Guided Investing Disclosure

Risk Questionnaire, Portfolio Selection and Ongoing Management

The Guided Investing Program is designed to provide a way for individuals to invest money and access our advisory services, along with brokerage and custody services, for a single fee. The Program offers investment advice and delivers advisory services to you primarily through the use of a Risk Questionnaire online.

Through the online Risk Questionnaire, we gather information from you regarding your current financial status, investment experience, future goals, investment objectives, and attitudes towards risk. Our recommendation to you will be based solely on your responses to the Risk Questionnaire and not on any other information you provide in your application to open the account.  Because our advice is based solely on your responses to the Risk Questionnaire, it is very important you read each risk question carefully.  There is information available on the page with the risk question that provides additional information on the risk question and how it impacts your investments. 

We will identify the appropriate asset allocation consistent with your responses to the Risk Questionnaire. Based on your responses, you will be presented a recommended Portfolio. You will be able to select a Portfolio that is more aggressive by one asset allocation category or less aggressive by one asset allocation category.  If you choose to deviate from the Recommended Portfolio and select a more or less aggressive Portfolio you understand the selected Portfolio may not align with the asset allocation category corresponding to your responses to the Risk Questionnaire and that the Portfolio you select may perform worse over any time period than the Recommended Portfolio or any other investment.

All Portfolios offered in the Guided Investing program invest solely in exchange-traded funds (“ETFs”).  ETFs are funds that trade on a stock exchange and can invest in many different individual stocks, bonds, or other asset types. ETFs are designed to track the performance of a specific market index or sector. ETFs allow you to diversify your investments without buying all of the individual companies that ETFs purchase.

The current allocation of ETF holdings in each Portfolio is available to you in the system at the time they are presented, and you should review the allocation prior to selecting the model. If you do not believe one of the recommended models is appropriate for you, you can update your responses to the questionnaire.

Copper Financial provides ongoing portfolio management over your Guided Investing accounts by monitoring the underlying investments in your account and entering trades to rebalance the underlying investments to bring your account in line with the model you selected. We manage these advisory accounts on a discretionary basis which means we have the authority to trade or rebalance your accounts without prior consent from you within the model you have chosen. The specific allocations within each underlying investment can vary by +/- 5% of the target allocation.

The trading in your Guided Investing account will have tax consequences if your account is a taxable account (e.g., individual account or joint account). 

To inquire about imposing reasonable restrictions on your Portfolio after opening your account, contact us at digital@cu.financial or 833.605.6681.

Fractional Shares

Guided Investing utilizes fractional shares when allocating among the underlying investments within your selected model. Fractional shares are illiquid outside of the Guided Investing program and cannot be transferred to another firm. If you attempt to transfer fractional shares to another, any fractional shares will be liquidated and the cash proceeds transferred out to the receiving firm.

Fees

Guided Investing accounts are assessed an asset-based program fee of 0.25% per year by Copper Financial.  We will deduct the fee from your Guided Investing account each month. 

The program fee does not include or cover transfer taxes, fees and or taxes assessed by state and federal governments or agencies thereof. Our program fee also does not cover administrative or account maintenance fees including, but not limited to, fees for electronic funds transfers, wire transfers, checks, annual IRA account maintenance fees, outgoing account transfer fees, account closing fees, the SEC Section 31 fee, or the FINRA Trading Activity Fee. The full list of the applicable fees can be found within the Copper Financial Brokerage Fee Schedule maintained at cu.financial/disclosures/.

In addition to the program and other fees described above, you will also incur certain fees charged by exchange-traded funds which are disclosed in the applicable prospectus. Examples of these fees include administrative expenses, internal management fees, and other service fees. For more information about these fees please read the summary or full prospectus or disclosure document for each ETF. Copper Financial does not receive a portion of these fees.

See the Guided Investing Wrap Fee Program Brochure (ADV Part 2A Appendix 1) for additional information on the fees assessed in Guided Investing accounts.