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?


Informational Advisory Services: We collect and analyze the data on your investment interests and risk profile. For all securities on our platform, we provide key fundamental and technical information as well as a Match Score calculated for a particular investor. 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. Furthermore, we create model portfolios (Thematic Trading Fractionals or TTFs) that comprise securities relevant to a certain investment topic and optimized using our proprietary optimization algorithm based on the risk-parity approach.

Portfolio Management Services: We offer portfolio management services through a fee program ("Program") as described in the program brochure to retail clients. We are the sponsor and investment advisor for the Program. A fee program is a type of investment program that provides clients with discretionary investment advisory and execution services for a fee calculated based on the market value of their accounts advised by Gainy. We have limited discretionary authority to choose, buy or sell securities for your account. You may choose one or several model portfolios (TTFs) that you want to be created in your accounts. Gainy, on your behalf, will buy the corresponding fractional shares to closely recreate the model portfolios in your account and will automatically rebalance them when model portfolios change or if your portfolio deviates from the model one.

We have designed our services for a very broad scope of investors. Although we do our best to incorporate the information on your interests and risk tolerance into our recommendations, not all recommendations generated by our algorithm may be applicable to your financial profile. But all recommendations are supported by the mechanics of our proprietary algorithm. Therefore, we encourage you to derive your own conclusion on the suitability of certain investments to your particular financial situation.

For additional information, please see our Form ADV Part 2A brochure 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?


Portfolio Management Services: Gainy offers its portfolio management fee program on a monthly fee basis, which is an annual percentage rate charged on the total assets managed by Gainy for you. Our Advisory fee rate is 1% of assets under management per year. This fee is calculated based on the account market value each day and paid at the end of the month. Depending on your choice and the availability of funds in your account, fees will be deducted from the client’s account or charged to your linked account. This fee includes all trading costs, i.e. commissions. However, there may be other third party fees, e.g. exchange fees, banking fees, etc. that you will still need to pay.

Informational Advisory Services: For smaller accounts, with a total value of less than $10 000, instead of a portfolio management fee, we charge the minimum fee of $100 per year to compensate Gainy for providing informational advisory services. This fee is also calculated on a daily basis based on the total value of assets under management and charged at the end of the month.

Asset-based fees associated with program will include most transaction costs and fees to the broker/dealer/custodian that has custody of the assets, and therefore may be higher than a typical asset-based advisory fee.

For additional information, please see 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 must 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 are some examples to help you understand what this means.

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.

The more assets there are in your advisory account, the more you will pay in fees, and the firm may therefore have an incentive (conflict of interest) to encourage you to increase the assets in your account.

For additional information, please see 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 www.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 +1(650) 636-6395.

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?