUAL AMENDMENT
This section discusses only material changes since the last annual update.
Since our last annual update on March 28, 2025, the following material changes have been made:
•
Item 4 & Item 5: Estate Planning Services defined.
•
Item 4 & Item 5: Tax prep and filing services are offered to clients with at least $1.5 million in assets under management.
Information about Dash Investments is also available on the SEC’s website at www.adviserinfo.sec.gov. To request a copy of
the most recent disclosure brochure, contact us at: 800-549-3227.
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ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES TO ADV BROCHURE SINCE LAST ANNUAL AMENDMENT ________________________________ 3
ITEM 3 - TABLE OF CONTENTS _________________________________________________________________________ 4
ITEM 4 - ADVISORY BUSINESS _________________________________________________________________________ 5
ITEM 5 - FEES AND COMPENSATION _______________________________________________________________ 6
ITEM 6 - PERFORMANCE-BASED FEES AND COMPENSATION ___________________________________________________ 7
ITEM 7 - TYPES OF CLIENTS ___________________________________________________________________________ 7
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS _____________________________________ 7
ITEM 9 - DISCIPLINARY INFORMATION ___________________________________________________________________ 8
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS ____________________________________________ 8
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ______________ 8
ITEM 12 - BROKERAGE PRACTICES ______________________________________________________________________ 9
ITEM 13 - REVIEW OF ACCOUNTS ______________________________________________________________________ 12
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ___________________________________________________ 12
ITEM 15 - CUSTODY _______________________________________________________________________________ 13
ITEM 16 - INVESTMENT DISCRETION ___________________________________________________________________ 13
ITEM 17 - VOTING CLIENT SECURITIES __________________________________________________________________ 13
ITEM 18 - FINANCIAL INFORMATION ___________________________________________________________________ 13
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ITEM 4 - ADVISORY BUSINESS
ADVISORY FIRM
Dash Investments (“Dash”) is a privately held California corporation registered with the SEC. Registration does not imply a
certain level of skill or training. Dash was founded in 2004 and is wholly owned and controlled by Jonathan Dash, who serves
as CEO and Chief Investment Officer. Zain Griffith is the Chief Compliance Officer.
Investment Management Services
Dash provides discretionary portfolio management on an individual account basis using a Global Value strategy focused on
common stocks and bonds held for long-term appreciation. We begin by assessing each client’s financial goals, objectives,
and circumstances, then execute day-to-day transactions without seeking prior consent. Clients may provide standing
restrictions on specific industries or securities.
Dash has limited authority to direct the custodian to deduct advisory fees from client accounts with appropriate written
authorization. Past performance is not a guarantee of future results.
Estate Planning Services
Dash facilitates estate planning support—including the creation of wills, trusts, and powers of attorney—through a
specialized third-party digital platform. Dash is not an attorney and does not provide legal advice or draft documents. All legal
documents are prepared by the platform’s legal professionals.
Participant Account Management Services
Dash uses a third-party platform to manage held-away assets such as defined contribution plan accounts with discretion. The
platform avoids custody issues since Dash does not access client log-in credentials. Dash is not affiliated with the platform
and receives no compensation from it. Accounts are reviewed at least quarterly and rebalanced as needed.
Rollover Recommendations
When advising on retirement assets, Dash acts as a fiduciary under the Investment Advisers Act and/or ERISA. If Dash
recommends rolling over employer plan assets into a managed IRA, a conflict of interest exists because Dash will earn an
advisory fee. Clients generally have four options: (1) remain in the current plan, (2) move to a new employer plan, (3) roll into
an IRA, or (4) cash out. Dash conducts a best-interest analysis comparing fees, investment options, and services before making
any recommendation.
Financial Planning Services
Dash provides comprehensive financial planning addressing goals, objectives, cash flow, estate, tax, retirement income,
charitable giving, and wealth transfer. Services may include:
• Review of financial goals and overall financial position
• Goal-specific plans covering real estate, education, retirement, charitable giving, estate planning, and business
succession
• Goal-oriented investment plans incorporating tax, asset allocation, risk, and liquidity considerations
• Risk management planning including insurance and company benefits
•
Estate plan design in conjunction with estate attorneys and tax advisors
A written financial plan is provided to each client. Financial planning services are included in investment management fees
(see Item 5).
Tax Planning, Preparation and Filing Services
Dash offers two distinct levels of tax-related services as part of our comprehensive wealth management:
•
Tax Planning and Analysis (Available to All Clients): Included in our standard advisory fee, Dash provides ongoing tax
planning and analysis. We utilize specialized software to review your tax returns and financial data to identify strategies
for enhancing the tax efficiency of your portfolio, such as tax-loss harvesting, income timing, or Roth conversions.
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• Tax Preparation and Filing (Asset Minimum Required): Clients with $1,500,000 or more in assets under management
with Dash are also eligible to receive professional tax preparation and filing services. These services are facilitated
through an unaffiliated third-party CPA at no additional charge beyond Dash’s standard advisory fee. Dash’s role in tax
preparation is limited to facilitating access to an independent CPA. All final tax-related decisions should be reviewed
with a qualified tax professional. The CPA is an independent professional, and Dash is not responsible for their specific
services.
Wrap Fee Programs
Dash does not sponsor a Wrap Fee Program.
Assets Under Management
As of December 31, 2025, Dash manages $681,637,820 in discretionary assets and $0 in non-discretionary assets.
ITEM 5 - FEES AND COMPENSATION
Investment Management Fees
Dash charges an advisory fee for investment management, supervision, and account-maintenance services. Financial planning
is typically included in investment management fees. Fees are calculated on all assets including cash and cash equivalents
unless otherwise agreed.
Fee Schedule
Account Value
First $1 Million
Next $4 Million
Over $5 Million
Annual Fee Rate
1.25%
1.15%
1.00%
Dash targets accounts of at least $1,000,000 in investable assets but may accept smaller accounts at its discretion. A minimum
annual fee of $12,500 applies. Dash may negotiate a flat annual rate. Advisory fees are negotiable based on the type of client,
services requested, complexity of the client’s situation, and other relevant factors. Dash’s fees may be higher or lower than
those charged by other investment advisers for similar services.
Fees are paid quarterly in arrears on the last business day of each calendar quarter at one-quarter of the annual rate, based
on closing market value. Contributions and distributions are pro-rated. Fees begin on the date the Investment Management
Agreement is signed. Related accounts may be aggregated (“householded”) for fee purposes, potentially resulting in lower
fees.
The qualified custodian deducts fees directly from client accounts pursuant to written client authorization, and delivers
quarterly account statements showing all deductions including advisory fees.
Either party may terminate the Agreement upon 30 days’ written notice. Upon delivery of a termination notice, the client
may immediately revoke Dash’s discretionary authority. Fees are pro-rated through the termination date.
Estate Planning Fees
Dash does not charge a separate fee for facilitating access to estate planning services as such access is included within Dash’s
standard advisory fee. Dash does not receive compensation from any third party platforms helping to provide estate planning
services.
Financial Planning Fees
Dash includes financial planning services as part of its standard advisory fee.
Tax Preparation and Filing Services
Clients with $1,500,000 or more in AUM with Dash are eligible for tax preparation and filing services through an unaffiliated
third-party CPA at no additional charge. Dash does not receive compensation from the CPA. Any services outside the scope
of what Dash facilitates may be subject to direct fees from the CPA, of which clients will be informed in advance. Dash reserves
the right to modify eligibility requirements upon reasonable notice.
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Additional Fees and Expenses
In addition to the advisory fees paid to Dash, clients may also incur charges from third parties. These include transaction fees,
custodial fees, and internal fund expenses (e.g., management fees, 12b-1 fees, and operating costs) as disclosed in a fund's
prospectus.
While Dash does not typically purchase mutual funds for client portfolios, we may manage existing mutual fund positions at
a client's specific instruction. In these instances, Dash seeks to hold the lowest-cost share class available to the client. Neither
Dash nor its supervised persons accept commissions for selling securities, and Dash does not share in any third-party fees or
expenses.
ITEM 6 - PERFORMANCE-BASED FEES AND COMPENSATION
Dash does not charge performance-based fees for private clients.
ITEM 7 - TYPES OF CLIENTS
Dash provides investment advice to individuals, high net worth individuals, estates, and trusts. The minimum initial account
value is $1,000,000. Exceptions may be made at Dash’s discretion.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Dash provides discretionary investment advisory services using a Global Value strategy. We conduct fundamental research
on a select number of global industries, analyzing financial reports, attending analyst and industry meetings, and engaging
company management. Key attributes evaluated include earnings and pricing power, free cash flow generation, sustainability,
and management quality and experience. Securities are purchased only when deemed appropriately valued, with the intent
to hold long-term.
Investment Philosophy
Dash’s investment approach is based on the following principles:
Long-Term Investing
Dash intends to hold positions for multiple years, providing benefits such as minimized transaction costs, low turnover, and
tax efficiency. We focus on value creation as long-term shareholders rather than market timing.
Focused Industry Groups
Dash concentrates holdings in a limited number of industries and companies, enabling deep research expertise. Positions
may represent a meaningful percentage of the portfolio. Holdings typically include leaders in industries driving global growth.
Reasonable Prices
Dash seeks to acquire high-quality companies at fair prices with strong returns on capital. The objective is to hold positions
long enough that investment returns approach the company’s growth rate.
Competitive Companies and Quality Management
Companies must demonstrate competitive advantages, growth potential, strong long-term returns on capital, free cash flow
generation, and capable management with a proven track record and shareholder-oriented culture.
When suitable investments cannot be identified, Dash may maintain significant cash positions. Dash may sell securities that
have reached intrinsic value, experienced fundamental changes, or to harvest tax losses.
Risks
Concentration Risk: Dash concentrates in a narrow number of industries and companies. Sectors not favored by Dash may
outperform at times, and holdings may be temporarily depressed. A declining share price does not alone trigger liquidation.
Long-Term Focus Risk: Dash does not react to short-term market movements or media commentary. In some instances,
analysis may prove incorrect and portfolio adjustments may be made.
Risk of Loss: Past performance is not indicative of future results. Investing involves risk of loss including loss of original
principal. Dash cannot guarantee or predict future results, identify market tops or bottoms, or insulate clients from losses.
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Accounts are subject to the following risks:
• Market Risk — Economic, political, and issuer-specific events cause security values to rise or fall.
•
Foreign Securities and Currency Risk — International investments involve currency fluctuations, foreign taxes and
regulations, illiquid markets, and political instability.
• Capitalization Risk — Small- and mid-cap stocks have historically been more volatile than large-cap stocks.
•
Interest Rate Risk — Rising rates generally reduce the value of fixed-income securities and may adversely affect
equities.
• Credit Risk — Issuers may be unable to make interest payments or repay principal; credit downgrades may reduce
security values.
•
Securities Lending Risk — Borrower failure to return securities or declines in collateral value may result in fund losses.
•
Liquidity Risk — Certain investments may be difficult to purchase or sell at an advantageous time or price.
• Cybersecurity Risk — Intentional or unintentional events at Dash or its service providers may result in data loss,
unauthorized access to confidential client information, or operational disruptions. Dash has established business
continuity and risk management systems, but these have inherent limitations and cannot guarantee protection.
ITEM 9 - DISCIPLINARY INFORMATION
There are no legal or disciplinary events for Dash and its management personnel.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS
Neither Dash Investments nor any of its management persons is registered, or has an application pending to register, as a
futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the
foregoing entities.
Additionally, neither Dash Investments nor any of its management persons is licensed as an insurance agent or engaged in
the sale of insurance products. Accordingly, the firm and its management persons do not receive commissions or other
compensation from the sale of insurance products.
Clients should review their IAR’s Form ADV Part 2B Brochure Supplement to determine whether their IAR is engaged in
activities creating conflicts of interest. Contact the Chief Compliance Officer with any questions.
Third-Party Tax Preparation Services
Dash maintains a relationship with an unaffiliated third-party CPA through which eligible clients receive tax preparation and
filing services. The CPA is not affiliated with Dash; no fees are shared between the parties and no formal referral
compensation arrangement exists. Clients are under no obligation to use the introduced CPA. Because no compensation flows
between the parties, Dash does not believe this relationship presents a material conflict of interest. However, Dash has an
interest in maintaining this relationship as part of its value-added services for clients with $1,500,000 or more in AUM, which
may create an incentive to refer clients to this particular CPA.
Estate Planning Platform
Dash facilitates client access to estate planning services through an unaffiliated third-party digital platform. Dash does not
receive compensation, referral fees, or revenue sharing from any third party platforms used for estate planning in connection
with client referrals, and third party platforms do not pay Dash any remuneration. Clients are under no obligation to use any
third party platforms and may engage any estate planning professional of their choosing. Because no compensation flows
between the parties, Dash does not believe this relationship presents a material conflict of interest. However, Dash has an
interest in maintaining this relationship as part of the value-added services it offers clients, which may create an incentive to
continue referring clients to the third-party digital platform rather than alternative platforms or providers. Clients should be
aware that the third-party digital platform and its affiliated legal professionals may have their own fee arrangements for
services outside the scope of what Dash facilitates.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics and Personal Trading
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Dash has adopted a Code of Ethics (the “Code”) governing personal securities transactions by officers, managers, members,
and employees (“Employees”). Under the Code, Employees may not purchase or sell securities for personal accounts (1) prior
to implementing a transaction for a Client Portfolio or (2) where the decision is substantially derived from Dash’s role as
investment adviser, absent certain exceptions. An Employee’s personal account includes accounts held in the name of the
Employee, spouse, minor children, or dependents in the same household, accounts for which the Employee is a trustee or
executor, and accounts the Employee controls. Jonathan Dash and other employees have significant personal assets managed
by Dash in the same strategies offered to clients. Employees are generally restricted from securities transactions for Client
Portfolios except to unwind pre-employment transactions, subject to pre-clearance. Clients may request a copy of the Code
by contacting the Chief Compliance Officer.
Participation or Interest in Client Transactions
Dash and its associated persons are prohibited from engaging in principal transactions and agency cross transactions. Dash
and its employees may hold positions in the same securities recommended to or held in client accounts, which creates a
potential conflict of interest. This conflict is addressed through Dash’s Code of Ethics, which prohibits employees from trading
ahead of client transactions and requires pre-clearance of personal securities transactions. Jonathan Dash and other
employees invest significant personal assets alongside clients in the same strategies, aligning employee interests with client
outcomes. Clients may obtain a copy of the Code by contacting the Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
We typically recommend that our Clients utilize Charles Schwab & Co., Inc. Advisor Services ("Schwab"), a registered broker-
dealer, Member SIPC, as the qualified Custodian. Our Firm is independently owned, operated and unaffiliated with Schwab.
Schwab will hold Client assets in a brokerage account and buy and sell securities when our Firm instructs them.
While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and open accounts
with Schwab by entering into account agreements directly with them. The Client opens the accounts with Schwab. The
accounts will always be held in the Client's name and never in our Firm’s.
How Our Firm Selects Custodian-Broker
Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on terms that are,
overall, most advantageous compared to other available providers and their services. Our Firm considers a wide range of
factors, including, among others:
• Combination of transaction execution and asset custody services (without a separate fee for custody).
• Capability to execute, clear, and settle trades (buy and sell securities for Client accounts).
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments,
etc.).
•
The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.).
Quality of services.
• Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the
prices.
• Reputation, financial strength, and stability.
•
Prior service to our Firm and our other Clients.
Availability of other products and services that benefit our Firm, as discussed below (see “Products and Services Available to
Us from Schwab”).
Client Brokerage & Custody Costs
While Dash typically executes trades at $0 commission for U.S. listed equities and ETFs, certain transactions or holdings may
incur third-party charges:
Foreign Securities: Transactions in foreign or over-the-counter (OTC) shares may be subject to Schwab’s standard transaction
fees or currency conversion costs.
Client-Directed Mutual Funds: At a client’s specific instruction, we may manage existing mutual fund positions. These funds
often carry internal management fees and Schwab transaction charges as detailed in the fund’s prospectus.
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Dash does not receive any portion of these third-party fees. For a complete schedule of costs, clients should refer to Schwab’s
Pricing Guide or the applicable fund prospectus.
Products And Services Available To Us From Schwab
Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory Firms and
Clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services
help us manage or administer our Clients’ accounts; others help us manage and grow our business. Schwab’s support services
typically are available on an unsolicited basis and at no charge to our Firm. These are typically considered soft dollar benefits
because there is an incentive to do business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have
established policies in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker
is in the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in carrying out
services to Clients. The following is a more detailed description of Schwab’s support services:
Services That Benefit Our Clients
Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities
transactions, and custody of Client assets. The investment products available through Schwab include some we might not
otherwise have access to or would require a significantly higher minimum initial investment by our Clients. Schwab’s services
described in this paragraph benefit our Clients and their accounts.
Services That May Not Directly Benefit Our Clients
Schwab makes other products and services available that benefit our Firm but may not directly benefit our Clients or their
accounts. These products and services assist our Firm in managing and administering our Clients’ accounts. Specifically,
Schwab provides Dash with software and other technology that:
• Provides access to Client account data (such as duplicate trade confirmations and account statements).
•
Facilitates trade execution and allocates aggregated trade orders for multiple Client accounts.
• Provides pricing and other market data.
•
Facilitates payment of our fees from our Clients’ accounts.
• Assists with back-office functions, recordkeeping, and Client reporting.
Our Interest In Schwab’s Services
The availability of these services from Schwab benefits our Firm because we do not have to produce or purchase them. These
services are not contingent upon our Firm committing any specific amount of business to Schwab in trading commissions. We
believe our selection of Schwab as Custodian and Broker is in our Client’s best interests.
Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit our Client
accounts. Our recommendation or requirement that you place assets in Schwab's custody may be based, in part, on the
benefits Schwab provides to our Firm or our Agreement to maintain certain Assets Under Management at Schwab and not
solely on the nature, cost, or quality of custody and execution services provided by Schwab.
Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and other fiduciary duties.
Schwab's execution quality may be different from other broker-dealers.
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions through a
specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage. We place trades for Client
accounts subject to our duty to seek the best execution and other fiduciary duties.
We will aggregate trades for ourselves or our associated persons with your trades, providing that the following conditions
are met:
• Our policy for the aggregation of transactions shall be fully disclosed separately to our existing Clients (if any) and
the broker/dealer(s) through which such transactions will be placed.
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• We will only aggregate transactions if we believe that aggregation is consistent with our duty to seek the best
execution (which includes the duty to seek the best price) for the Client and is consistent with the terms of our
investment advisory agreement.
• No advisory Client will be favored over any other Client; each Client that participates in an aggregated order will
participate at the average share price for all transactions in a given security on a given business day, with transaction
costs based on each Client's participation in the transaction.
• Our Firm will prepare a written statement (“Allocation Statement”) specifying the participating Client accounts and
how to allocate the order among those Clients.
•
If the aggregated order is filled in its entirety, it will be allocated among Clients per the allocation statement; if the
order is partially filled, the accounts that did not receive the previous trade's positions should be "first in line" to
receive the next allocation.
Notwithstanding the preceding, the order may be allocated on a basis different from that specified if all Client accounts
receive fair and equitable treatment. The reason for the difference in allocation will be documented and reviewed by our
Firm’s Compliance Officer. Our Firm’s books and records will separately reflect, for each Client account, the orders which are
aggregated, and the securities held by and bought for that account.
Our Firm will not receive additional compensation or remuneration of any kind because of the proposed aggregation; and
Individual advice and treatment will be accorded to each advisory Client.
Brokerage For Client Referrals
Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that broker-dealer or third
party.
AGGREGATION & ALLOCATION OF TRANSACTIONS
Our Firm may aggregate transactions if it believes that aggregation is consistent with the duty to seek the best execution for
its Clients and is consistent with the disclosures made to Clients and terms defined in the Investment Advisory Agreement.
No Client will be favored over any other Client. Each account in an aggregated order will participate in the average share price
(per Custodian) for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis. If we determine
that a pro-rata allocation is not appropriate under the circumstances, we will base the allocation on other relevant factors,
which may include:
• When only a small percentage of the order is executed, with respect to purchase allocations, allocations may be
given to accounts high in cash.
• Concerning sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, to the smallest position, or to an account that is out
of line concerning security or sector weightings relative to other portfolios with similar mandates.
• We may allocate one account when that account has limitations in its investment guidelines prohibiting it from
purchasing other securities that we expect to produce similar investment results, and other accounts can purchase
that in the block.
•
If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares
to other accounts. For example, this may be due to unforeseen changes in an account's assets after placing an order.
•
If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more account(s), we
may exclude the account(s) from the allocation.
• Our Firm will document the reasons for any deviation from a pro-rata allocation.
In certain cases, client requests or specific needs will trigger an unplanned transaction in a security where an aggregate
transaction occurred previously during the day. Under these circumstances, client transactions will be excluded from the
block transaction and receive differing pricing.
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Trade Errors
Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always avoid Client trade
errors.
Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in the Client's best
interest. In cases where the Client causes the trade error, the Client will be responsible for any loss resulting from the
correction. Depending on the specific circumstances of the trade error, the Client may not be able to receive any gains
generated due to the error correction. In all situations where the Client does not cause the trade error, the Client will be
made whole, and we would absorb any loss resulting from the trade error if our Firm caused the error. If the Custodian causes
the error, the Custodian will cover all trade error costs. If an investment error results in a gain when correcting the trade, the
gain will be donated to charity. Our Firm will never benefit or profit from trade errors.
Directed Brokerage
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transaction through a
specified broker-dealer. Additionally, our Firm typically does not permit the Client to direct brokerage. Our Firm places trades
for Client accounts subject to its duty to seek the best execution and other fiduciary duties.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or
dealer to obtain goods or services on the plan's behalf. Such direction is permitted provided that the goods and services
provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be
obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased
are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage
provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan.
ITEM 13 - REVIEW OF ACCOUNTS
Periodic Account Review
All accounts are generally reviewed monthly by Jonathan Dash, President of Dash. Reviews focus on all securities using
fundamental analysis, with attention to market conditions, client circumstances, time horizon, risk/return expectations, asset
allocation, and investment goal satisfaction. More frequent reviews may be triggered by changes in a client’s personal, tax,
or financial status, or by geopolitical or macroeconomic events. Clients may request a review at any time.
Client Reports
Clients receive monthly reports including third-party custodian updates on account transactions and holdings. Dash also
provides individual reports and general investment strategy and market outlook information.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Dash participates in the custodian’s institutional customer program and may recommend the custodian to clients. In
connection with this participation, Dash receives economic benefits not typically available to independent advisers, including
(without additional cost or at a discount): duplicate client statements and confirmations; access to a trading desk; block
trading capability; ability to deduct advisory fees directly from client accounts; electronic communications network for order
entry and account information; access to no-transaction-fee mutual funds and institutional money managers. These benefits
create a conflict of interest because their cost would otherwise be borne by Dash, and they may indirectly influence Dash’s
choice of custodian. However, clients do not pay more for assets maintained at Schwab. As fiduciaries, Dash always endeavors
to put client interests first.
Compensation for Client Prospect Generation
Dash pays a flat fee to participate in an online registry program that matches prospective clients with investment advisers.
This fee is payable regardless of whether a prospect becomes a client.
Referrals to Third-Party Service Providers
Dash may introduce clients to third-party service providers, including an unaffiliated CPA for tax preparation and a third-party
platform for estate planning, as described in Items 4 and 10. Dash does not receive referral fees, revenue sharing, or other
compensation from any third-party provider, and no provider pays Dash for client referrals. Clients are under no obligation
to use any introduced provider. Any engagement for services is entered into directly between the client and the provider.
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ITEM 15 - CUSTODY
Dash does not have physical custody of client funds or securities. Dash has limited custody solely due to its authority to deduct
advisory fees from client accounts. All client funds and securities are held at a qualified custodian in separate accounts in
each client’s name, pursuant to written client direction. Clients receive account statements directly from the qualified
custodian at least quarterly, showing all deductions including advisory fees. Clients are urged to review and compare
custodian statements against any reports received from Dash and to contact Dash or the custodian with questions.
ITEM 16 - INVESTMENT DISCRETION
Prior to engagement, clients execute a written Investment Management Agreement granting Dash authority to supervise and
direct investments per the client’s objectives and guidelines, and additional custodian documents authorizing Dash to
purchase, sell, or exchange securities without prior consultation. Dash is authorized to: (1) buy, sell, exchange, and trade
securities; (2) determine the amounts to be bought or sold; and (3) place orders with the custodian. Any limitations on
discretionary authority must be communicated to Dash in writing and may be amended by the client at any time.
ITEM 17 - VOTING CLIENT SECURITIES
Voting Proxies
Unless a client instructs Dash otherwise in writing, Dash votes proxies on behalf of clients. Dash has adopted proxy voting
policies and procedures (the “Policies”) requiring it to vote proxies in the best interests of clients and in a prudent, diligent
manner intended to enhance the economic value of client accounts. Dash may abstain where the client’s economic interest
is limited relative to the overall portfolio or where the client’s vote will not affect the outcome. Dash generally votes for
proposals recommended by the issuer’s board of directors unless specific company or industry concerns warrant otherwise,
determined on a case-by-case basis. Dash uses Broadridge’s ProxyEdge to vote proxies, managing notifications, voting,
tracking, mailing, reporting, and record maintenance. Clients may obtain a copy of the Policies and information on how Dash
voted shares by contacting Dash. Where clients retain proxy voting authority, the custodian will forward all proxy materials
directly to the client.
Class Action
Dash uses Broadridge’s Global Securities Class Action Services to monitor class action shareholder lawsuits and file claims on
behalf of eligible clients. A 25% contingency fee is assessed directly by Broadridge only if a recovery is made; Broadridge pays
recovery funds directly to clients net of this fee. Clients may opt out by advising Dash in writing.
ITEM 18 - FINANCIAL INFORMATION
Dash does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance and
therefore is not required to include a balance sheet. Dash has never been the subject of a bankruptcy petition.
Dash Investments | ADV 2A Brochure
3.2026
Page 13 of 13
PRIVACY POLICY NOTICE
FACTS
WHAT DOES DASH INVESTMENTS “DASH” DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell you how
we collect, share, and protect your personal information. Please read this notice carefully to
understand what we do.
The types of personal information we collect and share depends on the product or service you
have with us. This information can include, but is not limited to:
What?
Investment experience and risk tolerance.
• Social Security number and income;
• Assets and transaction history; and
•
When you are no longer our client, we continue to share your information as described in this
notice.
How?
All financial companies need to share clients’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their clients’
personal information; the reasons Dash chooses to share and whether you can limit this
sharing.
Reasons we can share your personal information
Does Dash Share?
Can you limit this sharing?
YES
NO
For our everyday business purposes–
This includes sharing with service providers who
perform services on our behalf, such as account
custodians, technology providers, and compliance
consultants.
YES
YES
For our marketing purposes–
to offer our products and services to you
For joint marketing with other financial companies
NO
We do not share
YES
YES
For text messaging purposes –
To schedule meetings or appointment reminders
NO
We do not share
For our affiliates’ everyday business purposes–
information about your transactions and experiences
For our affiliates to market to you
NO
We do not share
For non-affiliates to market to you
NO
We do not share
For third-party access
NO
We do not share
To limit our
sharing
Please note: This notice is provided at the time we establish our advisory relationship. For new
clients, if you wish to limit permissible sharing, you may contact us within 30 days of receiving
this notice. We will not share your information for purposes you can limit until 30 days after
providing this notice.
Questions?
Call 800.5493227 or go to www.dashinvestments.com.
Privacy Policy 03.2026
Page 2
Who we are
Who is providing this notice?
Dash Investments (“Dash”). We provide this privacy notice annually and when we
make material changes to our privacy practices.
SMS Privacy Policy
Dash values your privacy. By subscribing to our SMS notification service, you agree to this privacy policy.
Data Collection
n We collect your phone number and name for SMS mobile messaging
through the execution of the Investment Advisory Agreement and new
account paperwork.
Data Usage
n Your data is used solely for sending SMS messages This includes SMS
messages for appointment scheduling or appointment reminders.
To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.
§ We take reasonable steps to ensure the confidentiality of client
Data Security
information shared via text messages. However, clients are reminded to
avoid including sensitive personal or financial information, such as
account numbers or Social Security numbers, in text messages.
§ We do not share any individual’s consent to receive SMS from Dash
with third parties. We do not share phone numbers for SMS purposes or
affiliate marketing.
n We retain your contact data for the duration of your enrollment. You may
Data Retention
request deletion at any time.
Opt Out
n Reply STOP to any message to unsubscribe.
n We do not share your information with third parties for marketing purposes.
Non-Sharing Clause
Your information is only shared with our SMS provider for secure
messaging.
What we do
How does Dash protect my personal
information?
To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include
computer safeguards and secured files and buildings.
tell us about your investment or retirement portfolio
How does Dash collect my personal
information?
We collect your personal information, for example, when you
n open an account or give us contact information
n enter into an investment adviser contract or give us your income information
n
We also collect your personal information from other companies.
To ensure compliance and protect client information, all text message
communications are conducted using firm-approved, secure communication
platforms that are monitored and archived in accordance with regulatory
requirements.
Federal law gives you the right to limit only
n
sharing for affiliates’ everyday business purposes—information about your
creditworthiness
Why can’t I limit all sharing?
n affiliates from using your information to market to you
n
sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to limit
sharing.
Definitions & Terms
Companies related by common ownership or control. They can be financial and
nonfinancial companies.
Affiliates
n No mobile information including Personally Identifiable Information
(PII) or SMS consent will be shared with third parties/affiliates for
marketing/promotional purposes.
Companies not related by common ownership or control. They can be financial
and nonfinancial companies.
Non-Affiliates
n No mobile information including Personally Identifiable Information
(PII) or SMS consent will be shared with third parties/non-affiliates for
marketing/promotional purposes.
Third-Party Access
Non-affiliated companies are third-party entities that are not under common
ownership or control with Dash and do not share a corporate relationship. In the
context of SMS communications, these companies may include SMS gateway
providers, mobile carriers, third-party messaging platforms, and vendors that
support multi-factor authentication (MFA). While these entities may transmit,
process, or store SMS messages on behalf of the adviser, they operate
independently and are not affiliated with the RIA.
n We do not share your information with third parties for marketing
purposes. Your information is only shared with our SMS provider for
secure messaging.
A formal agreement between nonaffiliated financial companies that together
market financial products or services to you.
Joint Marketing
n No mobile information including Personally Identifiable Information
(PII) or SMS consent will be shared for joint marketing/promotional
purposes.
Other Important Information
By signing Dash Agreement, I acknowledge that I have fully read and understand this Privacy Policy and opt-in as outlined
above. I understand that if I have any questions or concerns about this policy, it is my responsibility to discuss this with my
financial professional.
We retain client information for at least six years following account closure as required by SEC recordkeeping rules (Rule 204-
2). After the required retention period, client information is securely destroyed in accordance with our information disposal
procedures.
Residents of certain states may have additional privacy rights, including the right to access, delete, or correct personal
information, and the right to opt-out of sales of personal information. For information about state-specific rights, please contact
us at 800.549.3227.
SMS Terms of Service
By opting into SMS through the Dash Agreement, you are agreeing to receive SMS messages from Dash. This includes SMS
messages for appointment scheduling or appointment reminders. Message frequency varies. Message and data rates may
apply. Message HELP for help. Reply STOP to any message to opt out. We reserve the right to revise this policy from time to
time without prior notice. You will be notified of any material changes in Our Privacy Policy either by email or by a conspicuous
posting on our website: www.dashinvestments.com