Introduction


Our firm, Gainy, Inc., is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser.  Brokerage and investment advisory services and fees differ, and it is important for a retail investor to understand the differences.  Free and simple tools are available to research firms and financial professionals at the SEC’s investor education website, Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.

What investment services and advice can you provide me?


We provide informational advisory services to retail investors. We do not buy or sell securities for you or otherwise manage or monitor your investments. As we do not manage your assets, there is no minimum account sized required to begin or maintain a relationship with our firm.  If you wish to execute the purchase or sale of any particular security, you must work with a financial intermediary to do so. We provide you with analysis and personalized selections of equity securities, exchange-traded funds (“ETFs”), and cryptocurrencies. Our advisory services are limited to these investment types. We utilize a proprietary algorithm to generate a selection of investments that match your interests and goals and to provide you with data and analysis concerning that selection.

For additional information, please see our Form ADV Part 2A brochure, specifically Items 4 and 7, for more detailed information about the services we offer.

Conversation Starters. Follow-up questions to ask your financial professional:
Given my financial situation, should I choose an investment advisory service? Why or why not?
• How will you choose investments to recommend to me?
• What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?

What fees will I pay?


We exclusively offer a subscription service, which grants you access to our services. You pay in advance for our services at rates that depend on the duration of access desired.  Those rates are as follows:

• Weekly Access:  $4.99 billed once every week.
• Monthly Access: $9.99 billed once every month.
• Semi-Annual Access: $49.99 billed once each six months.
• Annual Access: $89.99 billed once each year.

Clients new to our subscription service are offered a 7-day free trial. You are required to provide billing information for this 7-day free trial period and are billed automatically at the end of the free trial period if you do not cancel your selection subscription before the trial period ends. Once you have enrolled in our subscription service, you can cancel at any time.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

For additional information, please see Item 5 of our Form ADV, Part 2A.

Conversation Starter. Ask your financial professional-
Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?


When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you.

Here is an example to help you understand what this means. Our firm provides informational advisory services; we do not buy or sell securities for you or otherwise manage your assets. Because of our fixed fee subscription service, we have designed our services for a very broad scope of investors. Not all recommendations generated by our algorithm may be applicable for your financial profile. But all recommendations are supported by the mechanics of our proprietary algorithm.

For additional information, please see Item 10 of our Form ADV, Part 2A.

Conversation Starter. Ask your financial professional-
How might your conflicts of interest affect me, and how will you address them?

How do your financial professionals make money?


Our financial professionals are compensated via a salary and bonus. Such compensation is based on factors such as revenue growth. Other than as described herein, these payments to our financial professionals do not create any additional conflicts of interest.

Do you or your financial professionals have legal or disciplinary history?


No. You can visit Investor.gov for a free and simple search tool to research our firm and our financial professionals.

Conversation Starter. Ask your financial professional-
• As a financial professional, do you have a disciplinary history? For what type of conduct?

Additional Information


We encourage you to seek out additional information.

For additional information on our advisory services, see our Form ADV brochure on IAPD, on investor.gov, or on our website www.gainy.app. To request up-to-date information or a copy of the relationship summary please call us at (650) 580-9174. Answers to our conversation starter questions can be found at https://www.gainy.app/starter-questions.

Conversation Starter. Ask your financial professional-
• Who is my primary contact person? Is he or she a representative of an investment adviser? Who can I talk to if I have concerns about how this person is treating me?