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Informational Brochure
(Part 2A and 2B, Form ADV)
Covestor Limited doing business as
“Interactive Advisors”, “Interactive Advisers,” “Interactive Brokers Asset Management”, “IB
Asset Management”, and “IBKR Asset Management”
London Office:
Floor 12, 20 Fenchurch Street
London EC3M 3BY
United Kingdom
+44 (203) 787-9250
Boston Office:
100 Summer Street
Floor 16 - Interactive Advisors
Boston, MA 02110
866-825-3005
Website: https://interactiveadvisors.com
February 3, 2026
about
the
contents
of
this
brochure,
please
contact
us
at
1-866-825-3005
This brochure provides information about the qualifications and business practices of Covestor Ltd. If you have any
questions
or
clientservices@interactiveadvisors.com. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state securities authority. This brochure is for
informational purposes only. It does not convey an offer of any type and it is not intended to be, and should not be
construed as an offer to sell, or solicitation of an offer to buy, any interest in any entity, investment, or investment
vehicle.
Additional information about Covestor Ltd is available on the SEC’s website at www.adviserinfo.sec.gov. The SEC’s
website also provides information about any persons affiliated with Covestor who are registered as investment adviser
representatives of Covestor. Covestor’s registration as an investment adviser with the SEC does not imply a certain
level of skill or training. The oral and written communications of an adviser provide you with information, which can
help you determine whether to hire or retain an adviser.
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Item 2: Summary of Material Changes
No material changes have been made to this Informational Brochure since the annual amendment filed on March 31, 2025.
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Item 3: Table of Contents
Informational Brochure
1
Item 2: Summary of Material Changes
2
Item 3: Table of Contents
3
Part 2A: Brochure
4
Item 4: Advisory Business - Covestor Limited (“Covestor”)
4
Item 5: Fees and Compensation
12
Item 6: Performance-Based Fees and Side-by-Side Management of Client Accounts
15
Item 7: Types of Clients
16
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
16
Item 9: Disciplinary Information
35
Item 10: Other Financial Industry Activities and Affiliations
35
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
37
Item 12: Brokerage Practices
40
Item 13: Review of Accounts
43
Item 14: Client Referrals and Other Compensation
44
Item 15: Custody
44
Item 16: Investment Discretion
45
Item 17: Voting Client Securities
45
Item 18: Financial Information
46
Item 19: Requirements for State-Registered Advisers
46
Part 2B: Brochure Supplement - John Dahlstrom
48
Part 2B: Brochure Supplement - Jennifer Mitton
50
Part 2B: Brochure Supplement - Sanjoy Ghosh
52
Part 2B: Brochure Supplement - Bimal Shah
54
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Part 2A: Brochure
Item 4: Advisory Business - Covestor Limited (“Covestor”)
Advisory Firm Background and Principal Owner
Covestor Limited (“Covestor Ltd” or “Covestor”) doing business as (“dba”) Interactive Advisors, Interactive Advisers,
Interactive Brokers Asset Management, IB Asset Management, and IBKR Asset Management, an investment adviser
registered with the United States Securities and Exchange Commission (“SEC”), is a private limited company incorporated in
the United Kingdom and established on May 15, 2006. Covestor Ltd is not registered to conduct investment advisory business
in any jurisdiction outside the United States. Covestor Ltd is incorporated as a private limited company, but is not registered
to provide investment management or advice in the United Kingdom or anywhere outside of the United States.
Covestor Ltd is owned by Covestor Inc., a privately held firm whose principal owner is Interactive Brokers Group, Inc.
Interactive Brokers Group, Inc., together with its subsidiaries (the “Interactive Brokers Group”), is an automated global
electronic broker. Interactive Brokers Group, Inc. is a Delaware corporation whose common stock is publicly traded on
Nasdaq. Additional information about Interactive Brokers Group is available at https://www.interactivebrokers.com
Our registration does not imply any level of skill or training. The oral and written communications we provide to you, including
this brochure, are for you to evaluate us and our services, determine whether the advisory services we offer are right for you,
and disclose the potential conflicts of interest associated with our services.
Covestor primarily conducts its advisory business over the Internet or through privately offered pooled investment vehicles
under one of the above-mentioned business names, which are different from its legal name. The Firm’s website is located at
https://interactiveadvisors.com. For brevity and convenience, Covestor will be referred to as “Interactive Advisors” throughout
this brochure.
Advisory Services
Interactive Advisors provides: (a) online investment advisory services to retail clients through investments in portfolios
(“clients”); and (b) investment advisory and fund management services to private funds (“Fund Clients”).
Online Investment Platform - General Overview
Interactive Advisors offers an online investment platform through which its clients can invest in two types of portfolios: (1)
trading strategies managed by third-party portfolio managers (“Manager Portfolios”) and (2) proprietary investment portfolios
designed and managed by Interactive Advisors itself (“Interactive Advisors Portfolios”). Interactive Advisors allows clients
to invest in these strategies by simultaneously mirroring or replicating the activity in a Manager- or Interactive Advisors-
owned and managed account underlying the specific Portfolio into investing clients’ accounts.
Our services to clients are generally limited to the discretionary management of their assets and do not include financial
planning or any other services, but we may provide clients free of charge certain software-based financial planning tools or
features. Interactive Advisors offers a software tool, the Goal Tracker, which allows logged-in clients to estimate the likelihood
of achieving goals they specify within a set period of time using an asset allocation strategy. This tool uses various assumptions
and its output has various limitations discussed in this white paper on our website: https://interactiveadvisors.com/learn-
more/goal-tracker. Additional information on the assumptions, limitations and risks associated with the Goal Tracker tool is
available in Item 8.
Principal considerations for potential investors
Interactive Advisors’ platform is a primarily online investment platform designed for investors who want to have access to a
wide variety of investment choices (including but not limited to Smart Beta, Asset Allocation, index tracking, model ETF
portfolios, Socially Responsible Investing and various actively-managed investment strategies) and investors who generally
have a longer time horizon. Before opening an account with Interactive Advisors, clients should consider among other things:
the costs and potential benefits of investing in such a platform that charges a management fee in addition to commissions
charged separately by our affiliated broker-dealer, Interactive Brokers LLC (“IB LLC”, “Broker-Dealer”, or “Custodian”); the
need and desire for professional money management services; whether the client is comfortable granting investment discretion
to an investment adviser like Interactive Advisors; the client’s objectives, risk tolerance, time horizon, and financial
circumstances; whether the client prefers a primarily in-person rather than digital (online) and telephonic client experience;
and whether the client can receive documents electronically. Before investing with Interactive Advisors or any other
investment adviser, clients should consider paying off their high-interest debt and using workplace savings options.
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Distinction from traditional advisory services
Clients interested in using Interactive Advisors’ services should be aware of the fact that Interactive Advisors provides its
investment services primarily online, although it does make client support staff available for consultation as needed by Clients
on servicing and investment management issues. Clients should be able and willing to conduct most of their interactions with
Interactive Advisors using electronic methods. In the Investment Management Agreement they execute with Interactive
Advisors, Clients agree to receive all documents, notices, and updates electronically by email or through their access to the
Firm’s website accompanied by an email notice.
Platform Limitations
While we have designed our platform to be broadly applicable to many clients, it may not be appropriate for you if you:
● desire more frequent account reviews for trading opportunities;
● have a very short or a very long investment horizon, a high tolerance for market risk, or a desire to invest significantly
in alternative asset classes; or
● have especially complex investment objectives and needs as your current investments consist of illiquid securities,
annuities, and/or extremely low basis securities.
Because our platform is an online advisory service, it is not appropriate for you if you have limited or no access to technology.
Should you determine that our platform is appropriate for you notwithstanding the above considerations, you must keep in
mind that it is meant to be a component of your overall investment strategy and not your sole investment strategy. The
platform’s projections and decisions are limited in scope to the risk questions we ask you through the website before allowing
you to invest with us and the information that you supply to us. As the platform does not provide comprehensive financial
planning, there may be additional relevant information or other financial circumstances that the platform does not consider
(e.g., your debt load or other financial obligations) that could inform your investment decisions. We urge you to carefully
consider the platform’s costs and benefits before opening an advisory account and beginning to invest.
Interactive Advisors’ risk scoring methodology
Interactive Advisors analyzes each strategy on the platform to determine a risk score for the associated Portfolio. Interactive
Advisors then assigns a risk score between 1 (least risky) and 5 (most risky) to each Portfolio. The purpose of the risk score
is to ensure that the Portfolio risk is in line with client expectations and meets Interactive Advisors’ fiduciary obligation to
recommend suitable investments for clients.
To ensure that Interactive Advisors clients have access only to Portfolios that are suitable for their ability to take on risk and
risk tolerance, Interactive Advisors profiles clients using a risk questionnaire to ascertain their risk tolerance, using the same
scale of 1 to 5. The risk assessment/suitability questionnaire takes into consideration clients’ financial situation, annual net
income, estimated liquid net worth, age, investing knowledge, investment horizon, tolerance for stock market drops, and
attitude towards the trade-off between risk and return in connection with Interactive Advisors investments. Interactive
Advisors calculates risk scores for clients based on clients’ answers to this questionnaire. In determining the risk score of
clients investing in an Interactive Advisors portfolio through their existing investment advisor, Interactive Advisors will take
into account the answers the client’s existing advisor provides in response to the Interactive Advisors risk questionnaire based
on a separate authorization provided by the client to the advisor (discussed in Item 7). Advisors also have the option to use a
general risk scoring tool offered by our affiliate IB LLC to design their own risk questionnaire and risk scoring formula and
generate risk scores for their clients. To ensure consistency between the risk scores generated by its own risk assessment
questionnaire and the IB LLC risk scoring tool, for purposes of investments with Interactive Advisors, the IB LLC tool uses a
risk questionnaire framework and formula that Interactive Advisors’ Investment Management Team has deemed equivalent
to its own risk scoring framework.
Interactive Advisors matches up clients’ assigned risk scores with Portfolio risk scores in accordance with a proprietary risk
scoring methodology, i.e., clients may only invest in Portfolios with a risk score equal to or lower than their risk score.
Based on the risk score assigned by Interactive Advisors, clients may invest in one or more of the Portfolios or strategies that
have risk scores equal to or lower than the client either on their own or with the assistance of Interactive Advisors’ client
service representatives (who are appropriately registered as Investment Adviser Representatives). Interactive Advisors does
not take into account a client’s personal tax situation when recommending and managing portfolios. Interactive Advisors
recommends that clients consult with their tax advisor on such matters.
Clients can update their responses to the risk assessment questionnaire on Interactive Advisors’ website at any time to reflect
changes in their personal circumstances (e.g., financial situation, investment objectives, and risk tolerance). Changes to these
responses could (but do not necessarily have to) result in a change in a client’s risk score and thus the Portfolios that the client
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may be able to invest in. If a client’s updated risk score is lower than the risk score of any of his then-existing portfolio
investments, Interactive Advisors will prompt the client to invest in portfolios with risk scores consistent with the client’s new
risk score and Interactive Advisors will divest the client from the higher-risk-score portfolios after 30 days. Interactive
Advisors provides detailed definitions of all portfolio and client risk scores in the Learn more section of its website, under the
Risk scores tab (https://interactiveadvisors.com/learn-more/risk-scores).
Interactive Advisors clients are and remain responsible at all times for advising Interactive Advisors of any changes in
their financial situation, investment objectives, risk tolerance, and investment restrictions.
investments and may be contacted by
Annually, Interactive Advisors contacts clients to determine whether there have been any changes in their financial situation
or investment objectives and whether clients want to impose new or revise existing restrictions on the trading in their accounts.
Also, at least quarterly, Interactive Advisors will notify clients in writing to contact it if there have been any changes in their
financial situation or investment objectives or they wish to impose any restrictions on the trading in their account. Clients will
generally receive periodic statements and trade confirmations setting forth all transactions in their accounts, all contributions
and withdrawals, all fees and expenses charged, and the value of their account at the beginning and end of the period (including
any fractional share holdings and transactions) from Interactive Advisors’ affiliated broker-dealer, IB LLC. Interactive
Advisors’ client service representatives are available to discuss and explain investment decisions made for their Interactive
Advisors Portfolio
telephone at 1-866-825-3005 and by email at
support@interactiveadvisors.com.
individual, password-protected,
login credentials
to
its website,
Interactive Advisors provides clients with
https://interactiveadvisors.com/ where clients can view their holdings and account history as well as get access to account-
related documents, and revise their answers to the risk assessment questionnaire to reflect changes in their circumstances.
Interactive Advisors’ co-trading technology
Once an Interactive Advisors client invests in a specific strategy, Interactive Advisors simultaneously mirrors or replicates
into investing clients’ accounts the activity in the Portfolio Manager or Interactive Advisors-owned and traded account
underlying that Portfolio. Clients and Portfolio Managers have to enter into agreements with Interactive Advisors and with
Interactive Advisors’ affiliated broker-dealer IB LLC and have to open brokerage accounts with IB LLC.
A central piece of Interactive Advisors’ trading process is the aggregation of all Portfolio Manager or Interactive Advisors
trades (depending on whether the Portfolio is a Manager or Interactive Advisors Portfolio) and investing client orders into a
single order. To ensure pricing and execution fairness and to prevent any potential front-running by Portfolio Managers or
Interactive Advisors of client trades following them, Interactive Advisors places a single order that combines the Portfolio
Manager’s (or Interactive Advisors’) order with the number of shares that need to be transacted in order to replicate the
Manager’s or Interactive Advisors’ strategy into all investing clients’ accounts, a process referenced as “co-trading”.
Interactive Advisors then allocates the share to the Portfolio Manager (or Interactive Advisors) and clients’ accounts on a pro
rata basis at the average share price with transaction costs shared pro rata.
Interactive Advisors’ trading rules and client-specified investment restrictions
Interactive Advisors does not automatically replicate all trades in the Portfolio Managers’ or Interactive Advisors’ accounts.
For instance, clients may specify that certain securities not be traded in their accounts, and Interactive Advisors will block
trading in these securities even if a Manager (or Interactive Advisors) in whose Portfolio the client invests trades that security.
Clients may also decide to apply various Socially Responsible Investing exclusion lists (initially compiled and periodically
updated by Interactive Advisors) to their portfolio investments in order to have their portfolio investments avoid certain issuer
practices (e.g., animal testing; business ethics controversies; corporate political spending and lobbying; energy intensive; fossil
fuels; greenhouse emissions; hazardous waste; high water usage; tobacco, alcohol and gambling; and weapons and gun
manufacturers). Additionally, Interactive Advisors may also disallow certain portfolio trades altogether or simply block them
from replication or mirroring into client accounts based on its trading rules. For instance, Interactive Advisors does not allow
Manager or Interactive Advisors Portfolios to trade certain securities, including those with a market capitalization of less than
$50 million or an average daily volume of less than $100,000. Trades that violate any of Interactive Advisors’ trading rules
are blocked from replication in client accounts.
No guaranteed availability of Portfolios
For various reasons, Interactive Advisors may not be able to continue offering a specific portfolio. For instance, Interactive
Advisors may need to close a Manager Portfolio because the Portfolio Manager has decided to no longer make his trading
data available and terminate his participation on the platform. Portfolio Managers can close a Portfolio upon providing a 30-
day notice to Interactive Advisors at any time. When a closure occurs, Interactive Advisors will attempt to provide clients
with a selection of Portfolios with similar strategies wherever possible. Interactive Advisors may need to close one of the
Interactive Advisors Portfolios because it can no longer obtain the data from a third-party data provider (which may have
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terminated the relevant data licensing agreement) or for another reason. Should that occur, Interactive Advisors will inform
clients investing in such portfolios that the portfolio is no longer available and clients need to invest in different portfolios or
convert their existing investments in such portfolios into cash. Interactive Advisors will provide clients with as much advance
notice as practicable under these circumstances but no less than 30 days. Clients should be aware that in certain cases
Interactive Advisors depends on the Portfolio Managers or a third-party data provider to provide it with advance notice of
such decisions and, in order to protect clients’ interests, some portfolio divestments may need to occur before the expiration
of the 30-day period if the third-party provider decides to stop managing the portfolio before the end of that notice period.
Interactive Advisors cannot ensure that a comparable portfolio will be available, and, whether or not alternative portfolios
exist on the platform or elsewhere.
Clients are under no obligation to maintain an account with Interactive Advisors or, if they maintain an account, to invest in
any Portfolios. Please note that, after the closure of a portfolio, clients can choose to maintain the integer investments in that
closing portfolio in an IB LLC brokerage account distinct from the one managed by Interactive Advisors or an external
brokerage account outside of IB LLC, but clients will be responsible for managing those investments themselves, including
periodically rebalancing the assets. Fractional holdings in a closed portfolio cannot be transferred and must be sold. Please
note that, if you choose to remain invested with Interactive Advisors after the closure of a portfolio, you will incur transaction
fees in connection with liquidating your investment in a closed portfolio and investing in a new portfolio. You may also incur
federal and state tax liabilities if liquidation results in long and/or short-term gains.
Manager Portfolios
Manager Portfolios generally simultaneously replicate (mirror) the trading by third-party Portfolio Managers. Interactive
Advisors assigns risks scores to the Portfolio Manager strategies on its platform and allows Interactive Advisors clients with
commensurate risk scores to invest in those strategies.
Managers on the Interactive Advisors platform may be either registered investment advisors or advisors exempt from
registration. Registered Portfolio Managers must be federal or state-registered investment advisers, including hedge fund
managers. While Non-Registered Portfolio Managers may be hedge fund managers exempt from registration, Interactive
Advisors only allows such Non-Registered Portfolio Managers meeting certain trading experience and portfolio size criteria
to participate. Portfolio Managers participating on the Interactive Advisors platform represent to Interactive Advisors that they
are appropriately registered or licensed or exempt from such licensing or registration requirements in light of the business they
conduct both on and outside the Interactive Advisors platform. Portfolio Managers registered as investment advisers with the
SEC or a U.S. state also confirm to Interactive Advisors they are in good standing, will provide their current Form ADV 2A
and 2B filing to Interactive Advisors, and they and their access persons comply with all applicable regulatory requirements.
Portfolio Managers must also notify Interactive Advisors of changes in their registration or regulatory status. At this time,
only registered Portfolio Managers participate on the Interactive Advisors platform.
Portfolio Managers share their personal investment history by providing Interactive Advisors with access to their trade data
in an IB LLC brokerage account in real-time through a data feed. Portfolio Managers deploy their investment strategy by
trading in that IB LLC brokerage account, which is owned by the Portfolio Managers or their investment advisory firms.
Portfolio Managers license their portfolio holdings and trading record (“Historical Trade Data”) to Interactive Advisors for
publication and analysis. Historical Trade Data provided by Portfolio Managers may be related to the Portfolio Manager’s
trading in client, model (based on aggregate performance of all client assets invested in a given strategy) and/or proprietary
accounts. Some Portfolio Managers also provide additional content including their investment strategy, profile, portfolio
market reports and analysis. (Collectively, this additional content along with Historical Trade Data are referred to as “Manager
Content.”) Managers may run multiple Portfolios on the Interactive Advisors platform. All Manager Content represents the
opinions of that Manager, should not be construed as personalized investment advice to you or any other Interactive
Advisors client, and is subject to change without notice.
Interactive Advisors’ clients do not invest directly with the Portfolio Managers and the Managers do not have
discretionary trading authority over Interactive Advisors client accounts. The Portfolio Managers simply license their
trade data to Interactive Advisors, which then allows its clients to have Interactive Advisors mirror the same strategy
and trading decisions in their accounts if the Portfolio is in line with their risk score. Portfolio Managers implement
their trading philosophy and strategy without knowing the identity of Interactive Advisors’ clients or taking into
account Interactive Advisors clients’ individualized circumstances. Interactive Advisors’ offering of Manager
Portfolios to its clients does not imply that these strategies have been tested elsewhere, or have been successful for the
Portfolio Manager’s clients or the Portfolio Manager himself.
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Information on Manager Portfolios, their strategies, applicable fees, and minimum investment amounts may be found on the
individual portfolio pages on the https://interactiveadvisors.com website, accessible from the portfolio webpage:
https://interactiveadvisors.com/portfolios
Interactive Advisors Portfolios
In addition to Manager Portfolios, Interactive Advisors allows its clients to invest in certain portfolios that Interactive Advisors
itself constructs and manages. These portfolios (referred throughout this Brochure as “Interactive Advisors Portfolios”) are
proprietary investment portfolios designed and managed by Interactive Advisors itself. At this time, these in-house-constructed
portfolios include the Smart Beta Portfolios, the Asset Allocation Portfolio, the Index-Tracking Portfolios, the model ETF
portfolios (e.g., the WisdomTree, and State Street/SSGA Portfolios), and the Socially Responsible Investing Portfolios.
Interactive Advisors may launch additional in-house portfolios in the future and will update this disclosure as needed to discuss
their features and associated risks.
To provide the Interactive Advisors Portfolios, Interactive Advisors initially funds and trades a fixed amount of its funds in
separate proprietary brokerage accounts associated with each portfolio. Interactive Advisors reserves the discretion to add
additional funds to the initial investment amounts in order to manage these Firm-owned accounts with a higher investment
amount and more efficiently manage investments in these portfolios. Interactive Advisors then replicates the trading in these
proprietary brokerage accounts in the accounts of clients investing in that specific portfolio in order to implement its mirroring
procedures. Subsequently, any periodic (e.g., annually, quarterly, monthly or more frequent) rebalancing trades placed by
Interactive Advisors in these portfolios are proportionally replicated in client accounts investing in one or more of these
portfolios via Interactive Advisors’ co-trading technology.
Prior to investing in any of the Interactive Advisors Portfolios discussed below, clients are prompted and required to
review and acknowledge a separate portfolio-line-specific risk disclosure specifically laying out the risks and conflicts
of interest, the applicable fees and commissions, and the brokerage arrangements associated with investments in each
portfolio line. This disclosure document titled “Client Disclosures for Investments in Specific Interactive Advisors
Portfolio Lines” is available on the Forms and Agreements webpage: https://interactiveadvisors.com/forms-and-
agreements
Smart Beta Portfolios
At this time, Interactive Advisors offers 15 Smart Beta Portfolios, briefly discussed below. In the future, Interactive Advisors
may construct and offer to its clients other Smart Beta portfolios. Each Smart Beta portfolio seeks, as its investment objective,
to achieve total returns that exceed the total returns of certain market-capitalization-weighted indices, such as the S&P 500,
by relying on systematic rules-based investment strategies that do not use conventional market capitalization weights. They
are designed to provide systematic exposure to a fundamental factor or combination of factors, and employ alternative
weighting schemes based on measures such as value, growth, quality, and dividend yield.
In July 2019, Interactive Advisors launched ESG equivalents for 5 of the Smart Beta portfolios discussed in Item 8 of this
Brochure.
Additional information on the Smart Beta Portfolio construction process, actual trading results of the Firm-owned accounts
managing these portfolios, and other information on the general features of these portfolios may be found in this white paper:
https://interactiveadvisors.com/learn-more/smart-beta (also accessible from the Learn more tab on our webpage) and on the
individual portfolio pages (accessible from the webpage: https://interactiveadvisors.com/portfolios).
Asset Allocation Portfolio
Upon clients’ taking the risk assessment questionnaire and obtaining a risk score, Interactive Advisors recommends the most
suitable Asset Allocation Portfolio. Clients may accept or disregard this recommendation and proceed to select their own
portfolio investments based on their risk scores. Aside from the Asset Allocation Portfolio, Interactive Advisors recommends
no other portfolios on its platform at this time, allowing clients to select portfolios on their own as long as in line with their
risk score. Interactive Advisors does not recommend any portfolios (including the Asset Allocation Portfolio) to clients
residing in India selecting to invest on the platform pursuant to business arrangements with certain Indian broker dealers
The Asset Allocation Portfolio generally invests in 10-14 Exchange Traded Funds (“ETFs”). Interactive Advisors generally
selects the ETFs in each Asset Allocation Portfolio to best represent the target asset class while having relatively low
management fees and being relatively liquid.
Information on the general features of the Asset Allocation Portfolio may be found in this white paper:
https://interactiveadvisors.com/learn-more/asset-allocation (also accessible from the Learn more tab on the webpage:
https://interactiveadvisors.com).
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The custom Asset Allocation Portfolio feature allows Clients investing in the Asset Allocation Portfolio to adjust up or
down the default ETF allocation in their Asset Allocation Portfolio investment(s), subject to limitations based on the risk
tolerance they indicated to us. The standard Asset Allocation Portfolio uses preset weights for each sub-asset class/ETF
corresponding to Client’s risk score and account type (i.e., regular brokerage versus IRA account). In general, a Client may
increase or reduce an allocation to a particular sub-asset class/individual ETF by up to 3% and may eliminate allocations to
certain sub-asset classes/individual ETFs if our allocation model for his risk tolerance level permits. Clients may also apply
an “industry tilt” to their portfolio by allocating assets to industry/sector-specific ETFs. Depending on their risk score, clients
may allocate 1%-3% of their portfolio to each available sector-specific ETF. Clients may only allocate assets to the ETFs that
Interactive Advisors has selected for inclusion in the Asset Allocation Portfolio program. Each ETF Interactive Advisors
makes available for the Asset Allocation Portfolio is subject to unique risks. For additional details on the risks associated with
a particular ETF, please consult the prospectus and risk disclosures for that ETF. Interactive Advisors has and retains the
discretion to choose which specific ETFs to purchase or sell and the timing of the trade in clients’ custom Asset Allocation
Portfolio investment(s). Interactive Advisors also reserves the right to initially select and subsequently change the available
industry sectors and the specific ETFs corresponding to each industry sector. All specific ETFs used in a custom Asset
Allocation Portfolio are subject to change at Interactive Advisors’ discretion based on its evaluation of liquidity, cost of
ownership (i.e., expense ratio associated with the ETF) and coverage (i.e., adequate exposure to the specific sub-asset
class/industry tilt the ETF seeks to represent) without notice to clients choosing to utilize the custom Asset Allocation Portfolio
functionality. If a client customizes his Asset Allocation Portfolio investment, he may alter the investment characteristics of
the portfolio, including the expected return, risk, diversification and tax efficiency of the portfolio. The allocation clients select
is their ultimate responsibility and the performance of their customized Asset Allocation Portfolio investment may be worse
or better than the performance of Interactive Advisors’ recommended standard Asset Allocation Portfolio. Additionally,
clients’ selection and allocation of ETFs in their custom Asset Allocation Portfolio may result in higher costs to them than
they would incur in Interactive Advisors’ standard Asset Allocation Portfolio for their risk score. Interactive Advisors reserves
the right to modify the customized Asset Allocation Portfolio feature, including by changing or limiting the availability or
weighting of certain investments or groups of investments if it determines such action to be in clients’ best interests.
Clients interested in using our custom Asset Allocation Portfolio feature are asked to carefully read the disclosure language in
Disclosures for Investments in Specific Portfolio Lines (which they receive at the time of investing in the Asset Allocation
Portfolio; available at this location: https://interactiveadvisors.com/forms-and-agreements and consider their personal
circumstances before deciding whether to use our custom Asset Allocation Portfolio feature.
Optional Tax Loss Harvesting Functionality for Clients Investing in the Asset Allocation Portfolio
Interactive Advisors offers clients invested in the taxable Asset Allocation Portfolio the option to use tax loss harvesting
(“TLH”) as a value-added strategy. Tax loss harvesting is a strategy of selling securities in your portfolio that have decreased
in value, to generate capital losses to potentially decrease your taxes while using the proceeds from the sales to purchase
similar (but not identical) securities, to maintain the expected risk and return characteristics of the portfolio. Capital losses
may be used to offset capital gains and/or up to $3,000 per year on income. Tax loss harvesting rules pertain to individual
investors who are US taxpayers or US persons. They may or may not apply to other types of investors. Clients may opt in or
out of TLH at any time on their client dashboard. There is no additional fee for activating the TLH functionality. Clients
remain responsible for the annual account management fees associated with their Asset Allocation Portfolio investments.
Clients who are not invested in our Asset Allocation Portfolio cannot use our TLH functionality.
TLH is conducted quarterly, during the regular quarterly rebalances for the Asset Allocation Portfolio. Our TLH
algorithm gives more weight to short-term losses than long-term losses since the IRS treats short-term capital gains
differently than long-term ones and typically taxes them at a higher rate. The implementation of our TLH algorithm
assumes you do not hold or trade the ETFs held in your Asset Allocation Portfolio investments in any other account.
If the loss is deemed sufficiently large, the algorithm will direct selling of the ETF and replacing it with a different but
historically correlated ETF. When determining whether to harvest a loss and replace an ETF, the TLH algorithm takes into
account factors including the size of the unrealized loss and wash sale avoidance considerations. Replacement ETFs are
selected based on correlation to original ETF, expense ratio, liquidity and the underlying index of the ETF.
If the weighted losses exceed a certain loss threshold and if the ETF has not been purchased over the previous 30 days, all the
holdings in that ETF in the Asset Allocation Portfolio investment will be sold and the proceeds will be used to buy the
replacement ETF. We may revise the TLH algorithm in the future to accommodate partial replacements. During periods of
high trading volatility, Interactive Advisors reserves the discretion to cancel or postpone the replacement trades.
Interested clients should carefully review the disclosure document presented to them before they may turn on this functionality
(also available here: https://cdn.interactiveadvisors.com/22110402/documents/clients/tax-loss-harvesting-disclosure-07-sep-
2022.pdf) and consider their personal circumstances (e.g., tax situation) before activating TLH in their IA account(s). For
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additional details on the operation of TLH, including our list of replacement ETFs, you should read our white paper at:
https://interactiveadvisors.com/learn-more/tax-loss-harvesting. Clients are solely responsible for determining whether to
activate TLH and whether it is suitable in their circumstances.
Socially Responsible Investing Portfolios
Interactive Advisors offers 18 Socially Responsible Investing Portfolios, launched in the period from April 2019 to July 2020,
briefly discussed below. In the future, Interactive Advisors may construct and offer to its clients other Socially Responsible
Investing portfolios. Each Socially Responsible Investing portfolio seeks, as its investment objective, to invest in a basket of
stocks with favorable Socially Responsible Investing characteristics and criteria laid out in the Research section of each
portfolio page by relying on systematic rules-based investment strategies that do not use conventional market capitalization
weights. In addition to financial criteria, these portfolios are constructed using Socially Responsible Investing criteria when
selecting investments.
Additional information on the Socially Responsible Investing Portfolio construction process, actual trading results of the Firm-
owned accounts managing these portfolios, and other information on the general features of these portfolios may be found in
this white paper: https://interactiveadvisors.com/esg and on the individual portfolio pages (accessible from the webpage:
https://interactiveadvisors.com/portfolios).
Index Tracking Portfolios
At this time, Interactive Advisors offers 14 Index Tracking Portfolios. Each Index Tracking Portfolio is designed to follow
certain predefined rules so that the portfolio can track the specified basket of underlying investments of the reference index.
Each of the Index Tracking Portfolios aims to track the performance of the underlying basket of the index, and is a form of
passive investing. Interactive Advisors constructs and manages the Index Tracking Portfolios based on data provided by the
FTSE International Limited (“FTSE”) and the Frank Russell Company (“Russell”) under licensing agreements. The goal of
these portfolios is to allow investors to track the performance of certain specified portions of the US Stock market as
represented by the reference index. While based on data provided by the above two index providers, who calculate the
reference indices, the Index Tracking Portfolios are not in any way sponsored, endorsed, sold, promoted, or recommended by
these two index providers. Additionally, while these portfolios aim to track each corresponding reference index as closely as
possible and mimic the performance of that index, Interactive Advisors cannot make any guarantee that these portfolios will
succeed in doing so. Information on the general features of the Index Tracking portfolios may be found on the individual
portfolio pages, accessible through the webpage: https://interactiveadvisors.com/portfolios (or through the Portfolios links on
the home page).
WisdomTree ETF Portfolios
at:
At this time, Interactive Advisors offers four WisdomTree ETF Portfolios. These portfolios are proprietary investment
portfolios constructed and managed by Interactive Advisors based on data provided by WisdomTree Asset Management, Inc.
(“WisdomTree”) pursuant to a model portfolio licensing agreement. These portfolios are based on WisdomTree’s Model
Portfolios, implementing an index-centric approach seeking to add value through both asset allocation and ETF selection
relative to composite cap-weighted benchmarks. While strategic in nature, these model portfolios also reflect tactical tilts
based on market conditions. These portfolios are almost entirely composed of ETFs owned and managed by WisdomTree and
its affiliates (“WisdomTree ETFs”). WisdomTree primarily uses WisdomTree ETFs in these portfolios unless there is no
WisdomTree ETF consistent with the desired asset allocation or model portfolio strategy. There may be similar ETFs with
higher ratings, lower fees and expenses, substantially better performance or more attractive yield/risk profiles in the market.
Because WisdomTree and its affiliates earn fees for advisory, administrative and other services from most of the ETFs selected
for these portfolios (and thus benefit from investments made in these portfolios), WisdomTree has an incentive to favor its
own ETFs and to include higher cost ETFs in these portfolios. Additional information on the ETFs included in each of these
portfolios, including their investment objectives, risks, charges and expenses, can be found in the prospectus for each ETF
here
(and
https://www.wisdomtree.com/investments/resource-library/prospectus-regulatory-reports
https://www.ishares.com/us/library/financial-legal-tax) or can be obtained by calling 1-866-825-3005. While WisdomTree
manages the model portfolios (deciding on their ETF composition, weighting, periodic reweighting and reallocation), it does
not have discretionary authority over and cannot place trades in Interactive Advisors client accounts. Interactive Advisors is
responsible for placing trades in client accounts invested in portfolios corresponding to each model portfolio and allowing
investments in a specific portfolio deemed suitable for each client based on the client’s responses to a risk questionnaire.
Additional information about each of the WisdomTree ETF Portfolios may be viewed on the individual portfolio pages on our
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-aggressive;
website
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-endowment-moderately-aggressive;
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-conservative;
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-moderate.
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SSGA ETF Portfolios
At this time, Interactive Advisors offers two State Street ETF Portfolios. These portfolios are proprietary investment portfolios
constructed and managed by Interactive Advisors based on data provided by SSGA Funds Management, Inc. (“SSGA”)
pursuant to a model portfolio licensing agreement. These portfolios are based on SSGA’s Global Tactical Asset Allocation
ETF Model Portfolios, implementing a tactical asset allocation decision-making process, which includes evaluation of global
asset classes. These portfolios are almost entirely composed of ETFs owned and managed by SSGA and its affiliates (“SSGA
ETFs”). There may be similar ETFs with higher ratings, lower fees and expenses, substantially better performance or more
attractive yield/risk profiles in the market. Because SSGA and its affiliates earn fees for advisory, administrative and other
services from most of the ETFs selected for these portfolios (and thus benefit from investments made in these portfolios),
SSGA has an incentive to favor its own ETFs and to include higher cost ETFs in these portfolios. Additional information on
the ETFs included in each of these portfolios, including their investment objectives, risks, charges and expenses, can be found
in the prospectus for each ETF here: https://www.ssga.com/us/en/institutional/etfs/fund-finder?tab=documents.
on
our
website
at:
https://interactiveadvisors.com/ssga?portfolio=ssga-growth
While SSGA develops the model portfolios (deciding on their ETF composition, weighting, periodic reweighting and
reallocation), it does not have discretionary authority over and cannot place trades in Interactive Advisors client accounts.
Interactive Advisors is responsible for placing trades in client accounts invested in portfolios corresponding to each model
portfolio and allowing investments in a specific portfolio deemed suitable for each client based on the client’s responses to a
risk questionnaire. Additional information about each of the SSGA ETF Portfolios may be viewed on the individual portfolio
pages
and
https://interactiveadvisors.com/ssga?portfolio=ssga-moderate
Interactive Advisors Multi-Manager Funds
Interactive Advisors’ Fund Clients currently consist and are expected to consist of the Interactive Advisors Multi-Manager
Funds, which Interactive Advisors launched on February 1, 2022. Interactive Advisors provides investment advisory services
on a discretionary basis to three privately offered pooled investment vehicles in a master-feeder structure: Interactive Advisors
Multi-Manager Onshore Fund, L.P, a Delaware limited partnership (the “Onshore Fund”); Interactive Advisors Multi-Manager
Offshore Fund, L.P., a Cayman Islands exempted limited partnership (the “Offshore Fund”); and, Interactive Advisors Multi-
Manager Master Fund, L.P., a Cayman Islands exempted limited partnership (the “Master Fund”) (each, a “Multi-Manager
Fund” and collectively, the “Multi-Manager Funds”).
Interactive Advisors Clients and the Investment Management Agreement
Clients must enter into one or more written agreements with Interactive Advisors setting forth the terms and conditions under
which Interactive Advisors shall render its services (the “Investment Management Agreement” or “Client Agreement”) before
they engage Interactive Advisors to provide its investment management services. This agreement provides Interactive
Advisors with discretionary authority to initiate investment activities on behalf of the client over the client’s investment assets.
A copy of Interactive Advisors’ form Client Agreement is available upon request, as well as via the Forms and Agreements
page on our website in the Account Opening Agreements and Disclosures link (https://interactiveadvisors.com/forms-and-
agreements). Pursuant to that agreement, Interactive Advisors uses its related custodian’s trading facilities to mirror or
replicate trades in Manager or Interactive Advisors Portfolio accounts into the investing clients’ accounts. Interactive Advisors
uses its affiliated broker-dealer, IB LLC, to execute all trades on its platform.
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account
statements directly from IB LLC for their accounts (by mail, electronically on IB LLC’s website or through an IB LLC window
embedded on the client dashboard at https://interactiveadvisors.com/). Clients also receive online access to account activity
reports from Interactive Advisors that include relevant account and/or market-related information such as an inventory of
account holdings and account performance on a daily basis, and monthly updates of account balances and performance.
However, Clients should review the information in their custodial statements for accuracy and compare that information to
any report they receive from Interactive Advisors.
Interactive Advisors expects to execute an Investment Management Agreement with each of the Fund Clients. Investors in the
Fund Clients (the “Fund Client Investors”) are provided with reports as further described in each Fund Client’s governing and
offering documents.
Assets Under Management
As of December 31, 2025 Interactive Advisors manages approximately $196 million in assets on a discretionary basis,
including approximately $46 million in private fund assets. Interactive Advisors does not manage any assets on a non-
discretionary basis at this time. Clients should be aware that a significant shareholder of Interactive Brokers Group, Inc. is
also a significant client of Interactive Advisors.
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Termination of the Investment Management Agreement
The agreement between Interactive Advisors and the client will continue in effect until terminated by either party pursuant to
the terms of that agreement. Clients receive a copy of Interactive Advisors’ written disclosure statement or Informational
Brochure (i.e., this document) at the time they execute the Client Agreement.
Interactive Advisors Website
The content of the Interactive Advisors website at https://interactiveadvisors.com, including Manager Content, performance
analysis and rankings is provided as general and impersonalized investment information and commentary, and does not
constitute a specific recommendation or solicitation that anyone should purchase or sell any particular security, investment
advisory service, or portfolio. Interactive Advisors relies on information provided to it by Portfolio Managers and certain third
parties in publishing Manager Content for the websites, and also provides internally-generated content. Interactive Advisors
obtains Manager Content from sources believed to be reliable, but makes no representation as to its accuracy or completeness.
Item 5: Fees and Compensation
Interactive Advisors advisory fees are calculated and charged to clients investing in portfolios through its website on the
following basis:
Annual Management Fees
If engaged, Interactive Advisors charges an annual fee based upon a percentage of the market value of the assets being
managed by Interactive Advisors, i.e., the assets that a client chooses to invest in a Manager or Interactive Advisors Portfolio
(“Management Fee”).
Clients are able to invest in more than one portfolio available on https://interactiveadvisors.com. Interactive Advisors charges
distinct Management Fees for investments in each portfolio. If clients choose to invest in multiple portfolios, they will be
charged the sum of the fees associated with each portfolio they invest in. Management Fees vary by Portfolio chosen and the
level of assets invested in that Portfolio. No Management Fees are charged on assets that are not invested in a Portfolio.
1. For Manager Portfolios, the Management Fee consists of an annual management fee, quoted as an annual
percentage of the market value of client assets invested in a Manager Portfolio, ranging between 0.25% and
0.75% of the market value of client assets invested in each Portfolio.
a. The Management Fee charged by Interactive Advisors for investments in each Manager Portfolio may be
found on our website at https://interactiveadvisors.com/portfolios.
b. For Manager Portfolios, Interactive Advisors retains 0.25% of any Management Fees charged to its clients
and pays any remaining portion of Management Fees collected from clients to the Portfolio Managers.
c. Clients may be able to contract directly with the Portfolio Managers offering their strategies on the
Interactive Advisors platform to obtain their advisory services outside of the platform at lower fees
than they pay to Interactive Advisors.
2. For the Interactive Advisors Portfolios, Interactive Advisors charges investing clients an annual Management
Fee ranging between 0.10% and 0.20% of the market value of client assets invested in each portfolio.
a. For the Smart Beta, Asset Allocation, and Socially Responsible Investing Portfolios, Interactive
Advisors charges 0.20% of the market value of client assets invested in one of these portfolios.
i.
The Asset Allocation Portfolio is made up of ETFs. As explained throughout this Brochure, ETF
issuers charge management fees and expenses, which are disclosed in the ETFs’ prospectuses.
Clients will be solely responsible, directly or indirectly, for these additional expenses. Interactive
Advisors does not receive any portion of these commissions, fees, or costs, including but not limited
to the fees or costs charged by ETF sponsors or issuers. Clients may contact Interactive Advisors
at any time to get information on the fees and expenses charged by the ETFs in which they
are invested through their investment in one or more of the Interactive Advisors Portfolios
(e.g., Asset Allocation, SSGA, or WisdomTree Portfolios) or Manager Portfolios.
ii.
Because Interactive Advisors staff have constructed and manage the Smart Beta, Asset Allocation,
and Socially Responsible Investing Portfolios without any involvement on the part of Portfolio
Managers or a third-party data provider, Interactive Advisors retains the entire fee charged to its
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clients for investments in these portfolios and does not pay any portion of this fee to any Portfolio
Managers or other third-party data providers.
b. For the Index Tracking Portfolios, Interactive Advisors charges investing clients an annual
Management Fee amounting to 0.20% (20 basis points) of the market value of client assets invested in
one or multiple Index Tracking Portfolios.
i.
Interactive Advisors remits half of the 0.20% annual management fee collected from investing
clients to FTSE International Limited or the Frank Russell Company, the index providers licensing
the data necessary to construct and rebalance these portfolios.
c. For the WisdomTree andSSGA, and ETF Portfolios, Interactive Advisors charges investing clients an
annual Management Fee amounting to 0.10% (10 basis points) of the market value of client assets
invested in those portfolios. Interactive Advisors does not remit any of that fee revenue to
WisdomTree orSSGA, but these ETF model providers benefit from the expense ratios associated with
the ETFs included in the models they provide to Interactive Advisors.
3.
Interactive Advisors’ Management Fee shall be computed daily, but prorated and charged monthly, in arrears or
retroactively for the previous month (or in connection with a withdrawal from a portfolio), based upon the daily
market value of invested assets during the previous month. Thus, on a daily basis, the applicable fee rate associated
with each Portfolio in which a client has invested will be applied to the end-of-day market value of the client’s
investment (i.e., assets in client account invested) into that Portfolio, with the resulting amount divided by 365. For
purposes of calculating Interactive Advisors’ Management Fee, the value of the investment will be the value on the
day the fee is calculated (i.e., the initial value of the assets initially invested by the client in the strategy and all
intervening additions to or subtractions from that up to the date the fee is calculated). At the end of each month, the
client is charged a Management Fee made up of the sum of all daily fees calculated during that month for each
investment.
4. For the initial month of investment management services, the first month’s fees shall be calculated on a pro rata basis.
Interactive Advisors’ fee shall be prorated through the date of termination and any remaining balance shall be charged
or refunded to the client, as appropriate, in a timely manner.
5. The market value of an investment for purposes of calculating the Management Fee that a client owes to Interactive
Advisors is calculated based on data provided by IB LLC, Interactive Advisors’ affiliated broker-dealer and
custodian. IB LLC uses pricing data from independent third parties (SIX Financial, aka Telekurs for U.S. stocks and
ETFs) to arrive at the asset pricing information used by Interactive Advisors to derive portfolio values for purposes
of its Management Fee calculations.
6.
Interactive Advisors automatically deducts its Management Fees from client accounts, as authorized in the Client
Agreement, using IB LLC’s invoice billing process. Interactive Advisors calculates the fees owed to it by each client
every month and submits the invoice to IB LLC. IB LLC debits those fees from client accounts and pays them to
Interactive Advisors. The fees calculated and invoiced by Interactive Advisors must be in accordance with the level
of fees outlined for the various portfolios in the Client Agreement and at https://interactiveadvisors.com/low-fees.
Interactive Advisors does not charge its clients fees in advance. Additional details on how Interactive Advisors
calculates the Management Fees due to it by clients investing in any of its portfolios are included in Appendix A of
the Investment Management Agreement all clients agree to before retaining Interactive Advisors as their investment
advisor.
Interactive Advisors, in its sole discretion, may waive a portion of the Management Fee or charge a lower Management Fee
based upon certain criteria, including but not limited to: the initial launch of a service line, anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing
client, account retention, and pro bono activities. Interactive Advisors’ fees are not generally negotiable by individual clients.
The fees applicable to each Manager Portfolio available on the platform are generally negotiated between Interactive Advisors
and the Portfolio Manager offering the specific strategy.
Costs, Fees and Expenses Not Included in Interactive Advisors’ Annual Management Fees
Interactive Advisors’ fees only cover its investment advisory services and do not include brokerage commissions,
custodial fees, transaction fees, exchange fees, ETF fees or other related costs and expenses incurred for the investment
of client assets in portfolios offered by Interactive Advisors.
Unlike other robo advisor portfolio offerings, which charge a single wrap fee covering management fees and brokerage
commissions, Interactive Advisors’ management or advisory fee does not include the commissions associated with the trading
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in these portfolios. IB LLC commissions are also discussed in detail in Item 12: Brokerage Practices. You may also find
additional information on IB LLC’s commissions on the Interactive Advisors and IB LLC websites (including this location:
https://interactiveadvisors.com/low-fees)
In May 2021, Interactive Advisors elected to have all of its clients’ brokerage accounts at IB LLC operate under the
zero-commission “IBKR-LITE” fee model. IBKR-LITE clients are charged zero commission for US exchange-listed stock
and ETF trades. IBKR-LITE orders for NMS stocks are generally routed to select over-the-counter market-makers (“Market
Makers”) for handling. IB LLC’s agreements with the Market Makers provide IB LLC with payment for order flow (“PFOF”)
from each Market Maker for trades executed with that Market Maker. IB LLC may also route IBKR-LITE orders to another
broker, ATS, or exchange (each an “Away Route”), in which case it may collect PFOF for trades executed at or through that
Away Route. Although IB LLC’s receipt of PFOF may reduce the amount of price improvement that client accounts obtain
on their stock and ETF trades (as compared to the price improvement available under IBKR’s IBKR-PRO fee model),
Interactive Advisors believes that the amount that clients save by avoiding commissions (as compared to IBKR-PRO)
generally more than compensates for any loss of price improvement. For more information about IBKR-LITE, please refer to
Item 12: Brokerage Practices, found later in this Brochure and the IB LLC website (including this location: ibkr.com/compare).
count
towards
the
client
IBKR-Lite clients are charged no brokerage account activity fees and no market data fees for US exchange-traded
stocks and ETFs, but they may incur non-commission related fees such as market data fees for other products, service
fees such as wire transfer fees, and fees to cover regulatory fees incurred by IB LLC when clients sell stocks. These fees
are not intended to be a direct pass-through of exchange and third-party fees. Costs passed on to IBKR-Lite clients
may be greater than the costs paid by IBKR to the relevant exchange, regulator, clearinghouse or third party. For
products not entitled to zero-commission trading under IBKR-Lite, the same commission structure will apply to both
IBKR-Lite and IBKR-Pro. Where applicable, a “Fixed” commission model will apply to IBKR-Lite clients for such
products. For more information, see ibkr.com/commissions. OnClose, OnOpen, and outside regular trading hours
("Outside-RTH"), US listed stock orders are free for IBKR-Lite clients so long as the total monthly volume of shares
executed in the Open, Close auction or Outside-RTH does not exceed 10% of an account's monthly US stock trading
volume, otherwise the account will be charged USD 0.005 per share. Market orders placed prior to regular trading
hours will be
threshold.
treated as Market OnOpen orders and
https://www.interactivebrokers.com/en/pricing/commissions-stocks.php
Interactive Advisors’ election of the IBKR-LITE service for its client Accounts constitutes a conflict of interest in light of the
corporate affiliation between Interactive Advisors and IB LLC and the fact that the payments IB LLC will receive from Market
Makers and Away Routes on client Account orders will benefit the parent company of both entities (IBG LLC) and thus
Interactive Advisors indirectly, and the fact that IBKR-LITE executions may (but are not expected to) bring clients higher
total cost of execution than IBKR-PRO executions (even after accounting for the commissions savings, as a result of missed
opportunity for greater price improvement). This conflict of interest is disclosed to and acknowledged by Interactive Advisors
clients at account opening through signing this Agreement and the provision of a separate disclosure. This conflict is mitigated
by Interactive Advisors periodically reviewing IB LLC’s execution quality statistics to confirm that IBKR-LITE’s total cost
of execution (calculated as commissions and fees paid minus price improvement obtained) is generally equal to or better than
IBKR-PRO’s total cost of execution after accounting for the commissions savings from IBKR-LITE. Interactive Advisors
believes the benefits clients will receive from the IBKR-LITE commission structure outweigh the conflict of interest.
By acknowledging that Interactive Advisors uses the IBKR-LITE service for all its client accounts, you understand
that: (1) IB LLC will receive and retain all such payments from Market Makers and Away Routes, in whole or part,
for its own account and not that of the client, in consideration for services provided by IB LLC to the client; and (2)
you may have received better price improvement if IB LLC sent your orders to the market rather than the Market
Makers.
In addition to the advisory fees you pay to Interactive Advisors, you will be charged other separate, distinct and
additional fees and expenses by third parties, e.g., fees and expenses charged by mutual funds, REITs or ETFs. For
instance, ETF issuers charge management fees and expenses, which are disclosed in the ETFs’ prospectuses. ETFs typically
include certain embedded expenses that reduce the fund’s net asset value, and indirectly the performance of your investment
in a portfolio investing in ETFs. The embedded expenses of an ETF include ETF management fees, custodian fees, brokerage
commissions, and legal and accounting fees. These expenses may change from time to time at the sole discretion of the ETF
issuer. This means that you will pay more if you invest in portfolios made up of ETFs than if you purchased the ETFs directly.
Please note that Interactive Advisors does not benefit either directly or indirectly from these fees and expenses and
does not receive any portion of these and clients will be solely responsible, directly or indirectly, for paying these
additional fees and expenses. Clients may contact Interactive Advisors at any time to get information on the fees and
expenses separately charged by the ETFs in which they are invested through their investment in one or more of the
Interactive Advisors Portfolios or Manager Portfolios. Clients are directed to review Item 12: Brokerage Practices,
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found later in this brochure. In addition to the above fees, there may be other costs assessed to clients that are not included
in Interactive Advisors’ Management Fees, such as costs associated with exchanging currencies, wire transfer fees or other
fees required by law. No persons at Interactive Advisors or any supervised persons or representatives of Interactive Advisors
accept compensation or commissions for the sale of securities or other investment products (e.g., asset-based sales charges or
service fees from the sale of mutual funds).
Performance-Based Fees
Interactive Advisors does not charge Performance-Based Fees to clients investing in its portfolios through its website.
Fund Client Fees and Expenses
Management Fees
The fees applicable to each Fund Client, and the methodology for calculating such fees, are detailed in each Fund Client’s
offering documents, including the Private Placement Memorandum. Fee structures for certain Fund Clients can vary among
different classes of interests within a Fund Client. Interactive Advisors receives a management fee of 0.25% per annum from
the Multi-Manager Master Fund. Each Third-Party Sub-Advisor receives a management fee of 0.75% per annum from the
Multi-Manager Master Fund for its services in managing a Sub-Account in the Master Fund.
Fund Expenses and Other Costs
In addition to those fees and charges described above, Fund Clients will bear additional fees and expenses. The expenses borne
by a specific Fund Client are detailed in such Fund Client’s offering documents. The following is a non-exhaustive list of
expenses borne by Fund Clients (which may vary from Fund Client to Fund Client). Additional detail regarding the specific
expenses within each category is disclosed in each Fund Client’s offering documents:
(i) expenses related to the research, due diligence and monitoring of actual and prospective Fund Client investments (whether
or not consummated) and the consummation of Fund Client investments; (ii) the Third-Party Sub-Advisors’ performance fees;
(iii) organizational and reorganizational expenses; and (iv) operational expenses.
Generally, all expenses borne by the Fund Clients, other than the management fees and any expenses that the general partner
of the Fund Clients determines should be allocated to a particular Partner or Partners (e.g., Investor-Related Taxes), will be
debited to all of the Capital Accounts on a pro rata basis in accordance with their Partnership Percentages. To the extent that
expenses to be borne by a Fund Client are paid by the general partner of the Fund Clients or Interactive Advisors, such Fund
Client will reimburse such party for such expenses.
The Fund Clients do not have a pre-determined limit on their ordinary or extraordinary operating expenses. Each Fund Client’s
actual annual operating expenses will be disclosed in each Fund Client’s year-end audited financial statements, which are
provided to each Fund Client investor.
Performance-Based Fees
The performance allocation and/or performance fee (collectively, “performance compensation”) applicable to each Fund
Client is detailed in each Fund Client’s offering documents, including the PPM. Performance compensation arrangements for
certain Fund Clients can vary among different classes of interests within a Fund.
For the Multi-Manager Funds, each Third-Party Sub-Advisor who manages the Fund Client’s assets through a Sub-Account
of the Fund Client is eligible for a performance fee of 10% of the annual appreciation, if any, of the value of net assets managed
by such Third-Party Sub-Advisor above a cumulative “high water mark” calculated at the level of the Sub-Account (the “Third-
Party Sub-Advisor Performance Fee”).
Item 6: Performance-Based Fees and Side-by-Side Management of Client Accounts
Interactive Advisors does not receive Performance-Based Fees from clients investing in its portfolios through its website or
from the Fund Clients. The Multi-Manager Master Fund pays Performance-Based Fees to Third-Party Sub-Advisors who
manage Sub-Accounts in the fund. These Performance-Based Fees are described in greater detail above and in each Multi-
Manager Fund’s offering documents.
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Item 7: Types of Clients
Interactive Advisors’ clients who invest in its portfolios through its website include individuals, trusts, corporations, and other
legal entities.
Utilizing fractional trading, the majority of portfolios on our platform have an investment minimum of just $100.
Interactive Advisors has established the following account minimums:
● Manager Portfolios - For most Manager Portfolios the investment minimums range between $500 and $50,000, with
the majority of these portfolios having minimum required investments of $10,000 and below; and
●
Interactive Advisors Portfolios (e.g., Smart Beta, Asset Allocation, Socially Responsible Investing Portfolios, Index
Tracking, WisdomTree ETF Portfolios, and SSGA ETF Portfolios) - $100 minimum investment.
Clients may become Interactive Advisors clients and invest in one or more portfolios on the platform in one of two ways:
● By applying to open an Interactive Advisors account on the Interactive Advisors website; or
● By authorizing their investment advisor to open an Interactive Advisors account on their behalf on the Interactive
Advisors website.
Under the first method, clients sign Interactive Advisors’ Investment Management Agreement and acknowledge all required
documents and disclosures online directly.
Under the second method, clients’ investment advisors may hire Interactive Advisors as a sub-advisor. The client’s investment
advisor has responsibility to communicate with the client and to determine the suitability of investments in Interactive Advisors
portfolios based on the client’s financial circumstances, risk tolerance, liquidity needs, net worth, investment experience, and
any other factors that may be relevant and appropriate for such a determination. Clients’ investment advisors gather all
information needed to open an Interactive Advisors account on behalf of their clients and invest clients’ assets in such
portfolios as the advisor and the client deem appropriate. These investment advisors are responsible for providing clients with
a current copy of Interactive Advisors’ disclosure statement prepared in accordance with Form ADV Part 2 (i.e., this
Informational Brochure), and any other Interactive Advisors disclosures. Before Interactive Advisors allows an investment
advisor to invest one of its clients in an Interactive Advisors portfolio, Interactive Advisors will conduct its own due diligence
of the advisor and also obtain from advised clients a signed agreement allowing their advisor to invest their account in
Interactive Advisors portfolios (“Client Authorization”).
Interactive Advisors Fund Clients are privately offered pooled investment vehicles, as described in Item 4 above. Fund Clients
only accept as investors individuals or entities qualifying as Qualified Purchasers or Accredited Investors under the relevant
regulations pursuant to questionnaires administered by IB LLC before such individuals and entities are allowed to access IB
LLC’s Hedge Fund Marketplace, the sole platform on which investors can invest in the Fund Clients.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Interactive Advisors employs a variety of methods and strategies to make investment decisions and recommendations to
clients.
Manager Portfolios
For Manager Portfolios, Interactive Advisors typically relies on the investment decisions of Portfolio Managers in its
management of client accounts. Interactive Advisors attempts to track the Portfolio Manager’s trades as accurately as possible,
but it does maintain discretion to modify the Portfolio Manager’s trades or rebalance investing client accounts in order to
provide the best services to clients.
Interactive Advisors selects the Manager Portfolios that it will offer on the platform using a variety of criteria. As part of its
processes to ensure the quality of the Portfolio Managers on the Platform and to minimize the risk of Manager front-running,
Interactive Advisors screens the Managers and may require that they meet certain minimum criteria (e.g., AUM, size of
personal funds invested in the strategy). Interactive Advisors may also require that Portfolio Managers and their lead traders
certify to Interactive Advisors that they will not trade ahead of Interactive Advisors clients in their proprietary or personal
accounts or systematically trade ahead of Interactive Advisors clients in any non-Interactive Advisors client accounts using
the same strategy. Before Portfolio Managers launch their strategy on the platform, Interactive Advisors monitors the
performance of the strategy in the Manager’s IB LLC account in a live test environment. In this live test environment, the
Informational Brochure - February 3, 2026
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Managers make trades in their account and Interactive Advisors tracks the performance of their account. Interactive Advisors
displays the performance of the Manager’s account on its public website, if and when the Manager’s strategy is ultimately
approved to be listed on the platform. Interactive Advisors clients are not allowed to invest in the Manager’s strategy during
this live test period.
Managers complete a questionnaire in which they specify their parameters for portfolio construction, risk control and strategy
guidelines. This questionnaire assists Interactive Advisors in gathering information about each Manager, including his or her
investment philosophy, process, and strategy differentiators. Managers may then provide Interactive Advisors with historical
trade data for their strategy for periods before the Manager joined the platform. Interactive Advisors analyzes this information
to ensure consistency with the Manager’s responses to the questionnaire and other strategy-related materials. If the Portfolio
demonstrates performance and risk characteristics consistent with the strategy and Interactive Advisors’ Investment
Management team believes that the Manager has the skills and experience to consistently deliver the strategy described,
Interactive Advisors will open the Portfolio up for client investments. Interactive Advisors does not impose specific
performance requirements and views the consistency with which Portfolio Managers implement their strategy and ability to
generate alpha as more important in selecting Portfolio Managers for its platform.
Portfolio Managers generally use the following types of investments in managing Portfolios on the Interactive Advisors
platform:
● Equity Securities, including exchange-listed securities, certain over-the-counter securities, and American Depositary
Receipts (“ADRs”); and
● Exchange-traded funds (“ETFs”).
Interactive Advisors Portfolios
For the Interactive Advisors Portfolios (e.g., Smart Beta, Asset Allocation, Socially Responsible Investing, Index Tracking,
WisdomTree, and SSGA ETF Portfolios), Interactive Advisors utilizes a proprietary computer algorithm or model developed
in-house or licensed from a third-party data provider in order to select the stocks or ETFs included in the portfolios initially
and during periodic rebalancings (e.g., annually, quarterly, monthly, or more frequent). Interactive Advisors Portfolios
generally trade in equity securities traded on U.S. exchanges and ETFs and the main sources of information for the transactions
in these portfolios include data about US stocks and/or ETFs provided by third-party data vendors.
Prior to investing in any of the Interactive Advisors Portfolios discussed below, clients are prompted and required to
review and acknowledge a separate portfolio-line-specific risk disclosure specifically laying out the risks and conflicts
of interest, the applicable fees and commissions, and the brokerage arrangements associated with investments in each
portfolio line. This disclosure document titled “Client Disclosures for Investments in Specific Interactive Advisors
Portfolio Lines” is available on the Forms and Agreements webpage: https://interactiveadvisors.com/forms-and-
agreements
Smart Beta Portfolios
Interactive Advisors has undertaken research and back-testing to select the fundamental factors, rules, and/or weighting used
to construct the ten Smart Beta Portfolios. These portfolios combine elements of automated (robo) investing with management
oversight, and are auto-rebalanced quarterly to maintain their optimal strategic composition. Below are short descriptions of
the ten Smart Beta Portfolios offered at this time.
The Value Portfolio targets an allocation of 300 long positions, with stocks having attractive valuation ratios receiving higher
allocations, and both trailing and forward price-earnings valuation ratios being considered when determining allocations. This
contrarian approach to stock selection allows the Value Portfolio to allocate capital to companies that may be out of favor with
the market, but poised for recovery. The Value Portfolio has a significant element of broad equity market risk, and is therefore
exposed to stock market volatility and drawdowns. Due to this portfolio’s focus on value stocks, it will likely suffer greater
losses if this segment of the market underperforms.
The Growth Portfolio targets an allocation of 300 long positions, with stocks having attractive growth ratios receiving higher
allocations, and both trailing and forward earnings growth measures being considered when determining allocations. Even if
a company reports better than expected past results, the guidance given during the quarter is also important and considered by
Interactive Advisors in determining the attractiveness of the stock. The Growth Portfolio has a significant element of broad
equity market risk and is therefore exposed to stock market volatility and drawdowns. Due to this portfolio’s focus on growth
stocks, it will likely suffer greater losses if this segment of the market underperforms.
The Quality Portfolio targets an allocation of 300 long positions, with stocks having attractive quality ratios receiving higher
allocations, and return on assets and other earnings quality measures being considered when determining allocations. This
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portfolio seeks securities with strong fundamentals that are not excessively overvalued. The Quality Portfolio has a significant
element of broad equity market risk, and is therefore exposed to stock market volatility and drawdowns. Due to this portfolio’s
focus on quality stocks, it will likely suffer greater losses if this segment of the market underperforms.
The Dividend Portfolio targets an allocation of 300 long positions, with stocks having attractive dividend yields and stable
payouts receiving higher allocations. This ensures that future dividend payouts are less likely to be at risk. One advantage of
this portfolio is that it offers investors a stream of dividend income while also providing the potential for longer-term attractive
returns.
The Broad Market Portfolio targets an allocation of 1,000 long positions, with allocations being a blend of equal and
capitalization weight. Because of the equal weight component, the portfolio has a larger proportion of smaller companies
compared to a portfolio that is purely capitalization-weighted. During rebalancing of this portfolio, Interactive Advisors tends
to buy securities that have shown a relative decline in value, and sell securities that have shown a relative increase in value.
The portfolio is therefore less prone to having a concentration in bubble stocks that have experienced dramatic price
appreciation. The Broad Market Portfolio has a significant element of broad equity market risk, and is therefore exposed to
stock market volatility and drawdowns. Due to this portfolio’s use of half equal weighting, it will likely underperform if small-,
mid-cap or value stocks underperform.
Interactive Advisors also offers small-capitalization company versions of the above five portfolios.
In May 2019, Interactive Advisors launched the ESG Broad Market Portfolio. Also, in July 2019, Interactive Advisors
launched the following ESG versions of the above four portfolios: ESG Growth Portfolio , ESG Value Portfolio , ESG
Quality Portfolio , and ESG Dividend Portfolio. These portfolios use an ESG (Environment, Social and Governance)
investment strategy, which limits the types and number of investment opportunities available to this portfolio and could
underperform portfolios without an ESG focus, be they the Smart Beta Broad Market Portfolio, other Smart Beta portfolios,
or other portfolios on the Interactive Advisors platform or elsewhere. The ESG investment strategy of these portfolios could
result in the portfolios investing in securities, industries or sectors that underperform the market as a whole, foregoing
opportunities to invest in securities, industries or sectors that might otherwise be advantageous to invest in, and
underperforming other portfolios or investments screened for different ESG standards. Interactive Advisors could also be
unsuccessful in creating a portfolio composed of companies that exhibit positive or favorable ESG characteristics. The
performance of these portfolios is compared against a broad market investable ETF benchmark without an ESG focus, which
limits the comparability of the portfolio returns to the benchmark’s performance.
Additional information on the Smart Beta Portfolio construction process, actual trading results of the Firm-owned account
managing the portfolio, and other information on the general features of these portfolios may be found in this white paper:
https://interactiveadvisors.com/learn-more/smart-beta (also accessible from the Learn more tab on our webpage), on the
individual portfolio pages (accessible from the webpage:https://interactiveadvisors.com/portfolios) and the “Disclosures for
Investments in Specific Portfolio Lines” at this location: https://interactiveadvisors.com/forms-and-agreements
Asset Allocation Portfolio
Interactive Advisors has undertaken research to ensure that the diversified mix of asset classes for Asset Allocation Portfolio
is appropriate for the targeted investor profile and level of risk. Interactive Advisors Investment Management Team has looked
for diversification not only across asset classes (e.g., equities versus bonds), but also within a single asset class (e.g., corporate
bonds versus treasuries). Portfolio optimization techniques, weight and risk constraints were then considered to derive target
allocations. Interactive Advisors has screened and selected specific ETFs to best represent the target asset class, while also
having relatively low management fees and more liquidity. For taxable accounts, Interactive Advisors has selected tax-
advantaged assets like municipal bonds. Each quarter, these portfolios are rebalanced to target allocations. The selection and
weighting of the specific ETFs in each portfolio depends on their expected return characteristics, the degree of diversification
that they provide within the portfolio, the management fees charged by each ETF, and their relative liquidity. Every quarter
Interactive Advisors rebalances these portfolios to target weights. Interactive Advisors tries to combine different asset classes
in each portfolio to provide income, growth, and stability during different economic conditions while taking into account the
various asset classes’ historical performance.
The portfolio allocates capital to an equity component, a bond component, and an inflation-hedging component. Together
these deliver good diversification, which leads to risk reduction and return stability. The capital allocation to each of these
asset classes is dialed up or down depending on the targeted risk level. The portfolio’s final allocations depend on the targeted
level of risk, as well as on whether the capital is held in a tax-advantaged account like an IRA.
the general features of
the Asset Allocation portfolio may be found
in
Information on
this white paper
https://interactiveadvisors.com/white-papers/asset-allocation (also accessible from the Resources tab on the webpage:
Informational Brochure - February 3, 2026
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https://interactiveadvisors.com) and the “Disclosures for Investments in Specific Portfolio Lines” at this location:
https://interactiveadvisors.com/forms-and-agreements
Socially Responsible Investing Portfolios
Interactive Advisors offers thirteen (eighteen if one includes the ESG variants of the Smart Beta portfolios) Socially
Responsible Investing Portfolios. Interactive Advisors has undertaken research and back-testing to select the fundamental
factors, rules, and/or weighting used to construct the Socially Responsible Investing Portfolios. These portfolios combine
elements of automated (robo) investing with management oversight and are auto-rebalanced annually to maintain their optimal
strategic composition. These portfolios are constructed using a rules-based algorithm to determine position allocations.
Allocations are a blend of capitalization weights and equal weights. Due to the various filters employed, several of which do
not relate to financial criteria, the name count may be lower, and sector concentration higher, than other broadly diversified
portfolios. In order to reduce portfolio weight concentration in just a few names, we use allocations that are a blend of equal
and capitalization weight. Every year these portfolios are rebalanced to target weights. Below are short descriptions of the
main Socially Responsible Investing Portfolios offered at this time.
The Clean Air Portfolio is designed to invest in environmentally-conscious companies that are committed to reducing
emissions, manage the sustainability of their energy consumption, and aim to have a low-carbon footprint.
The Company Transparency Portfolio is designed to invest in companies that make an effort to protect their customers. We
include in this portfolio companies that care about customer welfare and data security, and follow best practices regarding
product safety, quality and product labeling.
The Customer Safety Portfolio is designed to invest in companies that care about customer privacy and safety, product access
and affordability, product quality and safety, and follow good selling practices. Failure on the part of a company to address
these factors may lead to misuse of personal data, product recalls from harmful practices, deceptive labeling, and predatory
selling, to name just a few.
The Ethical Leadership Portfolio is designed to invest in companies that follow best-practice corporate governance,
competitive behavior, and risk management principles, and provide equal treatment of stakeholders. We include in this
portfolio companies that demonstrate management’s ability to interact with regulators, resolve conflict between corporate and
societal interests, act responsibly in times of crises, and avoid anti-competitive behavior, such as collusion, fraud, and
corruption.
The Fair Labor & Thriving Communities Portfolio is designed to invest in companies that care about the societies where
they operate as well as maintain diverse and equal opportunities, and development opportunities for their workforce. We
include in this portfolio companies that care about upholding fair labor standards, maintain a safe and healthy workplace, have
processes and policies in place against abusive labor practices, and are committed to being good citizens, protecting public
health, and respecting business ethics.
The Gender Equality Portfolio is designed to invest in companies that maintain diverse and equal opportunities, and
development opportunities for their workforce. We include in this portfolio companies trying to achieve gender parity by
encouraging equal pay, active recruiting, promotion of women, and embracing a culture of tailored benefit packages and
mentorship programs.
The LGBTQ Inclusion Portfolio is designed to invest in companies that maintain diverse and equal opportunities, and
development opportunities for their LGBTQ workforce. We include in this portfolio companies that focus on culture and
hiring and promotion practices that embrace the building of a diverse and inclusive workforce with a focus on the LGBTQ
community.
The Land Health Portfolio is designed to invest in companies that pay attention to harmful land waste as a byproduct of their
activities and take into consideration the safe treatment, storage, and disposal of solid waste while observing local and universal
regulations. In constructing this portfolio, we also consider how companies handle the impact from the extraction of natural
resources, such as deforestation, biodiversity damage, and habitat loss.
The Mindful Business Models Portfolio is designed to invest in companies that display business model resilience and
incorporate ESG elements into long-term planning. We include in this portfolio companies that are working towards the
transition to low-carbon and climate-friendly economies and where management has shown a willingness to proactively
address legal and regulatory ESG issues.
The Ocean Life Portfolio is designed to invest in companies that manage their water use and place value on ocean and marine
life. We include in this portfolio companies that have waste management and recycling initiatives and controls and systems in
place to avoid significant disasters that can impact ocean life.
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The Pure Water Portfolio is designed to invest in companies that manage their water use and avoid contamination and toxic
waste. We include in this portfolio companies that care about the management of wastewater treatment and discharge, their
impact on ecosystems and the health and safety of the local community, including community members’ access to clean water.
The Racial Equality Portfolio is designed to invest in companies that maintain diverse and equal opportunities, and
development opportunities for their workforce. We include in this portfolio companies that practice equal hiring and provide
employment opportunities to persons of all races, regardless of skin color, backgrounds, and ethnicities in an environment that
is free of discrimination.
The Sustainable Product Lifecycle Portfolio is designed to invest in companies that consider the design, quality, and safety
of products and services, focusing on the entire supply chain and the materials used in manufacturing products. This portfolio
also attempts to capture the value companies and suppliers place on labor practices and human rights.
These portfolios use an ESG investment strategy. Such a strategy could limit the types and number of investment opportunities
available to these portfolios, lead the portfolios to underperform a portfolio without an ESG focus or with a distinct ESG focus,
and result in the portfolios investing in securities or industry sectors that underperform the market as a whole or foregoing
opportunities to invest in securities that might otherwise be advantageous to invest in. Interactive Advisors could also be
unsuccessful in creating a portfolio composed of companies that exhibit positive ESG characteristics.
Additional information on the Socially Responsible Investing Portfolio construction process, actual trading results of the Firm-
owned account managing the portfolio, and other information on the general features of these portfolios may be found in this
white paper (https://interactiveadvisors.com/esg), on the individual portfolio pages (accessible from the webpage:
https://interactiveadvisors.com/portfolios) and the “Disclosures for Investments in Specific Portfolio Lines” at this location:
https://interactiveadvisors.com/forms-and-agreements
ESG Exclusionary Lists
In January 2020, the Firm started offering clients the option to select from several predefined exclusionary lists in investing
in portfolios on the platform. Clients may select one of the following exclusionary lists in order to avoid investing in companies
they do not think share their values. Each of the following exclusionary groups is based on detailed business classification and
ESG metrics, typically contains 25 stocks, and is reviewed quarterly:
● Animal testing - excluding companies selling personal and household products and services that test cosmetic
products on animals;
● Business ethics controversies - excluding companies with the most controversies relating to ethics, politics or
corruption, as published in the media;
● Corporate political spending and lobbying - excluding companies with the highest amount of political donations
and those that spend the most on lobbying, relative to size;
● Energy intensive - excluding companies with the highest total energy usage;
● Fossil fuels - excluding companies that operate in the coal industry and/or are the largest producers of oil;
● Greenhouse emissions - excluding companies with the highest reported direct and indirect CO2 emissions;
● Hazardous waste - excluding companies responsible for creating the highest hazardous waste;
● High water usage - excluding companies with the highest levels of water withdrawals;
● Tobacco, alcohol and gambling - excluding companies deriving revenue from sales of tobacco, alcohol and
gambling activities; and
● Weapons and gun manufacturers - excluding companies deriving revenue from sales of military equipment and
weapons.
Clients deciding to exclude securities in any of these lists from their portfolio investments should understand that these
exclusions affect the performance of their portfolio investments as many of our portfolios have an overlap with the
stocks of companies engaging in practices targeted by the above exclusion lists. As clients decide to actively remove
specific securities from default portfolios on the platform by selecting one or more of the above exclusion lists to be
applied to their portfolio investments, they should expect the performance of these modified portfolios to materially
deviate from the default version of the portfolios.
Clients may find more information on these exclusionary lists on this webpage: https://interactiveadvisors.com/esg
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Index-Tracking Portfolios
Interactive Advisors offers 14 Index Tracking Portfolios. Each Index Tracking portfolio is designed to follow certain
predefined rules so that the portfolio can track the performance of a specified basket of underlying investments, a form of
passive investing. Interactive Advisors constructs and manages the Index Tracking Portfolios based on data provided by FTSE
and Russell under licensing agreements. The goal of these portfolios is to allow investors to track the performance of certain
specified portions of the US Stock market as represented by the reference indices. While based on data provided by the above
two index providers who calculate the indices these portfolios seek to track, the Index Tracking Portfolios are not in any way
sponsored, endorsed, sold, promoted or recommended by these two index providers. Additionally, while these portfolios aim
to track each corresponding reference index as closely as possible and mimic the performance of that index, Interactive
Advisors cannot make any guarantee that these portfolios will succeed in doing so.
At this time, Interactive Advisors offers the following Index Tracking Portfolios:
1. The Russell 1000 Real Estate Managed Portfolio seeks to invest in the real estate space across the US economy
with exposure to all investment and property sectors. The portfolio contains all tax-qualified REITs with more than
50 percent of total assets in qualifying real estate assets other than mortgages secured by real property that also meet
certain minimum size and liquidity criteria.
2. The Russell 1000 Consumer Discretionary Managed Portfolio invests in stocks of companies that provide goods
and services that consumers purchase on a discretionary basis. The portfolio targets long US Consumer discretionary
equities within the Russell 1000® Index.
3. The Russell 1000 Consumer Staples Managed Portfolio invests in stocks of companies providing direct-to-
consumer products that, based on consumer spending habits, are considered non discretionary. The portfolio targets
long US Consumer Staple equities within the Russell 1000® Index.
4. The Russell 1000 Dividend Growth Managed Portfolio seeks to invest in the top large-capitalization US dividend
equities within the Russell 1000® Index. The portfolio targets companies that have successfully increased their
dividend payments over a period of ten years within the Russell 1000® Index. Companies are screened for liquidity
and dividend status, then selected and equal weighted subject to a maximum individual sector weight of 30%.
5. The Russell 1000 Energy Managed Portfolio invests in stocks of companies involved in the exploration and
production of energy products such as oil, natural gas, and coal. The portfolio targets long US Energy equities within
the Russell 1000® Index.
6. The Russell 1000 Financial Services Managed Portfolio invests in stocks of companies that provide financial
services. The portfolio targets long US Financial Services equities within the Russell 1000® Index.
7. The Russell 1000 Health Care Managed Portfolio includes stocks of companies involved in providing medical or
healthcare products, services, technology, or equipment. The portfolio targets long US Healthcare equities within the
Russell 1000® Index.
8. The Russell 1000 Basic Materials Managed Portfolio includes stocks of companies that extract or process raw
materials. The portfolio targets long US Materials and Processing equities within the Russell 1000® Index.
9. The Russell 1000 Industrials Managed Portfolio includes stocks of companies that manufacture products and
provide services that consumers purchase on a discretionary basis. The portfolio targets long US Producer Durables
equities within the Russell 1000® Index.
10. The Russell 1000 Technology Managed Portfolio includes stocks of companies that serve the electronics and
computer industries or that manufacture products based on the latest applied science. The portfolio targets long US
Technology equities within the Russell 1000® Index.
11. The Russell 1000 Utilities Managed Portfolio includes stocks of companies that distribute electricity, water, or gas,
or that operate as independent power producers. The portfolio targets long US Utility equities within the Russell
1000® Index.
12. The Russell 3000 Dividend Growth Managed Portfolio seeks to invest in the top U.S. dividend equities within the
Russell 3000® Index. The portfolio targets companies that have successfully increased their dividend payments over
a period of ten years within the Russell 3000® Index. Companies are screened for liquidity and dividend status, then
selected and equal weighted subject to a maximum individual sector weight of 30%.
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13. The Russell Top 200 Managed Portfolio seeks to invest in the top 200 large-capitalization US equities. The
portfolio targets 200 long positions based on the Russell Top 200 Index. The Russell Top 200® Index is a market
capitalization weighted index of the largest 200 companies in the Russell 3000 Index.
14. The Russell 1000 Telecommunications Managed Portfolio consists of companies that are associated with the
global transmission of audio and video data.
Information on the general features of the Index Tracking portfolios may be found on the individual portfolio pages, accessible
through the webpage (https://interactiveadvisors.com/portfolios) (or through the Portfolios tab on the home page) and the
“Disclosures for Investments in Specific Portfolio Lines” at this location: https://interactiveadvisors.com/forms-and-
agreements.
WisdomTree ETF Portfolios
risks,
charges
and
can
be
found
in
the
prospectus
for
each ETF
reviewed
on
the
individual
portfolio
pages
on
our
website
Interactive Advisors offers four WisdomTree ETF Portfolios. These portfolios are proprietary investment portfolios
constructed and managed by Interactive Advisors based on data provided by WisdomTree pursuant to a model portfolio
licensing agreement. These portfolios are based on WisdomTree’s Model Portfolios, implementing an index-centric approach
seeking to add value through both asset allocation and ETF selection relative to composite cap-weighted benchmarks. While
strategic in nature, these model portfolios also reflect tactical tilts based on market conditions. These portfolios are almost
entirely composed of ETFs owned and managed by WisdomTree and its affiliates (“WisdomTree ETFs”). WisdomTree
primarily uses WisdomTree ETFs in these portfolios unless there is no WisdomTree ETF consistent with the desired asset
allocation or model portfolio strategy. There may be similar ETFs with higher ratings, lower fees and expenses, substantially
better performance or more attractive yield/risk profiles in the market. Because WisdomTree and its affiliates earn fees for
advisory, administrative and other services from most of the ETFs selected for these portfolios (and thus benefit from
investments made in these portfolios), WisdomTree has an incentive to favor its own ETFs and to include higher cost ETFs
in these portfolios. Additional information on the ETFs included in each of these portfolios, including their investment
here
objectives,
expenses,
https://www.wisdomtree.com/investments/resource-library/prospectus-regulatory-reports
(and
https://www.ishares.com/us/library/financial-legal-tax) or can be obtained by calling 1-866-825-3005. You may contact us to
obtain a listing of all the ETFs included in these portfolios. Additional information on the WisdomTree ETF Portfolios may
be
at:
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-aggressive;
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-endowment-moderately-aggressive;
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-conservative;
https://interactiveadvisors.com/wisdomtree?portfolio=wisdomtree-moderate and the “Disclosures for Investments in Specific
Portfolio Lines” at this location: https://interactiveadvisors.com/forms-and-agreements
SSGA ETF Portfolios
Interactive Advisors offers two SSGA ETF Portfolios. These portfolios are proprietary investment portfolios constructed and
managed by Interactive Advisors based on data provided by SSGA pursuant to a model portfolio licensing agreement. These
portfolios are based on SSGA’s Global Tactical Asset Allocation ETF Model Portfolios, implementing a tactical asset
allocation decision-making process, which includes evaluation of global asset classes. These portfolios are almost entirely
composed of ETFs owned and managed by SSGA and its affiliates (“SSGA ETFs”). There may be similar ETFs with higher
ratings, lower fees and expenses, substantially better performance or more attractive yield/risk profiles in the market. Because
SSGA and its affiliates earn fees for advisory, administrative and other services from most of the ETFs selected for these
portfolios (and thus benefit from investments made in these portfolios), SSGA has an incentive to favor its own ETFs and to
include higher cost ETFs in these portfolios.
and
and
in
the
“Disclosures
for
Investments
in Specific Portfolio Lines”
at
this
Additional information on the ETFs included in each of these portfolios, including their investment objectives, risks, charges
and expenses, can be found in the prospectus for each ETF here: https://www.ssga.com/us/en/institutional/etfs/fund-
finder?tab=documents.. You may contact us to obtain a listing of all the ETFs included in these portfolios. Additional
information about each of the SSGA ETF Portfolios may be reviewed on the individual portfolio pages on our website at:
https://interactiveadvisors.com/ssga?portfolio=ssga-
https://interactiveadvisors.com/ssga?portfolio=ssga-growth
moderate
location:
https://interactiveadvisors.com/forms-and-agreements.
Multi-Manager Funds
The Multi-Manager Funds’ investment objective is to generate attractive absolute returns on invested capital over a multi-year
period. Interactive Advisors, as Investment Manager, seeks to achieve that objective by initially allocating and periodically
Informational Brochure - February 3, 2026
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reallocating the Multi-Manager Funds’ capital among multiple sub-accounts (“Sub-Accounts”) managed by third-party sub-
advisors (“Third-Party Sub-Advisors”).
Interactive Advisors allocates the Master Fund’s capital among Sub-Accounts and assigns each Sub-Account to a different
Third-Party Sub-Advisor using a proprietary automated selection and allocation process that it has developed and back-tested.
Third-Party Sub-Advisors are private fund managers that meet the eligibility criteria described below and for whose Flagship
Fund (i.e., fund that formed the basis of Interactive Advisors’ initial selection of such Third-Party Sub-Advisor) IB LLC acts
as the prime broker. The Master Fund will invest only in the liquid products that are available on IB LLC’s electronic trading
platform. To be eligible to participate as a Third-Party Sub-Advisor, an investment advisor must meet the following criteria:
(1) prime brokerage client in good standing of IB LLC for at least three years; (2) management of a private fund that submits
trade orders exclusively through and custodies assets at IB LLC; (3) fund assets invested in assets having daily liquidity; and
(4) execution of a sub-advisory agreement. Interactive Advisors will evaluate each prospective sub-advisor’s qualifications
and determine, in its discretion, whether to accept it as a Third-Party Sub-Advisor.
Interactive Advisors will apply its proprietary algorithm to rank the Third-Party Sub-Advisors and intends to allocate the
Master Fund’s assets to approximately 15 to 30 Third-Party Sub-Advisors. Interactive Advisors will consider a variety of
factors in selecting Third-Party Sub-Advisors, including, but not limited to, portfolio net asset value; number of portfolio
holdings; performance indicators; portfolio Sortino ratios; portfolio composition; return correlation with market indices and
the length of such prospective Third-Party Sub-Advisor’s relationship with IB LLC. Interactive Advisors may increase or
reduce this number in its discretion and expects the number to fluctuate over time. Interactive Advisors will allocate not more
than approximately 15%, which may increase due to market movements, and not less than 1% of the Master Fund’s assets to
each selected Third-Party Sub-Advisor.
Each selected Third-Party Sub-Advisor will be required to manage its Sub-Account in parallel with such Third-Party Sub-
Advisor’s Flagship Fund, and will be required to trade its Flagship Fund and its Sub-Account together utilizing IB LLC’s
institutional trading platform and functionality that will help to allocate executed orders between the Flagship Fund and the
Sub-Account pro rata based on the total net asset value of the Flagship Fund and the Sub-Account. Interactive Advisors will
establish processes and procedures to monitor Third-Party Sub-Advisors’ parallel management of their Flagship Funds and
Sub-Accounts and will address material discrepancies. The Third-Party Sub-Advisors may, with regard to their respective
Sub-Accounts, engage in a wide range of investment strategies utilizing the liquid products available on IB LLC’s electronic
trading platform.
Interactive Advisors typically rebalances the Master Fund on the first day of each fiscal year ("Rebalance Date"), but may
choose to rebalance at any time at its discretion. To effectuate a rebalancing, Interactive Advisors will utilize its proprietary
algorithm and repeat the ranking and allocation process that it utilized for the initial selection of Third-Party Sub-Advisors
and allocation of Master Fund assets. In effecting a rebalancing, the Interactive Advisors may reallocate assets among Sub-
Accounts and add or eliminate Sub-Accounts or Third Party Sub-Advisors.
Interactive Advisors will allocate any additional capital received from new or existing investors in the Fund Clients, and make
withdrawals of any capital or assets from Sub-Accounts, generally on the first business day of each month. In most instances
Interactive Advisors will handle trading conducted for the purpose of eliminating a Sub-Account or reducing the allocation of
capital to a Sub-Account. Third-Party Sub-Advisors will be notified prior to the allocation of capital to their Sub-Accounts
and will handle trading conducted for the purpose of investing new capital in their Sub-Accounts.
General Risks Associated with Investments in Any Portfolios Offered by Interactive Advisors
All investment activities, including investments with Interactive Advisors, include a risk of loss that clients should be prepared
to bear. Interactive Advisors cannot guarantee any level of performance or that any client will avoid a loss of account assets.
Investment risks fall into the following categories. This listing of investment risks may not be all-inclusive, but should be
considered carefully by each client before deciding whether to invest with Interactive Advisors.
Market Risk: Security prices may decrease in response to direct and indirect events and market conditions, usually caused
by factors independent of the specific attributes of the investment security.
Inflation Risk: Rising inflation reduces the purchasing power of the underlying currency, which is the dollar for U.S. based
investments.
Liquidity Risk: Liquidity is the ability to convert an investment into cash. Investment assets are usually more liquid when
established markets exist to trade those securities. For instance, U.S. Treasury bills and most equity securities have highly
developed markets, while tangible property, such as real estate and precious stones, are less liquid. All portfolios make use of
fractional shares of stock. As stocks cannot be traded in fractions on public exchanges and fractional shares are typically
unrecognized and illiquid outside of the Interactive Advisors platform, if clients want to liquidate their investments in a
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portfolio, they will need to fully redeem their investment in which case IB LLC will sell any fractional shares to a liquidity
provider and any whole shares to the market. If clients want to transfer their holdings to another brokerage firm, they will first
need to sell their fractional shares to the liquidity provider through IB LLC and will incur commissions on all of these trades.
Additionally, high volatility and/or the lack of liquid markets for any security may prevent clients from selling their security
at all or at a favorable time or price because IB LLC has difficulty finding a buyer and may be forced to sell at a significant
discount to market value. Also, while Interactive Advisors values the securities held in client accounts based on data provided
by IB LLC (and obtained by IB LLC from third-party independent providers), that data may be stale or otherwise affected by
events impacting the security at issue. Interactive Advisors attempts to minimize some of this liquidity risk by blocking any
trades in both Manager and Interactive Advisors Portfolios in securities with a market capitalization of less than $50 million
or an average daily volume of less than $100,000.
Reinvestment Risk: This is the risk that future gains may be reinvested at less favorable (lower) rates of return than currently
available.
Interest-Rate Risk: Changes in interest rates may result in fluctuations in the prices of other investment vehicles. For example,
when interest rates rise, fixed income securities prices fall.
Currency Risk: Investments in non-U.S. based assets are subject to additional changes in valuation due to changes in currency
exchange rates.
Business Risk: This covers risks associated with specific industries or companies within an industry.
Financial Risk: Excessive use of credit (borrowing) to finance a business’ operations increases the risk of profitability,
because the company must cover its debt obligations in good and bad years.
Counterparty Risk: The risk to each party of a contract that the counterparty will not live up to its contractual obligations.
Cyber-Security Risk: Given Interactive Advisors’ reliance on the Internet to provide investment advice and conduct its
business, it is susceptible to operational, information security and other similar risks. Deliberate cyber attacks or cyber
incidents could lead a third-party to gaining unauthorized access to Interactive Advisors computer systems, misappropriating
Manager and client assets or sensitive information, corrupting data or causing operational disruptions.
Leverage Risk: Portfolio Managers cannot use borrowed funds or leverage to fund investments in their portfolios, i.e., trade
on margin. The Firm mitigates the risks and conflicts of using leverage or margin accounts in investing in its portfolios by
only allowing clients to invest with it through a no-borrowing-ability margin account, which is not allowed to borrow for
investment/leverage purposes but has the ability to use proceeds from stock and ETF sales immediately for new purchases
instead of waiting for the usual 2-day settlement period. A conflict of interest still arises as this account type’s use of margin
based on our management will result both in interest charges by IB LLC and a higher Fee payable to us based on the increased
gross market value of your Account. But we mitigate this conflict of interest by IB LLC generally not extending to our clients
any more margin that is deemed necessary to address free riding issues. The conflict cannot be completely eliminated because
these accounts could owe small amounts of margin interest to our affiliated broker-dealer IB LLC during the 2-day settlement
window.
Reliance on Information Provided by Clients and the Scope of the Risk Assessment Questionnaire: The investment
advice Interactive Advisors provides to clients is highly dependent on the accuracy of the information provided to Interactive
Advisors by its clients. If a client provides inaccurate information or fails to update outdated information, the quality and
relevance of Interactive Advisors’ investment advice could be materially affected. Interactive Advisors’ investment advice is
based on the risk assessment questionnaire it asks clients to fill out through its website and the answers and information clients
provide to Interactive Advisors in response to that questionnaire. There may be additional information or financial
circumstances not asked about in Interactive Advisors’ risk assessment questionnaire, that could inform, but is not taken into
account or reflected in Interactive Advisors’ investment advice. Clients may choose to contact another financial advisor to
discuss any such additional information or other financial circumstances that clients may think could be relevant to Interactive
Advisors’ investment advice. Interactive Advisors clients (or their advisors, if applicable) are responsible for advising
Interactive Advisors of any changes in their financial situation or investment objectives.
Reliance on Third-Party Data: Interactive Advisors’ investment advice is based on data and information from third-party
sources. While Interactive Advisors believes that the data it uses in its investment management processes is obtained from
reliable sources, it did not audit or validate this data, which may contain errors.
Reliance on Technology: Interactive Advisors’ investment activities depend on various computer and telecommunications
technologies, some provided by or dependent upon third parties, such as data feed, data center, telecommunications or utility
providers. Interactive Advisors’ services to its clients could be severely compromised by system and/or telecommunications
failures, power loss, unauthorized system access or use, computer viruses, fire or water damage, human errors in using certain
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systems, or other events or circumstances. Events that may interrupt computer or telecommunications systems could have a
material adverse effect on Interactive Advisors clients, including by preventing Interactive Advisors from trading, liquidating
or monitoring its clients’ investments. Interactive Advisors maintains back-up electronic books and records at a third-party
disaster recovery site. In case of interruption of its computer and/or telecommunications systems, Interactive Advisors will
strive to resume service to its clients promptly, barring any circumstances outside of its control.
Performance Drift Risk: This is the risk that the performance of any portfolio you invest in and the performance of your
account diverge, due to the following factors, among others:
● The Portfolio Manager’s compliance with the trading rules: For the protection of clients, trades that a Portfolio
Manager makes that are outside of the Interactive Advisors trading rules are not replicated in client accounts.
● Your risk score and exclusions: Your risk score and any restrictions you placed on buying or selling certain
securities or tickers could result in certain trades executed by the Portfolio Manager or Interactive Advisors not being
replicated in your account.
● Your cash flow behavior: Performance drift will result if you frequently invest additional cash or partially redeem
your investment.
●
Inability to mirror in exact proportion: Depending on the size of your investment relative to the Portfolio
Manager’s, translating each trade the Portfolio Manager makes into whole shares in your account can lead to small
rounding differences, and therefore slightly different allocations.
● The broker’s availability of stock to lend: When shorting, the stock must first be borrowed. The broker may not
have the exact amount of stock available to fulfill all that is requested.
Depending on the specific circumstances, performance drift can be to your disadvantage or to your benefit.
Model Risk: Some strategies include the use of various proprietary quantitative or investment models. Investments selected
using models may perform differently than expected as a result of changes from the factors’ historical – and predicted future
trends, and technical issues in the implementation of the models, including, for example, issues with data feeds. Moreover,
the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the
behavior of other market participants. A model’s return mapping is based partially on historical data regarding particular
economic factors and securities prices. The operation of a model, similar to other fundamental, active investment processes,
may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-
forma. For a model driven investment process – and again similar to other, fundamental and active investment processes, there
is no guarantee that the use of models will result in effective investment outcomes for clients.
Risks of Monte Carlo Simulation: For the Goal Tracker tool projections, we use Monte Carlo simulation to generate financial
and/or retirement goal projection forecasts and in connection with investment decisions. Monte Carlo simulation is a statistical
modeling technique that charts the probability of discrete financial outcomes at certain times in the future. The outcomes
presented using Monte Carlo simulation represent only a few of the many possible outcomes, will vary over time, and are not
guarantees of investment returns. Moreover, since past investment performance and general market conditions may not
necessarily be repeated in the future, your financial and/or retirement goals may not be fulfilled by relying on investment
decisions that are based on Monte Carlo simulation results. Differences in account size, age, risk tolerance, transaction timing,
and prevailing market conditions at the time of investment may also lead to different results, and you may lose money.
Generally in Monte Carlo simulations, results are very sensitive to assumptions about expected return and risk and the base
assumptions used may be unrealistic, leading to unrealistic outcomes.
Cash Drag Risk: The allocation of cash within your portfolio has an impact on portfolio performance. Some of the portfolios
offered on the platform have high allocations to cash. As the allocation to cash in a portfolio increases, the volatility of the
entire portfolio is reduced. In times when invested assets are increasing in value, portfolios with increased amounts of cash
lead to returns which lag a fully invested portfolio. Alternatively, when invested assets are declining in value, portfolios with
an increased amount of cash lead to a less significant decline in the portfolio.
Pattern Day Trader Classification Risk: Depending on your account type, net asset value, and trading activity, your account
may be classified as a Pattern Day Trader account by IB LLC, which will result in restrictions being placed on your account
for a period of time. A day trade is defined as a purchase and sale of a security (US and Non-US) within the same trading day.
The FINRA and NYSE instituted regulations intended to limit the amount of trading that can be done in accounts with small
amounts of capital, specifically accounts with less than 25,000 USD Net Liquidation Value. A Pattern Day Trader is someone
who effects 4 or more day trades within a 5 business day period.
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Risks Specific to Investments in Portfolios Made up of ETFs
1. Market Risk
ETFs are typically designed to track the performance of certain indices, market sectors, or groups of assets such as
stocks, bonds, or commodities. ETF managers may use different strategies to achieve this goal, but, in general, they
do not have the discretion to take defensive positions in declining markets. Investors must be prepared to bear the
risk of loss and volatility associated with the underlying index/assets.
2. Tracking Errors
Tracking errors refer to the disparity in performance between an ETF and its underlying index or its assets. Tracking
errors can arise due to factors such as the impact of transaction fees and expenses incurred by the ETF, changes in
the composition of the underlying index/assets, and the ETF manager’s replication strategy. The most common
replication strategies include: i) full replication, ii) representative sampling and iii) synthetic replication, which are
discussed in more detail below.
3. Trading at a Discount or Premium
An ETF may be traded at a discount or premium to its Net Asset Value (NAV). This price discrepancy is caused by
supply and demand factors, and may be particularly likely to emerge during periods of high market volatility and
uncertainty. This occurrence may also be observed for ETFs tracking specific markets or sectors that are subject to
direct investment restrictions.
4. Foreign Exchange Risk
Investors trading ETFs with underlying assets not denominated in U.S. dollars are also exposed to exchange rate risk.
Currency rate fluctuations can adversely affect the underlying asset value, also affecting the ETF price.
5. Liquidity Risk
Market Makers (MMs) are exchange members that provide liquidity to facilitate trading in ETFs. Although most
ETFs are supported by one or more MMs, there is no assurance that active trading will be maintained. In the event
that the MMs default or cease to fulfill their role, investors may not be able to buy or sell the product. Interactive
Advisors attempts to reduce this risk by selecting ETFs with more liquidity for portfolios whose composition its
Investment Management Team is responsible for determining.
6. Counterparty Risk Involved in ETFs with Different Replication Strategies
a. Full replication and representative sampling strategies:
An ETF using a full replication strategy generally aims to invest in all constituent stocks or assets in the
same weightings as its benchmark. ETFs adopting a representative sampling strategy will invest in some,
but not all of the relevant constituent stocks or assets. For ETFs that invest directly in the underlying assets
rather than through derivative instruments issued by third parties, counterparty risk tends to be less of a
concern.
b. Replication
strategies
using
swaps
and
other
derivatives
(i.e.,
synthetic
replication):
ETFs may utilize swaps or other derivative instruments to gain exposure to a benchmark. Currently,
replication ETFs can be further categorized into two classes:
● ETFs utilizing swaps: Total return swaps allow ETF managers to replicate the benchmark
performance of ETFs without purchasing some or all the underlying assets. ETFs utilizing swaps
are exposed to counterparty risk of the swap dealers and may suffer losses if such dealers default
or fail to honor their contractual commitments.
● ETFs utilizing derivatives: ETF managers may also use other derivative instruments to replicate
the economic benefit of the relevant benchmark. The derivative instruments may be issued by one
or multiple issuers. ETFs utilizing derivatives are subject to the counterparty risk of the derivative
instruments’ issuers and may suffer losses, if such issuers default or fail to honor their contractual
commitments.
Even where collateral is obtained by an ETF, it is subject to the collateral provider fulfilling its obligations.
There is a further risk that, when the right against the collateral is exercised, the market value of the collateral
could be substantially less than the amount secured resulting in significant loss to the ETF.
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Risks Specific to Investments in the Interactive Advisors Portfolios
Investments in the Interactive Advisors Portfolios (e.g., Smart Beta, Asset Allocation, Index Tracking, WisdomTree ETF
Portfolios, SSGA ETF Portfolios, and Socially Responsible Investing Portfolios, etc.) are subject to the risks discussed here
and the separate Risk Disclosures for each portfolio line available on the Forms and Agreements page of the Interactive
Advisors website (https://interactiveadvisors.com; https://interactiveadvisors.com/forms-and-agreements) (which clients are
required to acknowledge before being allowed to invest in any of these portfolios), any of which may adversely affect the
Portfolios’ yield, total return, and ability to meet their investment objectives. This discussion of the risks associated with
investments in the Interactive Advisors Portfolios is a summary of the discussion of risks in the separate portfolio-line-
specific risk disclosures, and clients are prompted to consult the “Disclosures for Investments in Specific Portfolio
Lines” for a fuller risk discussion at this location: https://interactiveadvisors.com/forms-and-agreements
As with any investment, there are a number of risks associated with investing in an Interactive Advisors Portfolio. These
include the following:
● You may lose all or part of your investment in the Portfolios, your investment may not perform as well as other
investments, or your investment may fluctuate significantly due to short-term or long-term market movements;
● There is no assurance that these Portfolios and strategies will meet their investment objectives, work as intended, or
perform as well as other investment strategies; and
● These Portfolios may not be suitable for all investors.
Sector and concentration risks: A portfolio may carry higher risk to the extent it is significantly composed of assets in a
particular sector, issuer, group of issuers, country, group of countries, region, market, industry, or asset class. For the portfolios
it constructs in-house (e.g., Smart Beta and Asset Allocation) Interactive Advisors generally attempts to avoid excessive
concentration in individual sectors of the market, but may not be successful.
Regulatory risk: The Portfolios are subject to the risk that a change in US law and related regulations will impact the way
Interactive Advisors manages these portfolios, increase the particular costs of their operation and/or change the competitive
landscape. This may result in Interactive Advisors deciding to cease offering these Portfolios.
Conflict of interest risks and disclosures: As explained above, Interactive Advisors trades its own funds alongside the assets
of the clients who invest in the Interactive Advisors Portfolios in order to effectuate its trade mirroring procedures. To avoid
the potential for front-running, orders in Interactive Advisors-owned accounts are combined with orders in client accounts and
submitted for execution to IB LLC in one or multiple trades. Executions are then allocated pro rata with participating accounts
receiving the same average price per share and sharing transactions costs pro rata. These safeguards are described in the
Investment Management Agreement that clients sign before investing with Interactive Advisors and are intended to ensure
Interactive Advisors adheres to its fiduciary duty to clients, and avoids or mitigates any conflicts of interest.
Risks associated with owning and trading fractional shares and related agency cross trades: Interactive Advisors is able
to offer the Interactive Advisors Portfolios and the extensive diversification they are designed to achieve for even relatively
small investments, by offering Interactive Advisors clients the ability to trade fractional shares of the ETFs and stocks that the
portfolios invest in. You will receive payments or value commensurate with your fractional ownership in the case of stock
dividends, stock splits, mergers, or other mandatory corporate actions (including cash dividends). Please refer to Item 11,
Fractional Share Transactions, for more information.
These portfolios may become unavailable for investment: Any of the Interactive Advisors Portfolios may become
unavailable for investment at any point in the future either because the Firm decides to close one of these portfolios or because
a third-party data provider decides to terminate the governing licensing agreement with the Firm or to cease providing the data
needed to manage the portfolio. Interactive Advisors will notify all affected clients of any such portfolio closure as soon as
possible to allow them to identify suitable alternative investments on the Interactive Advisors platform or elsewhere. You
should bear these contractual limitations in mind when deciding whether to invest in one of these portfolios, which may
become unavailable for investment in the future.
Not a bank deposit: Your investment in any of the Interactive Advisors Portfolios is not a deposit in a bank and is not insured
or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.
Smart Beta Portfolio-specific risks - Due to its composition, each Smart Beta Portfolio carries additional, specific risks,
which may lead it to lose or gain money out of proportion with the stock market as a whole.
● Value securities risk - Stocks in the Value Portfolio, perceived by Interactive Advisors as undervalued, may fail to
appreciate for long periods of time, may never realize their full potential value, or may underperform other segments
of the market or the market as a whole.
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● Quality securities risk - Companies issuing the stocks included in the Quality Portfolio may experience lower than
expected returns, even negative growth, as well as increased leverage.
● Growth securities risk - There is no guarantee that the past performance of the stocks in the Growth Portfolio will
continue. These stocks typically trade at higher multiples of current earnings than other securities and, therefore, may
be more sensitive to changes in current or expected earnings than other equity securities and may be more volatile.
● High-dividend securities risk - There is no guarantee that the large-capitalization companies issuing the stocks in
the Dividend Portfolio will declare dividends in the future or that, if the dividends are declared, they will remain at
current levels or increase over time.
● Equal weighting risk - Due to the Broad Market Portfolio’s use of half equal weighting and the resulting higher
proportion of small- and medium-capitalization company stocks, this portfolio may underperform other segments of
the market or the market as a whole.
● Small-capitalization company risk - Small-cap versions of the Smart Beta Portfolios are invested solely in small-
capitalization company stocks. Small-capitalization company stocks have historically been riskier than large and
medium-capitalization company stocks. Securities of small-capitalization companies generally trade in lower
volumes, are often more vulnerable to market volatility, get less analyst coverage, and are subject to greater and more
unpredictable price changes than other stocks or the stock market as a whole.
● ESG (Environment, Social and Governance) investment strategy risk - Five of the Smart Beta portfolio, the ESG
Broad Market Portfolio, ESG Growth Portfolio , ESG Value Portfolio , ESG Quality Portfolio, and ESG
Dividend Portfolio, use an ESG investment strategy, which limits the types and number of investment opportunities
available to these portfolios and could underperform portfolios without an ESG focus, be they the Smart Beta Broad
Market Portfolio, other Smart Beta portfolios, or other portfolios on the Interactive Advisors platform or elsewhere.
The ESG investment strategy of these portfolios could result in the portfolios investing in securities, industries or
sectors that underperform the market as a whole, foregoing opportunities to invest in securities, industries or sectors
that might otherwise be advantageous to invest in, and underperforming other portfolios or investments screened for
different ESG standards. Interactive Advisors could also be unsuccessful in creating a portfolio composed of
companies that exhibit positive or favorable ESG characteristics. The performance of these portfolios is compared
against a broad market investable ETF benchmark without an ESG focus, which limits the comparability of the
portfolio returns to the benchmark’s performance.
Tax burden implications of Smart Beta Portfolio investments: Given the high volume of trading in the Smart Beta
Portfolios due to their composition, quarterly rebalancing trades, and recurring investments, clients will also be responsible
for reporting large amounts of stock sales in their tax forms (e.g., IRS Form 8949, Sales and Other Dispositions of Capital
Assets). This tax-filing burden is increased for the Broad Market Portfolios, each made up of 1,000 stocks. Interactive Advisors
is not qualified to and cannot provide any tax advice or prepare any tax documents for clients. Clients will need to consult an
accountant or tax attorney to determine the tax-filing burden of investing in these portfolios. Please note that IB LLC provides
certain tools to assist clients with their tax filings, but these tools may only be able to support a limited number of trades.
Interest rate risk associated with bond ETFs: Some of the Interactive Advisors Portfolios (e.g., Asset Allocation,
WisdomTree and SSGA ETF Portfolios) invest in bond or fixed income ETFs, which are exposed to interest rate risk (i.e., the
risk that underlying bond prices will decline because of rising interest rates). An increase in interest rates may cause the value
of bond or fixed-income ETFs held by the portfolios to decline, which could lead to heightened volatility in the fixed-income
markets, and adversely affect the liquidity of fixed-income ETFs. The current historically low interest rate environment
exacerbates the risks associated with rising interest rates.
Credit risk associated with corporate bond ETFs: Some of the Interactive Advisors Portfolios invest in corporate bond
ETFs, which are exposed to the risk that the corporations issuing the debt or other counterparties may be unable or unwilling
to make timely interest and/or principal payments when due or honor any of their other obligations. This could negatively
affect the debt issuer’s credit rating or the market’s perception of that debt issuer’s ability to make payments, which could in
turn negatively affect the value of these portfolios’ investments in the corporate ETFs. The degree of credit risk associated
with the corporate bond ETFs depends on the financial condition of the issuers of the underlying instruments and the terms of
the underlying bonds the ETFs invest in.
Tax and other risks associated with municipal bond ETFs: The Asset Allocation Portfolio may invest in municipal bond
ETFs, which are exposed to the risk that all or a portion of the tax-exempt income from municipal bonds held will be declared
taxable, potentially retroactively, due to changes in tax laws or adverse interpretations by the Internal Revenue Service or state
or local tax authorities. Municipal bonds could also be adversely affected by changes in the rights of municipal bond holders,
including those in connection with the insolvency of the issuing municipality. Municipal bonds used to finance and backed by
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current or anticipated revenues from a specific project or asset could be adversely affected by the inability to collect revenues
from that project or asset.
Real estate investment risk and tax consequences for investments in the Russell 1000 Real Estate Managed Portfolio:
This portfolio invests in companies such as real estate investment trusts (“REITs”) or real estate holding companies, which
exposes investing clients to the risks of owning real estate directly, as well as to risks that relate specifically to the way in
which real estate companies are organized and operated. Real estate is highly sensitive to general and local economic
conditions and developments, and real estate companies, including REITs, use leverage, which increases investment risk and
could exacerbate this portfolio’s losses. Clients interested in this portfolio should consult with their accountant or tax attorney
on the tax consequences of investing in this portfolio, as dividend payments made out by REITs held in this portfolio could
be taxed as ordinary income at the top marginal tax rate. Interactive Advisors does not provide tax advice and does not in any
way represent that investing in this portfolio will result in any particular tax consequences.
Sector and concentration risks associated with investments in the Index Tracking Portfolios: A portfolio may carry
higher risk to the extent it is significantly composed of assets in a particular sector, issuer, group of issuers, country, group of
countries, region, market, industry, or asset class. Many of the Index Tracking Portfolios track indices focused on a specific
industry or sector and are thus more affected by the risks associated with that specific industry or sector.
ESG (Environmental, Social and Governance) investment strategy risk associated with investments in the ESG Asset
Allocation Portfolio - The Asset Allocation Portfolio allows the use of an ESG investment strategy, which limits the types
and number of investment opportunities available to this portfolio and could underperform an asset allocation portfolio without
an ESG focus, offered on the Interactive Advisors platform or elsewhere. The portfolio’s ESG investment strategy could result
in these portfolios investing in ETFs focused on securities, industries or sectors that underperform the market as a whole,
foregoing opportunities to invest in securities, industries or sectors that might otherwise be advantageous to invest in, and
underperforming other portfolios or investments screened for different ESG standards. Also, Interactive Advisors could be
unsuccessful in creating portfolios investing in ETFs made up of companies that exhibit positive or favorable ESG
characteristics, and the ETF manager (or the provider of the index the ETF seeks to track) may not succeed in selecting issuers
that exhibit positive or favorable ESG characteristics. Additionally, the ESG-focused ETFs the Asset Allocation portfolio
invests in have been launched relatively recently (2016-2018), have short performance histories and may not be successful in
implementing an ESG investment strategy. The performance of the ESG-focused Asset Allocation portfolio is expected to be
similar to that of the non-ESG Asset Allocation portfolio, but Interactive Advisors does not claim and cannot guarantee that
this will be the case in the future, given the limited performance history available for the ESG-focused ETFs the portfolio
invests in and the fact that past performance is no guarantee of future results. The expense ratios associated with the ESG-
focused ETFs are higher than those associated with their non-ESG ETF counterparts.
Socially Responsible Investing Portfolio-Specific Risks - The Socially Responsible Investing Portfolios carry additional,
specific risks, which may lead them to lose or gain money out of proportion with the stock market as a whole.
● Less diversification - By definition, Socially Responsible Investing Portfolios are less diversified than comparable
broad market portfolios because they are constructed to exclude investments in certain companies or industries, which
could lead to these portfolios being more or less volatile than a broader market portfolio.
● Equal weighting risk - Due to the use of half equal weighting in some portfolios like the Clean Technology Portfolio,
ESG Broad Market Portfolio, Clean Energy Portfolio, Low Greenhouse Emissions Portfolio, Fair Labor Portfolio
and Workforce Diversity Portfolio and the resulting higher proportion of medium-capitalization company stocks,
these portfolios may underperform other segments of the market or the market as a whole.
● ESG (Environment, Social and Governance) investment strategy risk - The Socially Responsible Investing
Portfolios use an ESG investment strategy, which limits the types and number of investment opportunities available
to these portfolios and could lead the portfolios to underperform other portfolios without an ESG focus, whether they
are other portfolios on the Interactive Advisors platform or elsewhere. The ESG investment strategy could result in
these portfolios investing in securities, industries or sectors that underperform the market as a whole, foregoing
opportunities to invest in securities, industries or sectors that might otherwise be advantageous to invest in, and
underperforming other portfolios or investments screened for different ESG standards. Interactive Advisors could
also be unsuccessful in creating portfolios composed of companies that exhibit positive or favorable ESG
characteristics. The performance of these portfolios is compared against a broad market investable ETF benchmark
without an ESG focus, which limits the comparability of the portfolio returns to the benchmark’s performance.
Basically, the application of socially responsible investment criteria may affect clients’ exposure to certain sectors or
types of investments and may impact the clients’ relative investment performance – positively or negatively –
depending on whether such sectors or investments are in or out of favor in the market.
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● Reduction not elimination of investments in companies investors may consider undesirable - The construction
of the Socially Responsible Investing Portfolios reduces but does not eliminate exposure to companies that investors
interested in socially responsible investing may consider to be undesirable.
● Subjective and qualitative nature of socially responsible investing and data limitation - Socially Responsible
Investing is qualitative and subjective by nature, and there is no guarantee that the criteria utilized, or judgment
exercised, by Interactive Advisors will reflect the beliefs or values of any one particular investor. Information
regarding the Socially Responsible Investing practices of companies these portfolios invest is obtained through
voluntary or third-party reporting, which may not be accurate or complete, and Interactive Advisors is dependent on
this information to determine the inclusion of a company in a portfolio (based on its commitment to, or
implementation of, socially responsible practices). Socially responsible norms also differ by region. And there is no
assurance that the socially responsible investing criteria employed will be successful. There is no guarantee that these
portfolios will produce returns similar to traditional investments.
● New portfolio risk - Interactive Advisors started trading the Socially Responsible Investing Portfolios in July 2020.
Therefore, these portfolios have no operating or actual performance history before July 2020. Clients investing in
these portfolios also bear the risk that Interactive Advisors may not be successful in implementing its investment
strategy.
Risks and Limitations Associated with the Client-Customized Asset Allocation Functionality
Clients interested in using our custom Asset Allocation Portfolio feature are asked to carefully read this disclosure (which they
also receive at the time of investing in the Asset Allocation Portfolio as part of this larger disclosure document, Disclosure for
Investments in Specific Portfolio Lines available here: https://interactiveadvisors.com/forms-and-agreements, and consider
their personal circumstances before deciding whether to use our custom Asset Allocation Portfolio feature.
As with all in-house portfolios Interactive Advisors offers, we have and retain the discretion to choose which specific ETFs
to purchase or sell and the timing of the trade. We also reserve the right to initially select and subsequently change the available
industry sectors and the specific ETFs corresponding to each industry sector. All specific ETFs used in a custom Asset
Allocation Portfolio are subject to change at our discretion based on our evaluation of liquidity, cost of ownership (i.e., expense
ratio associated with the ETF) and coverage (i.e., adequate exposure to the specific sub-asset class/industry tilt the ETF seeks
to represent) without notice to you. The standard Asset Allocation Portfolio is designed at each risk tolerance level to deliver
well-diversified portfolios that seek to maximize risk-adjusted returns. If you customize your Asset Allocation Portfolio, you
may alter the investment characteristics of the portfolio, including the expected return, risk, diversification and tax efficiency
of the portfolio. The allocation you select is your ultimate responsibility and the performance of your customized Asset
Allocation Portfolio may be worse or better than the performance of our recommended standard Asset Allocation Portfolio.
Additionally, your selection and allocation of ETFs in your custom Asset Allocation Portfolio may result in higher costs to
you than you would incur in our standard Asset Allocation Portfolio for your risk score.
We execute securities transactions to implement your customization instructions on the same trading day if they are received
by Interactive Brokers before 3:55 p.m. EST, or at the next market open if they are received after 3:55 p.m. EST. We will
rebalance your custom Asset Allocation Portfolio quarterly and at any other time you change your allocation instructions or
add or withdraw assets from your account. For quarterly rebalancings, we will aggregate buy and sell orders in specific ETFs
before sending orders to market and allocate executions among accounts at the average price.
We reserve the right to modify the customized Asset Allocation Portfolio feature, including by changing or limiting the
availability or weighting of certain investments or groups of investments if we determine such action to be in clients’ best
interests.
The same annual management fee (0.20%) applies to client investments in the standard and client-customized versions of the
Asset Allocation Portfolio.
Risks and Limitations Associated with Enabling the Tax Loss Harvesting Functionality for Asset Allocation Portfolio
Investments
Interactive Advisors does not represent that investing in the Asset Allocation Portfolio or using the TLH functionality will
achieve any particular investment or tax result. TLH does not constitute tax advice and Interactive Advisors assumes no
responsibility for the tax consequences of any TLH-related transaction, to any client. Clients should consult their personal tax
advisors regarding the tax consequences of investing in the Asset Allocation Portfolio, the effects of using TLH, whether the
transactions in non-Interactive Advisors accounts trigger wash sale restrictions, and the requirements for making appropriate
reports and filings with the IRS or any other taxation authority. The tax consequences of using a tax loss harvesting strategy
generally and TLH specifically are complex and uncertain and may be challenged by the IRS or any other tax
Informational Brochure - February 3, 2026
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authority. In case of an inquiry or proceeding by the IRS or any other tax authority, Interactive Advisors will not become a
party to that inquiry or proceeding on your behalf. The information with regard to TLH was not prepared to be used, and
cannot be used, by any investor to avoid penalties or interest. For additional information on claiming tax losses on your tax
filings, review the IRS instructions on Schedule D (Form 1040) Capital Gains and Losses or IRS Publication 550. Tax loss
information associated with your use of TLH can be located on your logged-in client dashboard. Our affiliated broker IB LLC
will provide you with a Form 1099 to be filed with your tax return.
TLH is generally valuable for investors with taxable accounts (as tax-advantaged accounts like traditional or Roth IRA
accounts are already tax-free or tax-deferred) who have a long-term investment horizon (as it works through tax deferral not
tax avoidance and thus it is less beneficial over a short investment horizon). Often TLH is most effective for investors who
harvest losses for use against high-rate income (i.e., short term capital gains) and convert future realized gains to long-term
capital gains subject to the preferentially lower rate.
The benefits of TLH and the net investment losses available for harvesting will depend on each client’s particular
circumstances, including but not limited to: income, state of residence, purchases and sales of assets in the client and spouse’s
accounts outside of Interactive Advisors, type of account and holding periods. Tax loss harvesting generally and the use of
our TLH functionality may not be appropriate or beneficial for all investors. Investors: (a) without taxable accounts;
(b) in relatively low income tax brackets; (c) expecting higher future tax rates; (d) planning to withdraw a large portion
of their investments within a year; and/or (e) trading any of the ETFs in their Asset Allocation Portfolio investments
in non-Interactive Advisors accounts, including joint accounts, likely to trigger the wash sale rule, will generally benefit
the least from using TLH.
The value added from TLH will depend on a variety of factors, including but not limited to:
A. Current tax rate versus future tax rate: Avoiding paying capital gains tax by offsetting the gains with harvested
losses does not mean that you never need to write a check to the IRS. By harvesting losses now, you are simply
deferring when you write the check to the IRS. If your future tax rate for long- and short-term gains is lower than
your current rates, you benefit by writing the check later, because that tax bill will be calculated using lower rates.
Thus, the greater the differential between current and future tax rates, the higher your benefit from TLH. If future tax
rates are higher than the current ones, delaying payment by opting to use TLH will work to your disadvantage.
B. Expected return of investment portfolio: The losses that TLH can harvest are highly dependent on the performance
of the positions within your Asset Allocation Portfolio investment and general market conditions. In certain years,
there will be large losses to harvest while in others very few.
C. Investment horizon: The longer you hold onto your investments, the higher the likely benefit of using TLH.
D. Volatility of underlying holdings: Because TLH involves selling investments that have declined in value, generally
portfolios with a greater proportion of riskier securities with higher volatility and greater price fluctuations present
more opportunities for tax-loss harvesting.
E. Tracking error of replacement ETF: After selling an ETF to harvest losses, TLH automatically invests the cash
proceeds from the sale in a replacement ETF with a high historical correlation with the original ETF. The
performance of the replacement ETF could be worse or better than that of the original ETF. We do not represent
and cannot guarantee that the replacement ETFs will ultimately perform the same or similar to the ETFs
being replaced despite their similar expected risk and return characteristics.
F. Availability of realized gains to offset realized harvested losses: Tax losses TLH harvests can be applied to offset
both capital gains and up to $3,000 in ordinary income annually. Losses that cannot be applied in a given tax year
can be carried over indefinitely to offset future income and capital gains. The benefits of TLH are higher when the
offset happens earlier rather than later, and when the offset is applied to short-term gains or income rather than to
long-term gains.
G. Trading securities substantially identical to those in your Asset Allocation Portfolio investments in other
accounts or in the same account invested in non-Asset Allocation Portfolio managed by Interactive Advisors,
could trigger the wash sale rule. If you buy the same or a substantially identical security within 30 days before or
after the sale of such securities in any account (including other Interactive Advisors accounts, brokerage accounts at
our affiliated broker-dealer IB LLC or investment accounts with other institutions), then the IRS does not allow
capital losses from such sales to offset capital gains due to the “wash sale” rule. A wash sale does not completely
eliminate the benefits of TLH but reduces that benefit by the amount of the wash sale itself. The wash sale rule applies
across all of your accounts, including your non-taxable retirement accounts, no matter where they are held. Trading
activity in any of IA’s non-Asset Allocation portfolio (even if in the same account where the Asset Allocation
Portfolio investments are held) can also result in negating our TLH algorithms, and triggering wash sale rules.
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Interactive Advisors does not monitor transactions in clients’ non-Interactive Advisors accounts, whether held at IB
LLC or elsewhere. Clients are thus responsible for ensuring they identify and properly handle wash sales resulting
from trading in their (and their spouse’s) non-Interactive Advisors accounts. For more information on the wash sale rule
and other tax-loss harvesting-related issues, please review IRS Publication 550 and the Interactive Brokers website.
Higher turnover as a result of TLH
TLH results in increased trading in the accounts of clients who activate the functionality. Such increased trading could
result in increased trading expenses, executions at less favorable prices, less favorable tax treatment of some dividends,
portfolio drift, and increased risk of trading errors.
functionality
for
their
Allocation
Portfolio
All Clients receive this disclosure document (which contains the above discussion of risks) at the time they decide to turn on
this
investments:
Asset
https://cdn.interactiveadvisors.com/22110402/documents/clients/tax-loss-harvesting-disclosure-07-sep-2022.pdf
Assumptions, limitations and risks associated with the Goal Tracker software tool
The long-term return estimates used by the Goal Tracker tool are estimates intended to provide a general guideline for the
potential returns of a client’s investment with Interactive Advisors. The projections or other information generated by the
long-term return estimates regarding the likelihood of various investment outcomes are hypothetical in nature, do not reflect
actual investment results or the realized returns of any of our portfolios, your account or the account of any other Interactive
Advisors client, are not guarantees of future results, and are provided for informational, educational and illustrative purposes
only. Hypothetical projected portfolio returns assume reinvestment of interest and dividends and do not include taxes or
inflation adjustments. Hypothetical projected portfolio values could differ significantly from the actual performance of
any of our portfolios. As such your likelihood of achieving your goals portrayed by the tool may be overstated and
unrealistic. Actual results in an Interactive Advisors client account investing in any Interactive Advisors portfolio could differ
significantly from these hypothetical results depending on factors such as: broad stock market performance, factor returns,
available liquidity, interest rates, economic growth, transaction costs, and other market factors.
There is no guarantee that clients will reach the goal specified in the tool and assumptions not used in this tool and other
market developments can affect the probability of reaching your goal(s). Interactive Advisors does not make any representation
that any client will or is likely to achieve results similar to these by investing in any portfolios on the Interactive Advisors
platform. The tool’s estimates and projections can vary with each use and over time. The estimates and projections generated
using the Goal Tracker tool are provided for informational, educational and illustrative purposes and are not intended to
constitute and should not be relied on as a full financial plan, comprehensive financial planning, legal or tax advice. Clients
should consult a qualified financial planner, tax advisor, CPA or lawyer to obtain such advice. Interactive Advisors does not
in any way represent that the estimates generated using this tool are based on or meant to replace a comprehensive evaluation
of a client’s entire personal portfolio. Through this tool or otherwise, Interactive Advisors does not provide tax advice. There
may be more tax-advantageous account types to achieve the stated goals, but this tool does not take that into account. None of
the tool’s projections should be construed as an offer, recommendation or solicitation to buy or sell any security. The main
assumptions, limitations and risks associated with the Goal Tracker software tool are discussed in this white paper on our
website (https://interactiveadvisors.com/learn-more/goal-tracker) and on the web page logged-in clients review when deciding
whether to use this tool.
Risks Specific to Investments in the Fund Clients
The risks specific to investments in the Fund Clients are disclosed in each Fund’s private placement memorandum. Because
the Fund Clients operate by allocating capital to Third Party Sub-Advisors, the risks present depend on each Sub-Advisor’s
investment strategy and the instruments that each Sub-Advisor utilizes to implement its strategy. All investments in the Fund
Clients are subject to risks specific to the particular investment strategies utilized. They are also subject to risks relating to
market conditions generally, as well as risks particular to the various types of instruments utilized by Each Sub-Advisor. Such
instruments include, but are not limited to: equities; commodities; debt securities; futures; options; other derivatives; and
ETFs. Additionally, Sub-Advisors may invest in non-US instruments that may carry risks unique to the jurisdictions in which
they are traded. Investors in the Fund Clients must review the private placement memorandum and accept the risks disclosed
there.
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Other Considerations for Clients Investing in Interactive Advisors Portfolios
Investment Advice
At this time Interactive Advisors offers investment advice by allowing clients to invest in Portfolios generally trading any or
a combination of the following: equity securities traded on U.S. exchanges, ETFs, and REITs.
Clients are advised that:
1.
Interactive Advisors’ investment advice consists of facilitating clients’ ability to select Manager or Interactive
Advisors Portfolios through its risk scoring system and guidance provided upon request by Interactive Advisors’
client service representatives. In the case of Asset Allocation Portfolio, after it assigns to clients risk scores based on
their answers to the risk assessment questionnaire, Interactive Advisors recommends to clients a specific Asset
Allocation portfolio, which clients may then choose to invest in or not. The Asset Allocation Portfolio is the only one
Interactive Advisors recommends to clients.
2.
(posted
in
the
Forms
and Agreements
page
at
Interactive Advisors may modify recommendations that are implied by the trading data provided by the Manager and
Manager Content in certain circumstances. For example, some securities transactions may not be executed under
Interactive Advisors’ Trading Rules laid out in the Portfolio Manager Trading Rules on the Interactive Advisors
website
https://interactiveadvisors.com;
https://interactiveadvisors.com/forms-and-agreements). This is discussed in more detail in Item 4 above.
3. Once a client selects a Manager Portfolio or an Interactive Advisors Portfolio to invest in, the client may not alter the
Portfolio or the trades in his account that is invested in that Portfolio strategy, except by restricting the trading of
specific tickers or securities in his account or using any of the ESG exclusion lists we offer for client selection. clients
can terminate their investment in a Portfolio at any time and invest in another Portfolio available on the Interactive
Advisors platform or choose not to invest in any Portfolio. Interactive Advisors does not charge management fees on
any funds held in client accounts that are not invested in any portfolios on its platform.
4. Any securities transferred to the Custodian to fund an account are solely for liquidation and subsequent investment
in a Manager Portfolio or Portfolios. Interactive Advisors does not issue recommendations on the further disposition
of transferred securities.
Trading Restrictions
1.
In managing client assets, Interactive Advisors retains discretion over the trading based on certain trading limitations.
Trading limitations include the following:
● Minimum thresholds for market capitalization to ensure portfolio trades occur in liquid securities;
● The size of a client’s account may not make it practical to allocate shares for certain trades initiated by a
Manager; and
● A Client may have specified certain ticker or security trading restrictions or restrictions based on predefined
ESG exclusion lists for investments in his account.
2. The concept of Interactive Advisors is to allow investors (i.e., clients) to replicate Manager or Interactive Advisors
trade data. This naturally leads to a significant conflict of interest as the Managers, and if the Manager is an entity,
its respective officers, directors, employees, and/or affiliates, will send a trade for execution ahead of clients. It is
therefore important to note the following:
i.
It is illegal for anyone to manipulate the market for securities.
ii.
Managers represent to Interactive Advisors that neither they nor their affiliates or employees trade
in securities in which they possess any material nonpublic information or use their knowledge of
the timing of the release of their trade data or the fact that the release of that trade data will prompt
trades in Interactive Advisors client accounts to trade ahead of Interactive Advisors clients or to
otherwise improve their position in the ownership of securities or futures or move the price of any
securities or futures.
iii. To eliminate the time lag between any Manager or Interactive Advisors trades and the
replication of these trades into client accounts and any incentives and conflicts of interest
presented by such time lag, Interactive Advisors has established procedures to mitigate the
risk of a Manager trading ahead of clients. This includes combining the orders for the sale or
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purchase of a security by a Manager (or Interactive Advisors) with those of clients investing
in that Manager or Interactive Advisors Portfolio in a single trade or allocating the combined
trades between Manager or Interactive Advisors and client accounts on a pro rata basis (a
process referred to as “co-trading”).
iv. Managers agreed to not buy or sell securities in any of their proprietary or personal accounts using
the strategy in the Interactive Advisors-linked account before buying or selling those same
securities in their Interactive Advisors-linked account.
v.
Interactive Advisors will randomly check managers’ trading in accounts following the same
strategy as their Interactive Advisors-linked account to detect any instances of trading ahead and/or
any indication of improper trading practices.
vi. Portfolio Managers may themselves be SEC- or state-registered investment advisers, or hedge fund
managers exempt from registration. Regardless of registration status, we expect Managers to
exercise a reasonable level of care, diligence, and skill. All Portfolio Managers must agree to report,
monitor, and review under their own Code of Ethics provisions trades in the IB account that is
mirrored through the Interactive Advisors platform. Portfolio Managers must also provide
Interactive Advisors with an annual certification that they are not aware of any instances of front-
running in connection with trades placed at Interactive Advisors through their Code of Ethics
reviews or otherwise. Portfolio Managers agree to promptly notify Interactive Advisors in writing
of any instances of front-running of trades placed at Interactive Advisors. Non-Registered Portfolio
Managers (generally exempt hedge fund managers) will be subject to a limited version of
Interactive Advisors’ Code of Ethics and will be required to report their personal trading activity
to Interactive Advisors. At this time, there are no unregistered Portfolio Managers on the
Interactive Advisors platform.
Use of Margin
Since the spring of 2019, to prevent free-riding violations and mitigate the above conflicts of interests, IB LLC has only
allowed Interactive Advisors clients to open no-borrowing-ability margin accounts. These accounts are not allowed to
borrow for investment/leverage purposes but have the ability to use proceeds from stock and ETF sales immediately
for new purchases instead of waiting for the usual 2-day settlement period, and, just like is the case with cash brokerage
accounts at IB LLC, any cash shortfall in these accounts is covered by liquidating account holdings sufficient to cover
the shortfall. A conflict of interest arises as this account type’s use of margin based on our management will result both
in interest charges by our affiliate IB LLC and a higher Fee payable to us based on the increased gross market value
of the account. We mitigate this conflict of interest by IB LLC generally not extending to our clients any more margin
that is deemed necessary to address free riding issues. Nonetheless this conflict of interest cannot be completely
eliminated because this account type could owe small amounts of margin interest to our affiliated broker-dealer IB
LLC during the 2-day settlement window.
Benchmark Comparisons Made Available to Clients
Comparisons to benchmarks on the individual portfolio pages on our website are provided for illustrative purposes only. As
of February 2021, benchmark comparisons provided in portfolio performance charts are not automatically available but can
be displayed if website visitors choose to have them displayed. Benchmarks relevant to each portfolio are assigned by
Interactive Advisors based on overall strategy, portfolio trade history, and/or other criteria. Interactive Advisors believes that
comparing the relative performance of the portfolios against the performance of an appropriate benchmark can provide insight
into the reasons for a portfolio’s performance and may assist clients in making investment decisions. There are no universal
criteria for choosing an appropriate portfolio benchmark. But clients should be mindful of the limitations of using benchmark
comparisons in making investment decisions. As prominently stated on our website, the performance, composition and
volatility of the portfolios we offer and the benchmark(s) that could be selected for comparison purposes, could vary
significantly.
At this time Interactive Advisors uses investable exchange-traded fund (“ETF”) as benchmarks. Unlike index returns,
investable ETF returns reflect the deduction (i.e., are net of) management fees, transaction costs and expenses and are thus
more comparable to Interactive Advisors portfolio returns. Benchmark returns displayed on the individual portfolio pages
have been calculated by Interactive Advisors using daily-adjusted close prices.
For some of the portfolios, Interactive Advisors has selected the S&P 500 ETF as a benchmark. Broadly-based benchmarks
like the S&P 500 ETF may be shown only as an indication of the general performance of the financial markets during the
Informational Brochure - February 3, 2026
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periods indicated, for comparison to general equity market behavior only and may not be suitable for comparison to individual
portfolios with specific objectives, such as industry or security types. Generally, Interactive Advisors chooses the S&P 500
ETF as a benchmark for a portfolio when that portfolio is not constrained to particular industries or types of securities, which
might make a benchmark with a narrower scope or in a specific market segment more appropriate. While portfolios for which
the S&P 500 ETF is used as a benchmark may invest from time to time in certain market segments in which there may be a
more appropriate benchmark, Interactive Advisors believes that over time the appropriate benchmark for those portfolios is a
broader market benchmark such as the S&P 500 ETF. For other portfolios, Interactive Advisors has chosen different
benchmarks based on portfolio construction rules and/or consultation with any relevant data providers (as applicable) and
similarly believes that those benchmarks are a reasonably accurate representation of the segment of the total market where the
portfolio is managed.
There can be no assurance that a benchmark will remain appropriate over time and Interactive Advisors will periodically
review the benchmark’s appropriateness and decide to use other benchmarks as appropriate.
Factors not considered by Interactive Advisors
Generally, in providing its services to clients, there are a number of factors Interactive Advisors does not consider including
but not limited to:
● Tax implications: Interactive Advisors does not consider its clients’ specific tax implications in recommending
portfolios. Interactive Advisors does not provide tax advice and does not represent in any manner that investments in
a portfolio will result in any particular tax consequences. Each client must rely on his own examination and that of
its financial, tax, and legal advisors in evaluating the tax implications of investing in an Interactive Advisors portfolio.
Clients and their personal tax advisors are responsible for how the transactions conducted in an account are reported
to the IRS or any other taxing authority on the client’s personal tax returns. Interactive Advisors assumes no
responsibility for the tax consequences on any client of any transaction. Clients should not construe the contents of
the Interactive Advisors website or any recommendation made by Interactive Advisors as tax advice.
● Transaction costs and frequency of trading: Interactive Advisors does not consider, but attempts to disclose, the
frequency of a portfolio’s trading when recommending portfolios to clients. A portfolio with a high level of trading
and turnover could lead to clients incurring substantial transaction costs, tax implications (such as short-term capital
gains), and other similar consequences that could negatively impact the value of a client’s investment. Clients should
bear these transaction costs in mind when deciding whether to invest in a portfolio on the Interactive Advisors
platform. Nonetheless, for the Smart Beta, Asset Allocation, and Socially Responsible Investing Portfolios (i.e., the
only portfolios for which it decides the frequency and extent of trading), Interactive Advisors periodically reviews
turnover to ensure it is not excessive in amount or frequency, including before each rebalancing to confirm turnover
is in line with expected values.
Item 9: Disciplinary Information
As of the date of this brochure, Interactive Advisors has not been subject to any legal or disciplinary actions material to a
client’s or a prospective client’s evaluation of Interactive Advisors’ advisory business. Therefore, Interactive Advisors has no
information applicable to this item.
Item 10: Other Financial Industry Activities and Affiliations
Interactive Advisors is part of the Interactive Brokers Group, an automated global electronic broker and market maker. Neither
Interactive Advisors nor its representatives are registered as a broker-dealer or representative of a broker-dealer.
In order to perform the co-trading processes for its platform described in Item 4 of this brochure, Interactive Advisors entered
into a Technology Services Agreement with the Interactive Brokers Group, LLC (“IBG LLC”). Specifically, pursuant to this
agreement, IBG LLC, at Interactive Advisors’ direction, will develop and program Interactive Advisors’ software, which,
among other things, calculates the amount of securities to be traded for Interactive Advisors clients to effectuate Interactive
Advisors’ co-trading procedures. Interactive Advisors remains solely responsible for the investment advice provided to its
clients, and will periodically monitor IBG LLC’s implementation of its replication procedures. Interactive Advisors will pay
to IBG LLC a fee equal to IBG LLC’s cost of performance of the services under this agreement plus ten percent (10%), and
reimburse IBG LLC for any disbursements incurred in the performance of the agreement. Interactive Advisors will not charge
its clients advisory fees higher than it would otherwise charge them in the absence of this agreement.
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IB LLC, the Broker-Dealer and Custodian for all trades in client and Fund Client accounts, is a related party to and is under
common control with Interactive Advisors; both entities are subsidiaries owned by Interactive Brokers Group. IB LLC is a
registered Broker-Dealer, Futures Commission Merchant, and Forex Dealer Member, regulated by the U.S. Securities and
Exchange Commission, the U.S. Commodity Futures Trading Commission, and the National Futures Association, and is a
member of the Financial Industry Regulatory Authority and several other self-regulatory organizations. IB LLC provides
clearing and custody services on an agency basis for the Interactive Advisors trading platform, which executes Portfolio
Manager and Interactive Advisors trades alongside client accounts in accordance with Interactive Advisors’ internal trading
rules and specific client restrictions.
Interactive Advisors’ relationship with IB LLC is material to its advisory business. A conflict of interest exists to the
extent that Interactive Advisors recommends the purchase or sale of securities (to implement initial investment or
rebalancing trades) given that IB LLC receives commissions in connection with all transactions in Interactive Advisors
clients’ accounts. Additionally, the parent company of both affiliates, the Interactive Brokers Group LLC derives the
majority of its revenues from the brokerage operations of the IB LLC subsidiary. As Interactive Advisors places all of
its clients’ trades through IB LLC (which receives compensation for these services), this compensation ultimately
benefits both IB LLC and Interactive Advisors given their corporate affiliation.
Interactive Advisors does not receive any compensation from the unaffiliated third-party Portfolio Managers or the data
providers supplying any of the data for portfolios on the Interactive Advisors platform.
eligible
to
receive
credit
interest
on
settled
cash
balances
in
brokerage
Allocation to cash and associated conflict of interest: IB LLC’s brokerage clients, including Interactive Advisors clients,
are
accounts
long
(https://www.interactivebrokers.com/en/index.php?f=46385). Generally, the rate clients will earn from IB LLC on their
uninvested cash balances will be lower than yields on other cash alternatives, such as money market funds, that are available
to clients for investments outside of their IB LLC accounts. Interactive Advisors’ affiliated broker-dealer IB LLC generates
revenue on the cash held in all of its brokerage clients’ accounts, which benefits the parent company and by extension
Interactive Advisors as part of the same corporate family. The interest revenue IB LLC generates does not in any way reduce
the fees clients owe Interactive Advisors for its portfolio management services. Interactive Advisors does not manage or charge
advisory fees on uninvested cash in its client accounts which clients do not invest in the portfolios on the platform. Generally,
Interactive Advisors has a financial incentive to have clients select and invest in its portfolios rather than hold unmanaged
cash in their accounts because Interactive Advisors does not charge fees or make any revenue on uninvested cash (other than
the general financial benefit conferred on the Interactive Brokers Group by IB LLC’s above-described revenue), but does
charge an annual management fee on funds invested in a portfolio. As to the cash which is part of a client’s portfolio
investment, Interactive Advisors mitigates any conflict of interest presented by the IB LLC program and revenue described
above by using tested investment management models to objectively determine the appropriate cash allocation in a given
portfolio (for in-house built portfolios like the Smart Beta, Asset Allocation, and Socially Responsible Investing Portfolios).
The Firm’s Investment Management Team has set the maximum initial cash allocation percentage for these three portfolio
lines to 1-2% of portfolio assets. This target cash allocation may drift upward over time due to periodic dividend payments.
Interactive Advisors does not determine or direct the cash allocation for any of the other portfolios it offers which are set either
by the Portfolio Managers or the ETF Model Providers, which are not affiliated with it or IB LLC and thus would not benefit
from a larger cash allocation or the resulting increased revenue. Interactive Advisors does not in any way consider the amount
of cash in client accounts or the potential IB LLC revenue resulting from these cash balances in client accounts in determining
the appropriate level of cash in any given client investment. Clients themselves decide and can change at any time the amount
of cash sitting in their accounts above and beyond the allocation to cash associated with a specific portfolio investment.
Interactive Advisors cannot control whether such free cash is invested in a portfolio or stays as cash in a client account as only
clients can decide how much funds they transfer to an Interactive Advisors account and subsequently how much of (and
whether) those funds get invested in a specific portfolio.
Interactive Advisors is controlled by Interactive Brokers Group, an automated global electronic broker that will provide
brokerage services to the Fund Clients. The Fund Clients will pay Interactive Brokers Group a fee in exchange for the
brokerage services provided to the Fund Clients, and Interactive Brokers Group will provide such services to the Fund Clients
on terms that are generally obtainable on an arm’s-length basis from unrelated third parties, although Interactive Brokers
Group will have an interest in obtaining fees and other amounts which are favorable to Interactive Brokers Group. Any fees
or other compensation received by Interactive Brokers Group in connection with its prime brokerage service will not be shared
with the Fund.
To the extent Interactive Brokers Group acts as broker to the Fund Clients, it may take commercial steps in its own interests,
which may have an adverse effect on the Fund Clients. For example, in connection with prime brokerage involving the Fund
Clients, Interactive Brokers Group may require repayment of all or part of a loan at any time or from time to time.
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The Fund Clients, Interactive Advisors, employees and officers of Interactive Advisors and their respective affiliates will take
any and all reasonably practicable steps to avoid or substantially mitigate any circumstance in which there would be an actual
or perceived conflict arising from the relationship among Interactive Advisors and Interactive Brokers Group. Members of
Interactive Advisors’ senior management personnel perform actions, controls and checks to manage and reduce the risk of a
conflict occurring, including, but not limited to, policies in Interactive Advisors’ compliance manual and related to trade
practices, best execution, commissions and ERISA accounts. Interactive Advisors will consider actual or potential conflicts
of interest relating to its relationship with Interactive Brokers Group, and where necessary, address such conflicts by
disclosure, Limited Partner consent or other appropriate action.
Interactive Advisors does not recommend or select other investment advisers for our clients. Interactive Advisors does select
the Third-Party Subadvisors managing the Fund Clients.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
Interactive Advisors has adopted a code of ethics that sets forth the standards of conduct expected of its Associated Persons
and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Advisers
Act, its Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public
information by Interactive Advisors or any of its Associated Persons. The Code of Ethics also requires that certain Interactive
Advisors personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre-
approval of certain investments such as initial public offerings and limited offerings.
Interactive Advisors’ Access Persons may not trade securities, commodities, derivative products, financial instruments, or
exchange-traded investment products on their own behalf between the hours of 8:30 a.m. and 6:00 p.m. local time at their
place of employment. However, Access Persons may retain financial advisers to conduct such trading on their behalf during
such prohibited hours.
When managing assets for the Multi-Manager Funds, Interactive Advisors' Access Persons obtain trading data from sub-
advisers of the Multl-Manager Funds which may contain material non-public information or other confidential information.
As a result, certain Access Persons have the ability to use this confidential information to trade for themselves or for Interactive
Advisors’s algorithm trading strategy for non-Fund clients. To address this conflict and promote the interests of clients and
Fund Client Investors, Interactive Advisors prohibits Access Persons sharing trading data between sub-advisers or with Access
Persons responsible for non-Fund clients. Interactive Advisors has also created a “Restricted List” for Access Persons where
personal trading using trading data for sub-advisers is prohibited, unless exempted by the CCO.
Interactive Advisors’ Access Persons may not purchase or sell, directly or indirectly, any security which they know at the time
of the purchase or sale is being considered for purchase or sale on behalf of any client or Fund Client account or being actively
purchased or sold on behalf of any client or Fund Client account. Given the firm’s historical business model, which was limited
to implementing transactions in client accounts by tracking the trade activity in Manager Portfolios, Interactive Advisors
personnel generally were not considered to know or expected to know that a security is being purchased or sold by a client
unless that personnel had access to the firm’s trade blotter or had other knowledge of the firm’s purchases or sales before their
implementation in client accounts. But, unlike with third-party Portfolio Manager trades, certain Interactive Advisors
personnel (e.g., the Investment Management team) will be managing the Interactive Advisors Portfolios (e.g. Smart Beta,
Asset Allocation, Socially Responsible Investing, WisdomTree, and SSGA ETF Portfolios) and are deemed to know (or are
likely to know) that a security will be eventually purchased or sold by any clients, who are following that portfolio. In
accordance with the provisions of Interactive Advisors’ Code of Ethics, Interactive Advisors’ Access Persons (including
Interactive Advisors’ Investment Management team) may not purchase or sell, directly or indirectly, any security which they
know at the time of the purchase or sale is being considered for purchase or sale on behalf of any client account or being
actively purchased or sold on behalf of any client account. While Interactive Advisors employees are allowed to become
Interactive Advisors clients and invest in any Interactive Advisors Portfolios, individuals involved in making investment and
trading decisions for the Interactive Advisors Portfolios and placing related trades will be subject to certain black-out periods
for trading illiquid stocks or ETFs traded in the Interactive Advisors Portfolios in any personal trading accounts.
Access Persons may become clients of Interactive Advisors and invest in any portfolios and, as such, any Interactive Advisors-
initiated trades for those Access Persons will be executed alongside and consistent with Interactive Advisors’ management of
other clients’ accounts. Interactive Advisors currently aggregates trades initiated by Portfolio Managers and the trades of
clients investing in those Managers’ Portfolios and allocates shares purchased or sold at the average price for each trade, so as
not to affect any clients favorably or unfavorably. Access Persons may also open brokerage accounts for use by Interactive
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Advisors as test accounts. Trades in these accounts are also executed alongside all other Interactive Advisors clients.
Interactive Advisors may provide the owners of these test accounts with funding to invest in these accounts.
Interactive Advisors Access Persons must acknowledge the terms of the Code of Ethics annually or as amended.
Fund Client Investors or clients may contact Interactive Advisors to request a copy of the Firm’s Code of Ethics.
Portfolio Managers’ Trading
Portfolio Managers may manage accounts outside of Interactive Advisors for other clients and may implement the same trading
strategy or decisions in those accounts before they do so in their Interactive Advisors account. This means that there may be
situations where Portfolio Managers enter the same trades on behalf of their clients outside of Interactive Advisors before they
trade in their Interactive Advisors account (and therefore before the strategy is replicated in Interactive Advisors client
accounts). This could result in Interactive Advisors clients getting less favorable pricing terms and performance in their
Interactive Advisors account than the Portfolio Manager’s clients get in their non-Interactive Advisors accounts. To minimize
the effects of this potential conflict of interest, all Portfolio Managers must agree to report, monitor, and review under their
own Code of Ethics provisions trades in the IB account that are co-traded through the Interactive Advisors platform. In the
Portfolio Manager License Agreement, Portfolio Managers represent to Interactive Advisors that neither they nor their
personnel or affiliated persons will use their knowledge of the timing of the trades in their Interactive Advisors account or the
fact that those trades will prompt trades in Interactive Advisors client accounts to trade ahead of Interactive Advisors clients
or otherwise improve their position in the ownership of those securities or move their prices. Portfolio Managers must also
provide Interactive Advisors with an annual certification that they are not aware of any instances of front-running in connection
with trades placed at Interactive Advisors through their Code of Ethics reviews or otherwise. Portfolio Managers agree to
promptly notify Interactive Advisors in writing of any instances of front-running trades placed at Interactive Advisors. Non-
Registered Portfolio Managers (generally exempt hedge fund managers) will be subject to a limited version of Interactive
Advisors’ Code of Ethics and are required to report their personal trading activity to Interactive Advisors. At this time, there
are no non-registered Portfolio Managers on the Interactive Advisors platform.
At its discretion, Interactive Advisors could randomly check managers’ trading in non-Interactive Advisors-linked accounts
following the same strategy as their Interactive Advisors-linked account to detect any instances of trading ahead and/or any
indication of improper trading practices and will prominently disclose to clients or prospects any material aspects of the
manager’s trading practices.
Proprietary Trading for the Management of Interactive Advisors Portfolios
Interactive Advisors manages the Interactive Advisors Portfolios by trading in one or more proprietary brokerage account(s)
associated with each such portfolio. A conflict of interest thus arises between Interactive Advisors executing trades in that
proprietary account with the knowledge that it will be executing similar trades in client accounts investing in that Interactive
Advisors Portfolio. Interactive Advisors may have an incentive to provide favored treatment to its proprietary account to the
detriment of Interactive Advisors client accounts investing in an Interactive Advisors Portfolio by trading ahead of clients in
that proprietary account or taking other actions which favor Interactive Advisors’ proprietary account. By choosing to invest
in one or more Interactive Advisors Portfolios, Interactive Advisors clients acknowledge and agree that Interactive Advisors
will manage their accounts by replicating trading Interactive Advisors conducts in proprietary accounts funded with its own
capital.
To mitigate any conflict of interest or risk of trading ahead of its clients presented by Interactive Advisors trading in a
proprietary brokerage account in connection with the management of the Interactive Advisors Portfolios, Interactive Advisors
has imposed on itself the same protections against potential front-running that it applies to the third-party Portfolio managers
whose trading Interactive Advisors mirrors, described in the Investment Management Agreement Interactive Advisors clients
sign:
● Combining orders for the sale or purchase of a security by Interactive Advisors with those of Interactive Advisors’
clients that invest in any of the Interactive Advisors Portfolio accounts;
● Placing the combined orders through IB LLC; and
● Allocating the combined trades between Interactive Advisors and client accounts on a pro rata basis (i.e., Interactive
Advisors clients and Interactive Advisors receive the same average price per share and share transaction costs pro
rata) (a process referred to as “co-trading”).
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Agency Cross Transactions
IB LLC and Interactive Advisors may only execute trades referred to as “Agency Cross Transactions” if a client has given
written consent in advance through the Investment Management Agreement executed with Interactive Advisors. In that
agreement, Interactive Advisors clients acknowledge and agree that an Interactive Advisors affiliate (namely, IB LLC) may
engage in “Agency Cross Transactions” as defined in Rule 206(3)-2 (17 C.F.R. § 275.206(3)-2) promulgated by the SEC
under the Advisers Act, in which an Interactive Advisors affiliate acts as a broker both for an Interactive Advisors client and
for the customer on the other side of the transaction. Interactive Advisors clients acknowledge that the Interactive Advisors
affiliate may receive commissions from and have a potentially conflicting division of loyalties and responsibilities regarding
both parties to such Agency Cross Transactions. Nonetheless, Interactive Advisors clients consent to and authorize IB LLC to
engage in such Agency Cross Transactions, and may revoke this consent and authorization at any time by written notice to
Interactive Advisors or IB LLC.
Compliance with Rule 206(3)-2 requires Interactive Advisors to satisfy the following conditions:
1. Clients must provide written consent in the Client Agreement prospectively authorizing Agency Cross Transactions
after full written disclosure that IB LLC, Interactive Advisors’ affiliate, will act as a broker, receive commissions
from and have a potentially conflicting division of loyalties and responsibilities regarding both parties to these
transactions. Interactive Advisors’ Investment Management Agreement with its clients provides such written
disclosure and obtains such written consent from its clients. Specifically, Interactive Advisors clients consent to IB
LLC designating their orders to trade: (1) on IB LLC’s Automated Trading System or a public exchange, against the
orders of other IB LLC customers, including liquidity providers; (2) through an exchange-operated price
improvement facility; or (3) against a third-party liquidity provider that would fill orders (such as orders for less than
a full share), which could otherwise not be filled in the open market. These Agency Cross Transactions are reflected
and identified in Interactive Advisors clients’ IB LLC activity statements. IB LLC will act as a broker for and receive
commissions from both parties to these transactions.
2.
Interactive Advisors or IB LLC on behalf of Interactive Advisors must send each client a written confirmation at or
before the completion of each transaction that includes (i) a statement of the nature of this transaction, (ii) the date
this transaction took place, (iii) an offer to furnish, upon request, the time when this transaction took place, and (iv)
the source and amount of any other remuneration received or to be received by Interactive Advisors’ affiliated broker-
dealer. This confirmation would take place prior to settlement, but after execution, and a transaction is not complete
until the settlement takes place. Interactive Advisors does not receive any compensation from IB LLC. IB LLC will
provide these written confirmations of Agency Cross Transactions to Interactive Advisors clients in the trade
confirmations and daily activity statements for the accounts, either through IB LLC’s Account Management system
or for the simplified robo advisor account type (opened since July 2018) through the Account Management window
embedded in the Firm’s dashboard, accompanied by email notice of posting.
3.
Interactive Advisors or IB LLC on behalf of Interactive Advisors must send clients an annual statement identifying
the total number of Agency Cross Transactions and the total amount of commissions or other remuneration that
Interactive Advisors or IB LLC received in connection with these agency-cross transactions since the last summary.
IB LLC will provide this information in the annual activity statements for clients’ accounts, provided as noted above.
4. Client consent may be revoked at any time, and all written disclosure statements and confirmations discussed above
must include a conspicuous statement that clients’ written consent to these Agency Cross Transactions may be
revoked at any time by written notice to Interactive Advisors or IB LLC. Interactive Advisors’ Investment
Management Agreement with its clients includes such a conspicuous statement. Trade confirmations and activity
statements provided by IB LLC to clients also include such a statement.
Fractional Share Transactions
Interactive Advisors is able to offer the Interactive Advisors Portfolios and Manager Portfolios and the extensive
diversification they are designed to achieve at even relatively small investment amounts by allowing Interactive Advisors
clients to trade fractional shares. Because stocks or ETFs cannot be traded in fractions on public exchanges, IB LLC,
Interactive Advisors’ affiliated broker-dealer, facilitates trading in these Portfolios by executing all fractional share orders on
behalf of Interactive Advisors clients against a liquidity provider who is an IB LLC client. This liquidity provider sells or buys
fractional shares that Interactive Advisors clients would not otherwise be able to trade in the open market. These trades occur
either at the execution price the liquidity provider gets on the market for shares it sells to Interactive Advisors clients or, if the
fractional shares are provided from the provider’s inventory, at the National Best Bid or Offer (“NBBO”) at the time of the
order.
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Interactive Advisors clients investing in any of the portfolios on the platform consent to IB LLC matching their fractional
share buy and sell orders with the liquidity providers willing to trade fractional shares with Interactive Advisors and its clients.
Clients may revoke their written consent to such transactions at any time by written notice to Interactive Advisors or IB LLC,
as discussed in the Investment Management Agreement. But clients revoking their written consent to these Agency Cross
Transactions in fractional shares should note that if they do so they will no longer be able to invest in portfolios on our platform,
which rely on fractional share investments.
Fractional shares are typically unrecognized and illiquid outside of a client’s advisory account and, as a result, fractional shares
may not be marketable or transferrable to another brokerage account. In the event of a liquidation or transfer of assets to
another account, Interactive Advisors may convert such fractional shares to cash.
As a result, if you want to liquidate any of your investments in your portfolio, you will need to fully redeem your investment
in which case IB LLC will sell any fractional shares to the liquidity provider and any whole shares to the market. If you want
to transfer portfolio holdings to another brokerage firm, you will first need to sell your fractional shares to the liquidity provider
through IB LLC and will incur commissions on all of these trades. Please note that IB LLC cannot facilitate customers voting
proxies on fractional share holdings, does not provide a mechanism to make voluntary elections on your fractional holdings,
and cannot provide you with any shareholder documentation for any holdings of less than one share.
Agency Cross Transactions in IRA Accounts
Pursuant to the Department of Labor’s Prohibited Transaction Exemption 86-128, Interactive Advisors started seeking IRA
account holders’ written consent for its affiliated broker dealer IB LLC to receive brokerage commissions for effecting or
executing securities transactions in their accounts and for acting as a broker for both the IRA account holder and the party on
the other side of the transaction and receive reasonable compensation from both parties before allowing clients to invest in
any portfolios. Interactive Advisors will give IRA account holders the opportunity to revoke their authorization on an annual
basis, but IRA account holders may also terminate their authorization at any time by calling 1-866-825-3005 or emailing us
at clientservices@interactiveadvisors.com. IRA account holders also receive certain information about IB LLC’s commissions
revenue and portfolio turnover in their quarterly and annual activity statements provided by IB LLC, as required under the
above-mentioned Prohibited Transaction Exemption 86-128.
Principal Transactions
Neither Interactive Advisors nor any of its Affiliates will engage in any principal transactions with Interactive Advisors clients
or Fund Clients. IB LLC will not knowingly designate client or Fund Client orders to trade with the orders of Interactive
Advisors’ Affiliates engaged in proprietary trading. This may affect the timing, price, and quantity of the execution received.
Please note that certain Interactive Advisors Affiliates, including Interactive Advisors employees, officers and directors, and
employees of the Interactive Brokers Group Inc., invest with and are clients of Interactive Advisors. Because Agency Cross
Transactions between Interactive Advisors Affiliates and other Interactive Advisors clients or Fund Clients could be deemed
principal transactions, Interactive Advisors will set up a process designed to prevent Interactive Advisors Affiliates from
trading with any other Interactive Advisors clients or Fund Clients, both internally and on the open market. Interactive
Advisors does not allow trading between Interactive Advisors client accounts internally at IB LLC.
Item 12: Brokerage Practices
Affiliated Brokerage
Interactive Advisors uses its affiliated broker dealer IB LLC for all trading in its portfolios. Clients must open a brokerage
account with IB LLC if they want to invest in one of the portfolios offered by Interactive Advisors. All brokerage commissions
and/or transaction fees charged by IB LLC are exclusive of and in addition to Interactive Advisors’ management fees.
All brokerage transactions under the Investment Management Agreement will occur through IB LLC, Interactive
Advisors’ affiliated broker-dealer. The use of an affiliate for brokerage services represents a conflict of interest. Due
to technical and best execution considerations, Interactive Advisors is only utilizing the brokerage services of IB LLC,
a related party. Interactive Advisors does not accept clients who direct the use of other brokers. Interactive Advisors
thus directs all of the Managers and clients on its platform to establish brokerage and custodial relationships with IB
LLC.
In the Investment Management Agreement, Interactive Advisors clients appoint IB LLC as the broker and custodian
for the assets in their accounts and direct Interactive Advisors to execute all trading in their Interactive Advisors
accounts through IB LLC, and acknowledge the conflict of interest in this brokerage arrangement. In the Investment
Management Agreement, clients also acknowledge that the appointment of IB LLC as the sole broker for their account
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may result in disadvantages to them, i.e., less favorable executions (e.g., higher commissions, greater spreads, or less
favorable net prices) than may be available through the use of a different broker-dealer.
Both Interactive Advisors clients and Interactive Advisors Portfolio Managers pay IB LLC commissions for the trades
in their Interactive Advisors accounts, which represents a conflict of interest. Interactive Advisors does not directly
receive any of the brokerage revenue generated by IB LLC from Managers or clients trading through Interactive
Advisors. But Interactive Advisors is supported financially by IBG LLC, the parent company of both Interactive
Advisors and IB LLC, and IBG LLC’s revenues primarily stem from its brokerage operations.
All Interactive Advisors trades are affected on an agency basis. When selecting IB LLC as a broker dealer, Interactive Advisors
did not consider whether Interactive Advisors or a related party receives client referrals from that broker-dealer.
Interactive Advisors has evaluated the brokerage services and cost of IB LLC and believes that IB will provide Interactive
Advisors clients with a blend of execution services, commissions costs, financial strength and reputation, trading platform,
responsiveness to clients’ execution needs, block trading capabilities, accuracy of trades and trade confirmations, and
professionalism that fulfills Interactive Advisors’ best execution requirement for client transactions. While Interactive
Advisors has a reasonable belief that IB LLC is able to obtain best execution and competitive prices, Interactive Advisors will
not independently seek best execution price capability through other broker dealers. Interactive Advisors periodically
undertakes Trade Cost Analysis (“TCA”) of trades in client accounts to confirm the quality of IB LLC’s brokerage execution
services. The commissions paid by Interactive Advisors’ clients shall comply with Interactive Advisors’ duty to obtain “best
execution.” Interactive Advisors shall periodically and systematically review its policies and procedures regarding
recommending IB LLC as a broker dealer to its clients in light of its duty to obtain best execution.
While we reasonably believe the use of IB LLC is in its clients’ best interests and allows for more effective investments,
clients should be aware and understand the use of IB LLC may prevent Interactive Advisors from negotiating brokerage
commissions and other charges on clients’ behalf. This practice may also prevent Interactive Advisors from obtaining best
execution of some or all of clients’ orders. As a result, the use of affiliated brokerage could result in higher commissions,
greater spreads, or less favorable net prices than would be the case if Interactive Advisors were able to select other broker-
dealers to execute transactions.
Additionally, clients and Fund Client Investors should be aware that a significant shareholder of Interactive Brokers Group,
Inc. is a significant client of Interactive Advisors through investments in the Smart Beta Portfolios and the Multi-Manager
Funds. Although this client does not receive any preferential treatment by comparison to other Interactive Advisors clients or
Fund Client Investors, his investments represent the majority of the assets under management at this time in the Smart Beta
Portfolios and the Multi-Manager Funds. This client relationship presents a conflict of interest as Interactive Advisors has an
incentive to favor this client over any other of its clients. .
Commissions Charged by IB LLC
In the summer of 2021, Interactive Advisors elected to have all of its clients’ brokerage accounts at IB LLC operate
under the zero-commission “IBKR-LITE” fee model. IBKR-LITE clients are charged zero commission for US exchange-
listed stock and ETF trades. IBKR-LITE orders for NMS stocks are generally routed to select over-the-counter market-makers
(“Market Makers”) for handling. IB LLC’s agreements with the Market Makers provide IB LLC with payment for order flow
(“PFOF”) from each Market Maker for trades executed with that Market Maker. IB LLC may also route IBKR-LITE orders
to another broker, ATS, or exchange (each an “Away Route”), in which case it may collect PFOF for trades executed at or
through that Away Route. Although IB LLC’s receipt of PFOF may reduce the amount of price improvement that client
accounts obtain on their stock and ETF trades (as compared to the price improvement available under IBKR’s IBKR-PRO fee
model), Interactive Advisors believes that the amount that clients save by avoiding commissions (as compared to IBKR-PRO)
generally more than compensates for any loss
to IBKR-Lite clients for such products. For more
IBKR-Lite clients are charged no brokerage account activity fees and no market data fees for US exchange-traded stocks and
ETFs, but they may incur non-commission related fees such as market data fees for other products, service fees such as wire
transfer fees, and fees to cover regulatory fees incurred by IB LLC when clients sell stocks. These fees are not intended to be
a direct pass-through of exchange and third-party fees. Costs passed on to IBKR-Lite clients may be greater than the costs
paid by IBKR to the relevant exchange, regulator, clearinghouse or third party. For products not entitled to zero-commission
trading under IBKR Lite, the same commission structure will apply to both IBKR-Lite and IBKR-Pro. Where applicable, a
“Fixed” commission model will apply
information, see
ibkr.com/commissions
The operation of the IBKR-LITE service for Interactive Advisors clients constitutes a conflict of interest in light of the
corporate affiliation between the two entities and the fact that the payments IBKR will receive from Market Makers and Away
Routes on Interactive Advisors client orders will benefit the parent company of both entities and thus Interactive Advisors
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indirectly and the fact that IBKR-LITE executions may end up bringing clients less price improvement than IBKR-PRO
executions even after accounting for the commissions savings.
This conflict of interest is disclosed to and acknowledged by Interactive Advisors clients at account opening through the
provision of this disclosure. This conflict is mitigated by periodically confirming that IBKR-LITE executions are in line with
IBKR-PRO executions after accounting for the commissions savings. Interactive Advisors believes the benefits clients will
receive from IBKR-LITE commission structure including zero-commission NMS stocks trades and fixed-rate commission US
equity options trades outweigh the conflict of interest.
Any information Interactive Advisors provides to clients about the possibility and benefits of a brokerage account upgrade is
provided by IB LLC and furnished to clients as a courtesy. This information should not be construed as a recommendation by
Interactive Advisors to upgrade to a full IB LLC brokerage account, to trade in any particular way, or to trade on margin.
The Fund Clients’ IB LLC brokerage account(s) utilize the IBKR-PRO fee model. IB LLC charges commissions and fees to
the Fund Clients on terms that are generally available on an arm’s-length basis to unrelated third parties.
Commissions and Tax Burdens Associated with the Rebalancing of the Interactive Advisors-Managed Smart Beta
Portfolios and Index Tracking Portfolios
Interactive Advisors rebalances these two Interactive Advisors Portfolio lines quarterly. Due to large number of holdings in
these portfolios, quarterly rebalancing of the Smart Beta and Index Tracking portfolios and client investments and divestments
could result in a large number of quarterly transactions in many or all of the securities, in which the Smart Beta and/or Index
Tracking portfolios and client accounts are invested. A higher turnover rate could result in higher turnover taxes when held in
a taxable account. The additional costs associated with higher portfolio turnover will affect the performance of client accounts
investing in these portfolios.
Clients will need to report some (or all) of these trades on their tax forms. Interactive Advisors cannot provide tax advice or
prepare tax documents for clients. Clients should consult an accountant or tax attorney to determine the tax-related obligations
associated with investing in these portfolios. IB LLC provides certain tools to assist its brokerage clients with their tax filings,
but these tools may only be able to support a limited number of trades.
Soft Dollar Arrangements
An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser receives research or
other products and services in exchange for client securities transactions or maintaining an account balance with the broker-
dealer. We do not have a soft dollar agreement with IB LLC or a third-party. But we do receive benefits other than execution
services by using IB LLC as our custodian and executing broker, including but not limited to services that help us manage and
administer client accounts such as: software and technology systems that allow us to manage client data, execute trades, get
market and pricing information, process advisory fees, recordkeeping and client reporting. Although the receipt of these
benefits is a potential conflict of interest, we believe these benefits are typical for the industry. Generally, our selection of IB
LLC is primarily supported by the scope, quality and pricing of IB LLC’s services. These benefits outside of execution are
general benefits used to help service all of our client accounts and are not allocated pro rata to certain client accounts.
In the event that Interactive Advisors determines to use soft dollars with respect to the Fund Clients, it will only do so in
compliance with the safe harbor provided by Section 28(e) of the Exchange Act and subject to prevailing guidance provided
by the SEC regarding Section 28(e).
Trade Aggregation
Trade orders placed by Portfolio Managers or Interactive Advisors will normally be aggregated with clients orders, which
facilitates best execution. We note however that trades may not be aggregated if client restrictions prevent us from doing so.
Trade Allocation
We attempt to allocate investment opportunities on a pro-rata basis among eligible accounts based on the originally planned
allocation. Both the Portfolio and the client will receive the average price for each trade. However, in certain situations, it may
not be equitable to allocate on a pro-rata basis (e.g. round lots or size restrictions on the allocation). The trading systems used
by IB LLC automatically allocate trades on a pro-rata basis (with respect to the market imposed round lot requirements).
Timelines
We will ensure that transactions are promptly and fairly allocated between the Portfolio Manager or Interactive Advisors, on
the one hand, and clients, on the other hand, at the average price.
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Small adjustment trades to minimize performance drift in Portfolios
To ensure that Interactive Advisors is able to better track trading activity in Manager or Interactive Advisors Portfolios, clients
authorize Interactive Advisors to make adjustment trades that Interactive Advisors in its discretion determines will help a
client account mirror the Portfolio(s) in which the client invests. Clients understand and acknowledge that these adjustments
may require small buy or sell trades in their accounts, which they authorize Interactive Advisors to effect without the clients’
specific advance approval or authorization. Clients also understand that they will incur additional transaction costs, including
commissions, in connection with these small adjustments. A conflict of interest arises in connection with these adjustments
because IB LLC, Interactive Advisors’ affiliated broker-dealer, collects commissions on these trades. Clients acknowledge
this conflict of interest and authorize Interactive Advisors to effect these adjustment trades in the Investment Management
Agreement they enter into with Interactive Advisors.
Best Execution
Regardless of how transactions are executed, Interactive Advisors strives to ensure IB LLC obtains best execution of client
and Fund Client trades whenever possible.
Item 13: Review of Accounts
Interactive Advisors will periodically contact clients to review its previous services or investment recommendations to them
and to discuss the impact resulting from any intervening changes in clients’ financial situation or investment needs.
Investment activity in all client accounts may be monitored periodically by the Chief Investment Officer for potential conflicts
with the client’s stated investment objectives and risk tolerances, namely in the areas of liquidity, risk exposure, and investment
strategy and trade activity associated with investments.
Interactive Advisors reevaluates the risk scores assigned to Portfolio Manager strategies (at least annually) and prompts clients
to review their answers to the risk assessment questionnaire and previously specified investment restrictions (at least quarterly)
to ensure clients are invested in strategies suitable for their risk appetite and ability to withstand investment losses. Annually,
Interactive Advisors will contact clients to determine whether there have been any changes in their financial situation or
investment objectives warranting a revision of their prior answers to the risk assessment questionnaire and whether clients
want to impose new or revise existing restrictions on the trading in their accounts. Interactive Advisors’ client service
representatives are also available to discuss and explain investment decisions made for their Interactive Advisors Portfolio
investments and may be contacted by telephone at 1-866-825-3005 and by email at support@interactiveadvisors.com.
Interactive Advisors clients are and remain responsible at all times for advising Interactive Advisors of any changes in
their financial situation, investment objectives, risk tolerance and investment restrictions. Clients who have
experienced material changes to their financial circumstances or investment objectives, or wish to impose initial or
modify existing ticker or reasonable restrictions upon Interactive Advisors’ management services, or make any other
changes to the management of their assets should promptly update their information and responses to the risk
assessment questionnaire on the Interactive Advisors website or contact one of our client services representatives to
inform them of any intervening changes.
individual, password-protected,
login credentials
to
its website,
Interactive Advisors provides clients with
https://interactiveadvisors.com/ where clients have direct access to their secure, private account detail pages, where they can
revise their investment objectives and their answers to the risk assessment questionnaire, view their account holdings, daily
account activity and performance, and access their monthly Portfolio reports detailing performance and risk exposure.
Clients are urged to periodically compare activity statements prepared by Interactive Advisors and quarterly account
statements and transaction confirmations provided by IB LLC with regard to activity, holdings and valuations in their
Interactive Advisors account. Clients should immediately inform Interactive Advisors of any discrepancies they detect
between Interactive Advisors and IB LLC account statements.
Fund Clients
Each Third-Party Sub-Advisor will be required to manage their Sub-Account in parallel with their Flagship Fund. Interactive
Advisors will establish processes and procedures to monitor Third-Party Sub-Advisors’ parallel management of their Flagship
Funds and Sub-Accounts and will address material discrepancies.
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Item 14: Client Referrals and Other Compensation
Solicitations and Referrals
Interactive Advisors does not receive compensation or other economic benefits from persons other than clients or Fund Clients
for providing investment advice or advisory services to its clients or Fund Clients. Interactive Advisors does not currently use
solicitors to refer advisory clients to the Firm and does not compensate a third-party for client referrals.
IB LLC, and its international affiliates (in their capacities as placement agents for the Fund Clients, the “Placement Agents”),
will act as the sole placement agents for the Fund Clients to assist in the placement of interests in the Fund Clients. The
relationship between Interactive Advisors and the Placement Agents presents such persons with a potential conflict of interest
in marketing such investment. Prospective investors in the Fund Clients should take the relationship between Interactive
Advisors and the Placement Agents into account when considering an investment in a Fund Client. Placement Agent
representatives involved in the marketing and placement of investments in the Fund Clients are not acting as tax, financial,
legal or accounting advisors to potential investors in connection with the offering of the Interests. Potential investors in the
Fund Clients must independently evaluate the offering and make their own investment decisions.
Portfolio Manager Compensation
Interactive Advisors compensates each Portfolio Managers with a portion of the Management Fee(s) charged to clients for
their investments in the specific Manager Portfolio. Occasionally, Interactive Advisors clients may have initially heard about
Interactive Advisors from one of the Portfolio Managers on the platform, but Interactive Advisors will not compensate
Portfolio Managers for any client referrals.
Item 15: Custody
Recommended Custodian and Clearing Services
Interactive Advisors recommends that clients utilize the brokerage and clearing services of IB LLC. Interactive Advisors only
implements its investment management services after the client has arranged for and furnished Interactive Advisors with all
information and authorization regarding the opening of a brokerage account with IB LLC, a related party of Interactive
Advisors.
Interactive Advisors likely has custody of client funds and securities by virtue of its affiliation with IB LLC, the qualified
custodian for client funds and securities, and also in light of certain provisions in the brokerage agreement that clients enter
into with IB LLC for the simplified robo advisor account type launched in July 2018.
In accordance with the SEC’s Custody Rule and in recognition of the corporate relation between Interactive Advisors and IB
LLC, the qualified custodian of its clients’ assets, since 2015, Interactive Advisors has engaged an independent public
accountant to conduct an annual, independent surprise audit of client funds and securities.
IB LLC sends quarterly account statements directly to Interactive Advisors clients identifying the amount of funds and
securities in their account(s) at the end of the period and setting forth all transactions in the account(s) during that period,
including but not limited to any fees charged by Interactive Advisors. Clients should contact IB LLC or Interactive
Advisors immediately if they do not receive account statements from IB LLC on at least a quarterly basis. Interactive
Advisors clients should carefully review those statements to ensure that they accurately reflect the transactions in their
Interactive Advisors account(s). Interactive Advisors may also separately provide account updates to its clients. Clients should
carefully compare the account updates they receive from Interactive Advisors with the account statements they receive from
IB LLC, the qualified custodian. The account statements received from IB LLC are the official custodial records for Interactive
Advisors client accounts. The reports provided by Interactive Advisors are not statements but simply tools clients should use
in evaluating the performance of their investments and are not intended to replace the statements received from the custodian
of assets, IB LLC. If clients discover any discrepancy between the account statements provided by Interactive Advisors and
those provided by IB LLC, then they should contact Interactive Advisors immediately.
Fund Clients
IB LLC, a “qualified custodian” as such term is defined in the Custody Rule, will be the custodian of the Fund Clients’ funds
and securities. Interactive Advisors will be deemed to have custody of Fund Client funds and securities because it will have
the authority to obtain Fund Client funds or Securities, for example, by deducting advisory fees from a Fund Client’s account
or otherwise withdrawing funds from a Fund Client’s account.
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Interactive Advisors will comply with the Custody Rule in accordance with the so-called “Pooled Vehicle Annual Audit
Exception”, which, among other things, requires that each Fund Client be subject to audit at least annually by an independent
public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight
Board, and requires that each Fund Client distribute its audited financial statements to all investors within 120 days of the end
of its Fiscal Year.
Item 16: Investment Discretion
As authorized in the Interactive Advisors Client Agreement, Interactive Advisors assumes discretionary authority over client
assets placed with Interactive Advisors for management. This is done via a power of attorney granting Interactive Advisors
the ability to initiate financial transactions and trades on behalf of its clients, in order to execute trades in Portfolios clients
invest in. This grant of investment discretion allows Interactive Advisors to place trades in client accounts without contacting
clients before each trade. In all cases, however, Interactive Advisors’ discretion will be exercised in a manner consistent with
the investment objectives, risk tolerance, and risk score for the particular client account. Clients maintain authority to revise
their answers to the risk assessment questionnaire, change their investment status, and may place restrictions on the securities
to be bought or sold for their account.
No self-directed trading available
Clients should understand that the Interactive Advisors platform is a discretionary investment advisory program and not a self-
directed brokerage service. Unlike in a self-directed brokerage account, in their Interactive Advisors accounts clients cannot
enter individual buy and sell orders for specific securities to be executed at particular times. In accordance with the
discretionary trading authority granted Interactive Advisors by clients, once a client selects a Manager or an Interactive
Advisors Portfolio to invest in, the client may not alter the Portfolio or the trades in his account that is invested in that Portfolio,
except to restrict the trading of specific tickers or securities in his account. Clients may terminate their investment in a Portfolio
at any time and invest in another Portfolio available on the Interactive Advisors platform or choose not to invest in any
Portfolio. If a client wants to control the specific time and securities to be bought and sold in his account, he should not use
Interactive Advisors’ services or should execute separate self-directed trades in a separate partition of the client’s IB LLC
brokerage account or another brokerage account at IB LLC or elsewhere.
Interactive Advisors clients may restrict the tickers or securities traded in their account at any time and Interactive Advisors
will honor these restrictions when mirroring the trading in portfolios clients choose to invest in if such restrictions are received
in a timely fashion before Interactive Advisors places trades in client accounts. Clients should understand that imposing
restrictions on future investments and selling any existing holdings in a portfolio affect the performance of a client’s account
negatively or positively and lead to that account performing differently and possibly worse than the Manager or Interactive
Advisors account trading that portfolio or other client accounts invested in the same portfolio. Clients also understand and
acknowledge that they are responsible for informing the Firm if they do not want to sell existing holdings in a security
they decide to restrict and implement the security restriction only prospectively. In the absence of such notice from
clients, the Firm will implement any security restriction by both selling existing holdings in that security and refraining
from trading in that security in the future, if and until the client decides to lift that restriction.
Fund Clients
Interactive Advisors will execute an Investment Management Agreement with each Fund Client. Interactive Advisors’
investment decisions and advice with respect to each Fund Client are subject to each Fund Client’s investment objectives and
guidelines, as set forth in each Fund Client’s offering documents.
Item 17: Voting Client Securities
Interactive Advisors obtains authority from its clients to receive proxy materials and vote client proxies, and has adopted proxy
voting policies and procedures designed to ensure that it votes proxies in the best interest of its clients and that it provides
clients with information about how their proxies are voted. In light of its fiduciary duty to clients, the complexity of the issues
that may be raised with proxy votes and the relatively large number of unique holdings that clients may hold in their accounts
as a result of investments in portfolios on the platform, Interactive Advisors has retained Institutional Shareholder Services
Inc. (“ISS”) to vote proxies on its behalf. ISS is an independent third party that specializes in providing a variety of fiduciary-
level proxy-related services to institutional investment managers and investment advisors. The services provided by ISS to
Interactive Advisors include in-depth research, voting recommendations, vote execution and recordkeeping. ISS’s Proxy
Voting Guidelines (Benchmark Policy Recommendations) for the United States guiding ISS’s proxy voting on Interactive
Advisors’ behalf are available on the ISS website: https://www.issgovernance.com/policy-gateway/voting-policies/ At times,
Interactive Advisors and/or ISS may not be able to vote proxies on behalf of clients when clients’ holdings are in countries
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that restrict trading activity around proxy votes or the securities are otherwise restricted. Also, Interactive Advisors will not
be responsible or liable for failing to vote on any proxies where it has not received the proxies or related shareholder
communications on a timely basis.
Interactive Advisors will use its best judgment to vote proxies in the best interests of its clients and will typically follow the
recommendations of ISS. In the event that Interactive Advisors decides to vote a proxy (or a particular proposal within a
proxy) in a manner different from the ISS recommendation, Interactive Advisors will document the reasons supporting the
decision. In the event that Interactive Advisors intends to deviate from the proxy voting recommendation of ISS and a conflict
of interest is present, Interactive Advisors shall bring the proxy voting issue to the attention of affected clients for guidance
on how to vote the proxy while disclosing the conflict. Clients may obtain a copy of Interactive Advisors’ Proxy Voting
Policies and Procedures and information about how client proxies were voted by calling us at 1-866-825-3005 or emailing us
at clientservices@interactiveadvisors.com.
The ISS platform Interactive Advisors uses to vote proxies on its clients’ behalf uses pre-populated vote features. Interactive
Advisors will periodically sample pre-populated votes.
When Interactive Advisors becomes aware that an issuer intends to file or has filed additional soliciting materials with the
SEC that would reasonably be expected to affect its vote, in advance of the submission deadline, the Firm will promptly review
these additional materials and decide if Interactive Advisors is to adhere to ISS’s recommendation(s). Notwithstanding, if
Interactive Advisors believes ISS’s proxy recommendations will generally serve the best economic interests of its clients,
Interactive Advisors will vote in accordance with ISS’s recommendations. However, if additional soliciting materials are made
available to Interactive Advisors seven (7) business days prior to the submission deadline by U.S. issuers or fourteen (14)
business days by non-U.S. issuers, the Proxy Administrator is not required to review these materials or take any action.
Under ISS’s current processes, in the event new material public information becomes available or if ISS finds that a report
contains a material error, ISS promptly issues a Proxy Alert (“Alert”) to inform its clients including Interactive Advisors of
any corrections and, if necessary, any resulting changes in the vote recommendations. Alerts are distributed to ISS’ investor
clients through the Proxy Exchange platform used to distribute the regular research and voting recommendations. This ensures
that the Firm, if it received an original report, will also receive the related Alert, which is attached to the relevant original
company meeting report. Even if the Firm has cast its vote before receiving an Alert, the Firm may cancel and change its vote
at any time before the meeting cut-off date, if it determines that such a change is warranted by the new information. ISS is
currently evaluating client needs as it relates to future reporting, alerting, and on-screen signals to indicate the availability of
issuer feedback. Historically, issuers have rarely issued information requiring ISS to issue an update warranting an alert to
shareholders.
Interactive Advisors will neither advise nor act on behalf of any client in legal proceedings involving companies whose
securities are held or were previously held in the client’s account, including but not limited to, the filing of “Proofs of Claim”
in class action settlements.
Fund Clients
The Multi-Manager Funds’ proxy voting policy is that each Third-Party Sub-Advisor will vote on behalf of its Sub-Account
all proxy proposals, amendments, consents or resolutions (collectively, “Proxies”), in accordance with its own proxy voting
policies and procedures and in parallel with its Flagship Fund; provided that such Third-Party Sub-Advisor will comply as
promptly as practicable with any instructions as to the handling of such matters received from Interactive Advisors. Generally,
investors in the Fund Clients may not direct a Third-Party Sub-Advisor’s vote in a particular solicitation.
Item 18: Financial Information
Interactive Advisors does not require or solicit the prepayment of its advisory fees, and does not have any adverse financial
condition or financial commitment that is reasonably likely to impair its ability to meet contractual and fiduciary commitments
to clients and Fund Clients. Interactive Advisors has never been the subject of a bankruptcy proceeding. Interactive Advisors
is not self-sustaining through its advisory fee revenue alone, and is financially supported by its ultimate parent IBG LLC,
through periodic capital contributions and unsecured loans. Clients may obtain information about the financial condition of
Interactive Brokers Group, Inc. by visiting the Group’s website at https://investors.interactivebrokers.com/ir/main.php and
https://www.interactivebrokers.com/en/index.php?f=559
Item 19: Requirements for State-Registered Advisers
Because our principal place of business is outside the U.S., in the United Kingdom, and we are an investment adviser registered
with the SEC, Interactive Advisors is not required to register with the individual states. Interactive Advisors qualifies to register
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directly with the U.S. Securities and Exchange Commission. However, Interactive Advisors makes notice filings in states that
require such notice under state “Blue Sky” laws.
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This brochure supplement provides information about John Dahlstrom that supplements Interactive Advisors’
brochure. You should have received a copy of that brochure. Please contact us at 1-866-825-3005 if you did not receive
Interactive Advisors’ brochure or if you have any questions about the contents of this supplement. Additional
information about John Dahlstrom is available on the SEC’s website at www.adviserinfo.sec.gov.
Part 2B: Brochure Supplement - John Dahlstrom
Covestor Limited doing business as “Interactive Advisors”, “Interactive Advisers,” “Interactive
Brokers Asset Management”, “IB Asset Management”, and “IBKR Asset Management”
Boston Office:
100 Summer Street
Floor 16 - Interactive Advisors
Boston, MA 02110
866-825-3005 x 716
London Office:
Floor 12, 20 Fenchurch Street
London EC3M 3BY
United Kingdom
+44 (203) 787-9250
Website: https://interactiveadvisors.com
February 3, 2026
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John Dahlstrom, Director, Manager/Client Relations
Born
1982
Educational Background
Suffolk University, 09/2000 to 05/2004, B.A. – Finance
Business Experience
Covestor doing business as Interactive Advisors, Client Adviser, 07/2015 – present
NGAM - Investment Consultant - 03/2011 - 07/2015
MSSB - Client Service Associate - 06/2003 - 02/2011
Professional Certifications
FINRA Series 7, 63 and 66.
John is supervised by Sanjoy Ghosh, Chief Investment Officer. He reviews John’s work
on an ongoing basis along with John’s activities through our investment management
systems. All inquiries should be directed to Sanjoy Ghosh at 866-325-3005 x 702.
Disciplinary Information
None
Other Business Activities
None
Additional Compensation
None
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This brochure supplement provides information about Jennifer Mitton that supplements Interactive Advisors’
brochure. You should have received a copy of that brochure. Please contact us at 1-866-825-3005 if you did not receive
Interactive Advisors’ brochure or if you have any questions about the contents of this supplement. Additional
information about Jennifer Mitton is available on the SEC’s website at www.adviserinfo.sec.gov.
Part 2B: Brochure Supplement - Jennifer Mitton
Covestor Limited doing business as “Interactive Advisors”, “Interactive Advisers,” “Interactive
Brokers Asset Management”, “IB Asset Management”, and “IBKR Asset Management”
Boston Office:
100 Summer Street
Floor 16 - Interactive Advisors
Boston, MA 02110
866-825-3005 x 713
London Office:
Floor 12, 20 Fenchurch Street
London EC3M 3BY
United Kingdom
+44 (203) 787-9250
Website: https://interactiveadvisors.com
February 3, 2026
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Jennifer Mitton, Director, Investor Relations
Born
1988
Educational Background
Bates College, Boston, BA, Psychology, 2007 - 2011
Harvard Extension School, Masters of Finance, 2013 - 2016
Business Experience
Covestor doing business as Interactive Advisors,
Investor Relations, 03/2020 – present
Loomis Sayles - Portfolio Analyst - 06/2018 - 02/2020
Harbourvest Partners - Portfolio Data Analyst - 05/2016 - 06/2018
Advantage Data - Fixed Income Analyst - 12/2014 - 05/201
Professional Certifications
FINRA Series 65
Jennifer is supervised by Sanjoy Ghosh, Chief Investment Officer. He reviews
Jennifer’s work on an ongoing basis along with Jennifer’s activities through our
investment management systems. All inquiries should be directed to Sanjoy Ghosh at 1-
866-825-3005 x 702.
Disciplinary Information
None
Other Business Activities
None
Additional Compensation
None
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This brochure supplement provides information about Sanjoy Ghosh that supplements Interactive Advisors’ brochure.
You should have received a copy of that brochure. Please contact us at 1-866-825-3005 if you did not receive Interactive
Advisors’ brochure or if you have any questions about the contents of this supplement. Additional information about
Sanjoy Ghosh is available on the SEC’s website at www.adviserinfo.sec.gov.
Part 2B: Brochure Supplement - Sanjoy Ghosh
Covestor Limited doing business as “Interactive Advisors”, “Interactive Advisers,” “Interactive
Brokers Asset Management”, “IB Asset Management”, and “IBKR Asset Management”
Boston Office:
100 Summer Street
Floor 16 - Interactive Advisors
Boston, MA 02110
866-825-3005 x 702
London Office:
Floor 12, 20 Fenchurch Street
London EC3M 3BY
United Kingdom
+44 (203) 787-9250
Website: https://interactiveadvisors.com
February 3, 2026
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Sanjoy Ghosh, Chief Investment Officer
Born
1973
Educational Background
Colgate University, B.A., Economics and Math, 1992 - 1996
Wharton, University of Pennsylvania, M.A, and Ph.D, Finance, 1996 - 2000
Business Experience
Covestor Ltd doing business as Interactive Advisors,
Chief Investment Officer, 05/2013 – Present
Panagora Asset Management, Director, Equities, 7/2004 - 4/2013
Professional Certifications
FINRA Series 65
Disciplinary Information
None
Other Business Activities
None
Additional Compensation
None
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This brochure supplement provides information about Bimal Shah that supplements Interactive Advisers’ brochure.
You should have received a copy of that brochure. Please contact us at 1-866-825-3005 if you did not receive Interactive
Advisors’ brochure or if you have any questions about the contents of this supplement. Additional information about
Bimal Shah is available on the SEC’s website at www.adviserinfo.sec.gov.
Part 2B: Brochure Supplement - Bimal Shah
Covestor Limited doing business as “Interactive Advisors”, “Interactive Advisers,” “Interactive
Brokers Asset Management”, “IB Asset Management”, and “IBKR Asset Management”
London Office:
Floor 12, 20 Fenchurch Street
London EC3M 3BY
United Kingdom
+44 (203) 787-9250
Boston Office:
100 Summer Street
Floor 16 - Interactive Advisors
Boston, MA 02110
866-825-3005
Website: https://interactiveadvisors.com
February 3, 2026
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Bimal Shah, Chief Technology Officer
Born
1969
Educational Background
King’s College, University of London, B.Sc. (1st Hons.),
Physics and Computer Science, 1986 - 1989
Queen Mary University of London, M.Sc. (Distinction),
Computer Science, 1989 - 1990
Business Experience
Covestor Ltd doing business as Interactive Advisors,
Chief Technology Officer, 09/2008 – Present
Betfair, Engineering and Product Manager, 04/2005 - 08/2008
Thinkingcap Technology, Founder, 01/1999 - 03/2005
D.E.Shaw & Co., Group Manager and Architect, Financial Data, 10/1996 - 12/1998
Accenture, Consultant and Manager, 01/1991 - 09/1996
Disciplinary Information
None
Other Business Activities
None
Additional Compensation
None
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