Sootchy is a registered investment adviser (“RIA”) with the U.S. Securities and Exchange Commission and, as such, we provide advisory services rather than brokerage services. Investment advisory and brokerage services and fees differ, and it is important for you to understand these differences. Additionally, free and simple tools are available to research firms and financial professionals at Investor.gov/CRS which also provides educational materials about broker-dealers, investment advisers, and investing. This document is a summary of the services and fees we offer to “retail” investors, which are natural persons who seek or receive services primarily for personal, family, or household purposes.
What investment services and advice can you provide me? The Advisory Service is intended to be used by college savers who desire to save for qualified higher education expenses through a qualified tuition program (commonly referred to as a 529 Plan) and require assistance selecting an investment within the 529 Plan (the “Advisory Service”). The Advisory Service is delivered through the Sootchy website at https://www.sootchy.com/. Regular and continuous Internet access is required to enroll in the Advisory Service, to receive services and to access all documents. The minimum necessary to open an account with Sootchy (the “Account”) is the minimum necessary to open an account with the 529 Plan.
The Advisory Service will use an algorithm to recommend a portfolio for you within a 529 Plan selected by Sootchy (the “529 Plan”). The Advisory Service is not a comprehensive investment advisory service or a complete financial plan. In making its recommendations, Sootchy does not take into account other aspects of your financial or tax situation. The 529 Plan is not affiliated with Sootchy and is not responsible for recommendations made by Sootchy or the operation of the Advisory Service. In the future, the Advisory Service may include other Section 529 Plans that meet the Investment Adviser’s investment screening criteria.
If you enroll in the Advisory Service, Sootchy’s proprietary algorithm will identify and propose an existing Portfolio within the 529 Plan using the information you provided during the enrollment process and, when applicable, certain assumptions about your financial situation, investing experience, and investment knowledge. Sootchy will oversee the algorithm but will not monitor each client’s Account. Our investment advisory service is non-discretionary. The Advisory Service helps identify an investment within the 529 Plan consistent with your risk tolerance, investment horizon, and other information you provide during the enrollment process. You have an obligation to update your information through our website whenever it changes materially.
Whether you invest in the portfolio in the 529 Plan, implementation of our recommendation(s) is your responsibility. You make the ultimate decision as to whether to invest in the 529 Plan. If you invest in a different portfolio within the 529 Plan or another college savings program the performance of such Portfolio will differ from the performance of the portfolio Sootchy recommends. More information regarding our services, fees and other disclosures can be found in our Part 2A by clicking this link https://adviserinfo.sec.gov/firm/brochure/307621.
• “Given my financial situation, should I choose an investment advisory services? 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? You agree to pay a flat/fixed advisory fee per Account. The fee is deducted on a monthly basis from your client Account or your 529 Plan account. The advisory fee you pay covers the ongoing management of your client Account, including the technology platform that delivers the Advisory Services and communications to keep you informed about your client Account(s). The annual advisory fee does not cover fees and expenses charged by the 529 Plan. 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 regarding fees, refer our Form ADV Part 2A by clicking this link https://adviserinfo.sec.gov/firm/brochure/307621. Please see Sootchy.com/529 Plan for more information on fees and expenses charged by the 529 Plan.
• “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 are some examples to help you understand what this means. • Sootchy makes money helping you select a portfolio within the 529 Plan. - While in our judgment the 529 Plan is appropriate for college savers this creates an incentive for us for you to invest in the 529 Plan as opposed to other qualified tuition programs and savings products that may be available to you.
• “How might your conflicts of interest affect me, and how will you address them?”
How do your financial professionals make money? Our Company and the financial professionals servicing your account(s) are compensated through salary and either an annual bonus or variable compensation based on their performance – not based on the number of individuals that open accounts.
Do you or your financial professionals have legal or disciplinary history? Yes, these events are disclosed in the specific individual’s Form U4. Their documents can be found by going to Investor.gov/CRS.
• As a financial professional, do you have any disciplinary history? For what type of conduct?”
Additional Information For more information about our investment advisory services and to request a copy of the relationship summary contact us at 310-807-0140 or click the link provided https://adviserinfo.sec.gov/firm/brochure/307621.
▪ “Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?”
*To review the answers to our conversation starters, please review our website at https://www.sootchy.com/.
Last updated: 30/06/2020