Legal & Privacy Documents
General disclosures
Privacy policy
Terms of service
Investment advisory agreement
Form ADV Part 2A Wrap Program Brochure
Form CRS
General Disclosures
Updated as of March 26, 2024
Plenty was founded to democratize access to financial products and tools that accelerate wealth building. Plenty Financial, Inc. (“Plenty Financial”) provides a web, mobile, personal financial management and educational platform to consumers; some of these tools are freely accessible to all consumers, others require a fee-based subscription. Wholly owned subsidiary Plenty Financial RIA, LLC (“Plenty RIA”) leverages industry-leading technology to provide advisory services (“Advisory Services” or “Services”) in the form of software-first financial planning and investment advisory services for fee-based Subscribers. You should not construe the contents of any presented materials as legal, tax, investment or other advice.
Plenty RIA partners with Atomic Invest LLC (“Atomic Advisors”), an SEC-registered investment advisor, to manage and execute our investment offerings; Atomic Advisors is Plenty’s sub-adviser. Neither Atomic Invest nor Atomic Brokerage, LLC (FINRA registered broker-dealer and member of SIPC), nor any of their affiliates is a bank. All investments made are legally owned by you. Investment accounts are not bank guaranteed or FDIC insured and may lose value. Before investing, consider your investment objectives and Plenty Financial and Plenty RIA’s fee structure. Advisory services are not intended to provide tax advice or financial planning advice for every aspect of a client’s financial situation and do not include investments that clients hold outside of Plenty’s accounts. Custodial clearing, execution, and other brokerage services are provided to Atomic Invest by Pershing LLC, one of the world’s largest securities servicing companies. For the avoidance of doubt, Plenty RIA does not utilize Atomic Brokerage for its client accounts.
Performance & Tax-Loss Harvesting Impact Disclosures
Comparisons to existing ETFs or indices are provided for illustrative purposes. Performance information provided is based on rigorous backtesting of trading algorithms using historical data derived from third-party sources that Plenty RIA believes to be reliable. Plenty Financial does not guarantee the accuracy of Site information and may receive inaccurate information from third-party sources. Historical performance is not indicative nor guarantees current or future performance. All information disclosed in presented materials are for illustrative purposes only and are not to be construed as specific advisory recommendations.
Portfolio information is presented net of all advisory fees and expenses (the “wrap fee”) associated with maintaining an account with Plenty RIA; commissions and other brokerage/custodial costs are included in the wrap fee. For all periods the performance information includes the reinvestment of dividends and interest unless otherwise noted. For the avoidance of doubt, the wrap fee does not include separate subscription fees for services provided by Plenty Financial.
Investing is inherently risky and Plenty Financial does not guarantee positive performance. Different assumptions will lead to different results. There is no assurance that an investor’s investment objectives will be met or that investors will receive a return on their capital. Investors may experience possible loss of principal. Investment performance is subject to volatility. Investors must read and acknowledge all risks before making the final decision to proceed with an investment. Investors are advised to consult additional legal, accounting, or tax advisors for legal, business, tax or related matters concerning the information in this document to make an independent determination of investment fit and consequences of a potential investment at US federal, state, local, or non-US tax consequences.
Plenty RIA does not offer tax advice or tax accounting matters to clients. Investors should not construe the tax-loss harvesting feature of the company’s services as legal or tax advice. Performance of tax-loss harvesting offerings are estimates provided based on client provided income information; there is no guarantee of completeness or accuracy of information that client provides.
Tax-loss harvesting: Tax-loss harvesting involves certain risks, including the risk that the new investment could have higher costs than the original investment and may introduce portfolio tracking error into your accounts. There may also be unintended tax implications. Prospective Clients should consult with their tax or legal advisor prior to engaging in any tax-loss harvesting strategy. Neither Plenty nor its subadvisor provide tax or legal advice. Tax-loss harvesting may not be suitable for every investor and may have limited or no impact in retirement accounts. For example, tax-loss harvesting may not materially benefit investors in low income tax brackets.
Tax-loss harvesting and wash sale rule: The wash sale rule prohibits the realization of a loss from selling a security if a “substantially identical” security is purchased 30 days before or after the sale. The wash sale rule also applies when the purchase is made in a different account or even the account of a spouse. In general, tax-loss harvesting seeks to avoid potential wash sales. Tax-loss harvesting techniques implemented by the subadvisor are not able to avoid wash sales associated with assets held or transactions conducted in accounts that are held outside of Plenty. This limitation includes outside accounts that may be linked in Plenty’s website for planning purposes, but that are not connected for Plenty to provide investment advice. Although the tax-loss harvesting algorithm available through the subadvisor seeks to avoid wash sales, situations may occur where tax-loss harvesting may result in a wash sale. Clients are responsible for their own analysis of whether wash sales may have occurred across the totality of their accounts.
ETF Disclosures
Investment recommendations may include the use of exchange-traded funds (ETFs) which are subject to market risk, including loss of principal. An ETF typically includes embedded expenses that may reduce the fund’s net asset value, and therefore directly affect the fund’s performance and indirectly affect a client’s portfolio performance or an index benchmark comparison. Expenses of the fund may include management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Furthermore, ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. ETFs used in portfolio recommendations are high liquidity ETFs with loss expenses and low tracking error but performance is not guaranteed.
Non-Deposit Products
Investments described on this website are NOT FDIC INSURED nor are they insured by any other governmental agency or instrumentality. Investments on this website MAY LOSE VALUE and they are not obligations, guarantees and are NOT BANK GUARANTEED.
Fee and Account Disclosure
Client fees are charged in two parts: 1) An ongoing software subscription fee, 2) Variable advisory fees for assets under management. Plenty RIA compensates sub-advisors for investment management and execution. There is a chance that Plenty RIA’s fees offset returns.
Advisory Services
Plenty engages a sub-advisor to provide investment products. All investment accounts are held at BNY Mellon’s Pershing LLC. For more details about Atomic Invest, please see the Form CRS, Form ADV Part 2A, the Privacy Policy, and General Disclosures.
Interactive Educational Analysis Tools using Hypothetical Performance for Financial Planning
Plenty Financial intends to accelerate clients’ reaching discrete financial goals. Plenty Financial’s platform is not intended to provide comprehensive investment advice for every aspect of a client’s financial situation and does not incorporate investments that clients hold elsewhere. Additionally, Plenty Financial’s platform does not pro actively assess and understand information that a client may not have disclosed. As a result, any suggested tips or educational tooling cannot guarantee the completeness of information used.
Plenty Financial provides educational tools for financial planning; these are intended to be for illustrative purposes. Information provided are “forward-looking” details that are inherently unreliable and actual events or results may differ materially from those reflected here. Plenty Financial does not make any assurance or guarantees as to the accuracy of any estimates or calculations provided by the educational tools. Plenty Financial uses client or third party information for forward-looking calculations but cannot guarantee the accuracy and completeness of information provided by clients or third parties. Plenty Financial does not provide tax advice and recommends that individuals consult with additional tax advisors.
Our Interactive educational analysis tools contain inherent limitations and are not a substitute for actual investment returns derived from a live portfolio. There are numerous risk factors related to trading and markets which cannot be fully accounted for when modeling hypothetical future performance. Consequently, future returns are not guaranteed, and a loss of principal may occur. In addition, results may vary with each use and over time.
Our interactive tools are not a recommendation for any security or investment. References to any investments are intended to illustrate the application of the investment process only and should not be used as the basis for making any decision about purchasing, holding or selling any securities. A sample portfolio is used in the tool but completing an actual investment requires a client to select and confirm a model portfolio that may differ from the portfolio shown in the interactive tool. This Interactive Analysis Tool contains inherent limitations and is not a substitute for actual investment returns derived from a live portfolio. There are numerous risk factors related to trading and markets which cannot be fully accounted for when modeling hypothetical future performance. Consequently, future returns are not guaranteed, and a loss of principal may occur. In addition, results may vary with each use and over time. Please see Plenty Financial’s general disclosures for the full set of disclosures.
Return data used in the interactive tool are hypothetical performance data which contains inherent limitations and is not a substitute for actual investment returns derived from a live portfolio. There are numerous risk factors related to trading and markets which cannot be fully accounted for when depicting Hypothetical Performance. Consequently, future returns are not guaranteed, and a loss of principal may occur.
The Tool depicted assumes the following:
A steady contribution rate (set by you)
an annual rate of return of x% per year (based on a risk level you select)
Including a reinvestment of interest and dividends
Excluding taxes, transaction fees, management fees, and other factors which might impact results
Further, any investing strategy involves legal, regulatory, macroeconomic, liquidity and other risks which could negatively impact returns. Similarly, operational risk, such as business continuity risk could negatively affect investment results. Further, opportunity risk exists insofar as other investments may have similar or superior characteristics.
The annual return rates that we use for various portfolio compositions are based on a 10 year hypothetical back test comparison. The analysis is based on historical returns; past performance does not guarantee future results. The Analysis includes dividends and interest, but excludes taxes, transaction fees, management fees, and other factors which would impact results. Results assume rebalancing on the last trading day of each quarter and immediate reinvestment of dividends. Policy benchmarks are MSCI ACWI for equity strategy and Bloomberg Barclays US Aggregate for fixed income strategy.
Hypothetical returns in interactive tools - classic portfolios
This interactive tool includes an analysis that is intended to illustrate the hypothetical performance of various multi-asset-class model portfolios for the time periods ending on 12/31/2023 based on historical performance. It does not imply actual performance of a client portfolio or guarantees future results.
The analysis uses a 10-year historical backtest of a portfolio comprised of exchange traded funds (ETFs). The use of a 10 year historical backtest is a limitation given that the interactive tool does not show other return time frames where returns would differ from the returns presented (i.e. 1 and 5 year). The ETFs in the analysis include an allocation to iShares Core S&P 500 ETF (IVV), SPDR MSCI ACWI ex-US ETF (CWI), and iSHARES Core US Aggregate Bond ETF (AGG). Returns may differ if different ETFs or investments are used in the analysis. The analysis uses IVV for its allocation to US equities, CWI for its international equity allocation and AGG for its fixed income and cash allocation. These ETFs were chosen given that they are widely utilized ETFs and represent a focus on either U.S. equities, international equities, and fixed income. Other investments not considered may have characteristics similar or superior to those being analyzed. Returns shown reflect portfolios ranging from most conservative (risk score 0) to highly aggressive (risk score 10). Results may vary with each member and usage over time.
Total Gross Return by NAV: Total return represents changes to the NAV and accounts for distributions from the fund. The figures are pre-tax and net of fund expenses. Note that the analysis does not account for asset-based and/or subscription fees from Plenty, all of which would lessen the return shown in the results.
Total Net Return by NAV: Total net return is calculated based on Total Gross Return net of 0.20% of management fee from Plenty. Note this return does not deduct the $100 annual subscription fee collected by Plenty Financial, Inc., which would lessen the return shown in the results.
Marketing and Social Media
All statements made through marketing material and social media sites that mention Plenty Financial or are sponsored/maintained by Plenty Financial and its affiliates are not intended as investment, tax, or legal advice. Plenty Financial and its affiliates are not responsible for and do not endorse the content by other users or followers of the social media sites sponsored or maintained by Plenty Financial or its affiliates. Plenty Financial and its affiliates are also not responsible for the terms of use or privacy or security policies of any social media sites, and you use such sites at your own risk. Plenty Financial and its affiliates reserve their rights to block any user or follower who posts, tweets or retweets content that is deemed inappropriate or offensive or constitutes spam, a testimonial, advice, recommendation, or advertisement for securities, products, or services or is promotional in nature. Plenty Financial and its affiliates also reserve their rights to block users or followers whose posts, tweets or retweets contain offensive or inappropriate content or serve as promotional sites. Any opinions expressed by our users or followers are those of the persons submitting the comments and don't necessarily represent the views of Plenty Financial or its affiliates. Testimonials are not a guarantee of future performance or success.
Limitation of Liability
Plenty Financial and its affiliates and its and their respective employees, officers, directors, partners, agents, representatives, suppliers and service providers shall not be liable for any damages of any kind arising from or in connection with the use of the online platform, including mistakes, omissions, interruptions, deletion of files or email, errors, defects, viruses or delays in operation or transmission, even if they are expressly advised of the possibility of such damages. This is a comprehensive limitation of liability that applies to all damages of any kind, including compensatory, direct, indirect, punitive, special, incidental, or consequential damages, including but not limited to damages for lost profits, loss or inaccuracy of data or loss of revenue.
YOU AGREE THAT ALL CAUSES OF ACTION ARISING OUT OF OR CONNECTED WITH THE ONLINE PLATFORM SHALL BE RESOLVED INDIVIDUALLY, WITHOUT RESORT TO ANY FORM OF CLASS ACTION, AND THAT YOUR SOLE REMEDY IS TO CEASE USE OF THE ONLINE PLATFORM.
Some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages. In such jurisdictions, our liability is limited to the greatest extent permitted by law. While Plenty Financial endeavors to ensure that the online platform is available at all times, it will not be liable if, for any reason, this Site is unavailable at any time or for any period.
Indemnification
By accessing and using the online platform and Content, you agree to indemnify, defend and hold harmless Plenty Financial (specifically including its officers, directors, owners, partners, employees, agents, information providers, licensors and licensees) (collectively, the “Indemnified Parties”) from and against any and all claims, losses, costs and expenses (including attorneys’ fees) arising out of or relating to (a) any breach (or claim, that if true, would be a breach) by you of these General Disclaimers and (b) your use of or activities in connection with the online platform. We reserve the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. You shall not enter into any settlement agreement which affects the rights of any of the Indemnified Parties or requires the taking of any action by any of them, without our prior written approval.
Website Subject to Change
Plenty Financial reserves the right to amend or revise any information or documents contained on this website at any time without notice. The information and documents contained on this website relate only to the dates indicated therein and may not be accurate as of any subsequent date. Plenty Financial does not undertake any obligation or assume any responsibility to update any such information.
Links to Other Sites
The online platform contains links to other independent third-party web sites, and we provide links to third-party websites as part of the Services (in all cases “Linked Sites”). These Linked Sites are provided solely as a convenience to you. Such Linked Sites are not under our control, and we are not responsible for and do not endorse the content of such Linked Sites, including any products, information or materials contained on such Linked Sites. You will need to make your own independent judgment regarding your interaction with these Linked Sites. We accept no responsibility for reviewing changes or updates to, or the quality, content, policies, nature or reliability of third-party web sites or applications. You should review applicable terms and policies, including privacy and data gathering practices of third-party web sites, which may materially differ from those of Plenty Financial, and should make whatever investigation you feel necessary or appropriate before proceeding with any transaction with any third-party.
Consent to Electronic Records and Signatures
Required documents are provided electronically through this application. By agreeing to the terms within the advisory agreement, you are consenting and acknowledge the delivery of the Plenty RIA’s Form CRS, Plenty RIA’s ADV Part 2, Plenty Financial’s privacy policy, Atomic Advisor’s Form CRS, Atomic Advisor’s ADV Part 2, and Atomic Advisor’s Privacy notice and providing signatures electronically where required. All materials in this site are meant to be reviewed in their entirety, including any footnotes, legal disclaimers, restrictions or disclosures, and any copyright or proprietary notices. Any disclaimers, restrictions, disclosures or hedge clauses apply to any partial document or material in the same manner as they do to the whole, and will be deemed incorporated in the portion of any material or document that you consult or download.
Plenty Privacy Policy Notice
Updated as of November 9th, 2022
Back to Top ^
Your privacy is important to us. At Plenty, we seeks to protect the privacy of individuals who use our products. This privacy notice intends to help you understand how Plenty Financial, Inc. and its affiliates (“Plenty”) collects, uses, and shares your personal information and to help you understand and exercise your rights. To make this Privacy Notice easier to read, our websites, applications, and other offerings are collectively called “Services.”
Please read this “Privacy Policy Notice” carefully to understand what we do.
Plenty does not disclose nonpublic personal information about its prospective, existing or former customers to third parties other than as described below.
Personal information we collect. Plenty collects information about you purely to improve the quality of products and services that we offer to you. We will never sell your data and rigorously protect the usage of any data you provide.
Plenty collects personal information to provide affordable access to financial planning tools and investment management services. We collect personal profile data including your name, contact information, date of birth, and SSN in order to meet legal requirements to provide investment offerings to you. We collect information about your goals and aspirations in order to create a plan to help you reach them. We collect information about your risk tolerance to provide a suitable investment portfolio. Payment information we collect enables us to be paid for our services and offering. Your account balance and transaction data is collected to enable us to improve the ‘to do tips’ and enable the tracking and forecasting engine.
We work with a series of service providers to build our offerings. Our service provider for account linking is Plaid (privacy policy here). Our service provider for investment management is Helium Advisers (privacy policy here). Our service provider for billing services is Stripe (privacy policy here).
How Plenty collects this information. Plenty collects this information from you through various digital means. Information will be collected with users manually input personal information through our web app. Information may be automatically collected through cookies (though users may opt out) or use of our Site and Services (ie. pages visited, mouse movements, internet protocol (IP) addresses, etc). . Plenty maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information which Plenty believes are adequate to prevent unauthorized disclosure of such information.
How Plenty uses this information. All financial companies need to share customers’ personal information to run their everyday business and Plenty uses the personal information collected from you for everyday business purposes. These purposes may include for example:
To provide advisory services to you.
To use as inputs in Plenty’s educational financial planning tools.
To improve Plenty’s product offerings for you.
To open an account for you.
To process a transaction for your account.
To market products and services to you.
To respond to court orders and legal investigations.
As an SEC Registered Investment Adviser (RIA), we must ensure that individuals we provide investment services for meet government regulations around Know Your Customer (KYC), Customer Identification Program (CIP), and Anti-Money Laundering (AML).
Sharing data with others. Data may be shared with service providers that Plenty has selected; each service provider has an established and reviewed privacy policy. With explicit request and acknowledgement, individuals may share some or all of your account information with another individual. We enable this through a multiplayer experience where you may invite another individual to your household, such as your partner.
Disclosure to others. Plenty may provide your personal information to firms that assist Plenty in servicing your account and have a need for such information, such as a broker or administrator. Plenty may also disclose such information to service providers and financial institutions with whom Plenty has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you. Plenty requires third-party service providers and financial institutions with which Plenty has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which Plenty discloses the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. Plenty notes that the Federal privacy laws only give you the right to limit the certain types of information sharing that Plenty does not engage in (e.g., sharing any personal information with others in order for them to market to you).
Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
How Plenty protects your personal information. To protect your personal information from unauthorized access and use, Plenty maintains rigorous physical, electronic, and procedural safeguards that comply with Federal law to safeguard nonpublic personal information which Plenty believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secured files and buildings.
Your Privacy Choices and Right. At all times, we preserve privacy choices that you control:
Email Communications: You may opt out of future promotional email notifications at the bottom of each email. You will continue to receive transaction-related emails regarding products you use. You will also continue to receive non-promotional communications about us and our services ie. updates to our Terms of Service or our Privacy Policy.
Text Message: You may opt out of receive text message by responding ‘STOP’ or by contacting us.
Device Notifications: You may opt out of receiving push notifications by changing the setting on your device. With your consent, we may collect location-based information. You may opt out by changing your device settings.
Cookies and Internet-Based Advertising: You may decline the usage of cookies by adjusting your preferences within the device.
Data Retention: Plenty stores collected information for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable law.
California Resident Rights: If you are a California resident, you have the privacy rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us.
California Resident Rights: Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes.
This Privacy Policy Notice relates to the following entities:
Plenty Financial RIA LLC
Who to contact with questions. If you have any questions about this Privacy Notice, please contact the compliance team by email at compliance@withplenty.com.
Terms of Service
Effective date: December 1st, 2022
Back to Top ^
Welcome to Plenty. Plenty was founded to democratize access to financial products and tools that accelerate wealth building. Please read on to learn the rules and restrictions that govern your use of our website(s), products, services and applications (the “Services”). If you have any questions, comments, or concerns regarding these terms or the Services, please contact us at:
Email: support@withplenty.com
Address: 576 Sacramento St, Floor 6 - Plenty, San Francisco, CA 94111
These Terms of Use (the “Terms”) are a binding contract between you and PLENTY FINANCIAL, INC. (“Plenty,” “we” and “us”). Your use of the Services in any way means that you agree to all of these Terms, and these Terms will remain in effect while you use the Services. These Terms include the provisions in this document as well as those in the Privacy Policy. Your use of or participation in certain Services may also be subject to additional policies, rules and/or conditions (“Additional Terms”), which are incorporated herein by reference, and you understand and agree that by using or participating in any such Services, you agree to also comply with these Additional Terms.
Please read these Terms carefully. They cover important information about Services provided to you and any charges, taxes, and fees we bill you. These Terms include information about future changes to these Terms, automatic renewals, limitations of liability, a class action waiver and resolution of disputes by arbitration instead of in court. PLEASE NOTE THAT YOUR USE OF AND ACCESS TO OUR SERVICES ARE SUBJECT TO THE FOLLOWING TERMS; IF YOU DO NOT AGREE TO ALL OF THE FOLLOWING, YOU MAY NOT USE OR ACCESS THE SERVICES IN ANY MANNER.
ARBITRATION NOTICE AND CLASS ACTION WAIVER: EXCEPT FOR CERTAIN TYPES OF DISPUTES DESCRIBED IN THE ARBITRATION AGREEMENT SECTION BELOW, YOU AGREE THAT DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION AND YOU WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION.
Will these Terms ever change?
We are constantly trying to improve our Services, so these Terms may need to change along with our Services. We reserve the right to change the Terms at any time, but if we do, we will place a notice on our site located at withplenty.com, send you an email, and/or notify you by some other means.
If you don’t agree with the new Terms, you are free to reject them; unfortunately, that means you will no longer be able to use the Services. If you use the Services in any way after a change to the Terms is effective, that means you agree to all of the changes.
Except for changes by us as described here, no other amendment or modification of these Terms will be effective unless in writing and signed by both you and us.
What about my privacy?
Plenty takes the privacy of its users very seriously. For the current Plenty Privacy Policy, please click here.
Children’s Online Privacy Protection Act
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from children under 13 years of age; if you are a child under 13 years of age, please do not attempt to register for or otherwise use the Services or send us any personal information. If we learn we have collected personal information from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided us personal information, please contact us at support@withplenty.com.
What are the basics of using Plenty?
You may be required to sign up for an account with your email (“Plenty User ID”), and provide us with certain information or data, such as your contact information. You promise to provide us with accurate, complete, and updated registration information about yourself. You may not provide another person’s name with the intent to impersonate that person. You may not transfer your account to anyone else without our prior written permission.
Additionally, you may be able to access certain parts or features of the Services by using your account credentials from other services (each, a “Third Party Account”), such as those offered by Google or Plaid. By using the Services through a Third Party Account, you permit us to access certain information from such account for use by the Services. You are ultimately in control of how much information is accessible to us and may exercise such control by adjusting your privacy settings on your Third Party Account.
When you “add accounts” as part of the Service, Plenty will connect to a third party financial institution that you identify, for example Plaid. You will need to authorize and permit Plenty’s partners to use and store information submitted by you for Plenty to successfully link and add the account (“Linked Account” or “Funding Account”). By accepting these terms and conditions you expressly authorize Plenty and/or our third-party processor partners to initiate ACH credit and/or debit transactions between your Funding Accounts and your Plenty accounts. These transactions will either be manually initiated on the Plenty Website by you or through your confirmation of a recurring funding plan. You always maintain control over the amount and frequency of funding.
By linking these accounts or authorizing Plenty and its partners to access your Third Party Account information, you are consenting to the processing of your Third Party Account information and other personal information you provide that is needed to retrieve such Third Party Account information in accordance with our Privacy Policy, as permitted by law and in connection with Plenty’s use of your Third Party Account information in connection with provision of our Services to you. Plenty is not responsible for the Third Party Account information or products and services offered by or on any third party sites.
You represent and warrant that you are an individual of legal age to form a binding contract (or if not, you’ve received your parent’s or guardian’s permission to use the Services and have gotten your parent or guardian to agree to these Terms on your behalf).
You will only use the Services for your own internal, personal, non-commercial use, and not on behalf of or for the benefit of any third party, and only in a manner that complies with all laws that apply to you. If your use of the Services is prohibited by applicable laws, then you aren’t authorized to use the Services. We can’t and won’t be responsible for your using the Services in a way that breaks the law.
You will not share your Plenty login credentials with anyone, and you must protect the security of your Plenty Account and any other access tools or credentials. You’re responsible for any activity associated with your Plenty account.
Multiplayer Functionality at Plenty
Plenty’s Service enables you to invite another user’s individual account to to your individual account to form a household. You may choose to share varying amounts of information about your investment goals and financial information for tracking and planning purposes. You agree that by inviting an individual to join your individual account and forming a household account or by accepting an invitation to join a household and explicitly choosing to share information, you are agreeing to share your investment goals and any other available financial information with that individual. When you choose to share this information, the information that may be shared includes but is not limited to : goal amount, goal timeline, funding plan, contributions, and investment return, account balances, transaction, institution name, account last 4 digits, and other investment history figures. The member you connect your account with will not be able to withdraw or deposit from your account. If you wish to enable this function you will have to inform us that you wish to operate this account as a joint account and upon written confirmation from both account holders we can give both account holders the ability to control withdrawals and deposits.
When you form a household, some information from your profile (for example, your first name, last name, email address, income, birthday etc.) will automatically be shared with that individual when they accept the invite. For any other information you have sole discretion and ability to control the privacy settings for what you choose to share. . You agree that you are solely responsible and Plenty has no liability with regards to who you choose to invite and add to your account and for any household you may form on our platform you may be added to.
What about messaging?
As part of the Services, you may receive communications through the Services, including messages that Plenty sends you (for example, via email or SMS). When signing up for the Services, you will receive a welcome message and instructions on how to stop receiving messages. By signing up for the Services and providing us with your wireless number, you confirm that you want Plenty to send you information regarding your account or transactions with us, which may include Plenty using automated dialing technology to text you at the wireless number you provided, and you agree to receive communications from Plenty, and you represent and warrant that each person you register for the Services or for whom you provide a wireless phone number has consented to receive communications from Plenty. You agree to indemnify and hold Plenty harmless from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys’ fees) arising from or in any way related to your breach of the foregoing.
Are there restrictions in how I can use the Services?
You represent, warrant, and agree that you will not provide or contribute anything, including any Content (as that term is defined below), to the Services, or otherwise use or interact with the Services, in a manner that:
infringes or violates the intellectual property rights or any other rights of anyone else (including Plenty);
violates any law or regulation, including, without limitation, any applicable export control laws, privacy laws or any other purpose not reasonably intended by Plenty;
is dangerous, harmful, fraudulent, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable;
jeopardizes the security of your Plenty account or anyone else’s (such as allowing someone else to log in to the Services as you);
attempts, in any manner, to obtain the account or other security information from any other user;
violates the security of any computer network, or cracks any passwords or security encryption codes;
runs Maillist, Listserv, any form of auto-responder or “spam” on the Services, or any processes that run or are activated while you are not logged into the Services, or that otherwise interfere with the proper working of the Services (including by placing an unreasonable load on the Services’ infrastructure);
“crawls,” “scrapes,” or “spiders” any page, data, or portion of or relating to the Services or Content (through use of manual or automated means);
copies or stores any significant portion of the Content; or
decompiles, reverse engineers, or otherwise attempts to obtain the source code or underlying ideas or information of or relating to the Services.
A violation of any of the foregoing is grounds for termination of your right to use or access the Services.
What are my rights in the Services?
The materials displayed or performed or available on or through the Services, including, but not limited to, text, graphics, data, articles, photos, images, illustrations and so forth (all of the foregoing, the “Content”) are protected by copyright and/or other intellectual property laws. You promise to abide by all copyright notices, trademark rules, information, and restrictions contained in any Content you access through the Services, and you won’t use, copy, reproduce, modify, translate, publish, broadcast, transmit, distribute, perform, upload, display, license, sell, commercialize or otherwise exploit for any purpose any Content not owned by you, (i) without the prior consent of the owner of that Content or (ii) in a way that violates someone else’s (including Plenty's) rights.
Subject to these Terms, we grant each user of the Services a worldwide, non-exclusive, non-sublicensable and non-transferable license to use (i.e., to download and display locally) Content solely for purposes of using the Services. Use, reproduction, modification, distribution or storage of any Content for any purpose other than using the Services is expressly prohibited without prior written permission from us. You understand that Plenty owns the Services. You won’t modify, publish, transmit, participate in the transfer or sale of, reproduce (except as expressly provided in this Section), create derivative works based on, or otherwise exploit any of the Services. The Services may allow you to copy or download certain Content, but please remember that even where these functionalities exist, all the restrictions in this section still apply.
Who is responsible for what I see and do on the Services?
Any information or Content publicly posted or privately transmitted through the Services is the sole responsibility of the person from whom such Content originated, and you access all such information and Content at your own risk, and we aren’t liable for any errors or omissions in that information or Content or for any damages or loss you might suffer in connection with it. We cannot control and have no duty to take any action regarding how you may interpret and use the Content or what actions you may take as a result of having been exposed to the Content, and you hereby release us from all liability for you having acquired or not acquired Content through the Services. We can’t guarantee the identity of any users with whom you interact in using the Services and are not responsible for which users gain access to the Services.
You are responsible for all Content you contribute, in any manner, to the Services, and you represent and warrant you have all rights necessary to do so, in the manner in which you contribute it.
The Services may contain links or connections to third-party websites or services that are not owned or controlled by Plenty. When you access third-party websites or use third-party services, you accept that there are risks in doing so, and that Plenty is not responsible for such risks.
Plenty has no control over, and assumes no responsibility for, the content, accuracy, privacy policies, or practices of or opinions expressed in any third-party websites or by any third party that you interact with through the Services. In addition, Plenty will not and cannot monitor, verify, censor or edit the content of any third-party site or service. We encourage you to be aware when you leave the Services and to read the terms and conditions and privacy policy of each third-party website or service that you visit or utilize. By using the Services, you release and hold us harmless from any and all liability arising from your use of any third-party website or service.
Your interactions with organizations and/or individuals found on or through the Services, including payment and delivery of goods or services, and any other terms, conditions, warranties or representations associated with such dealings, are solely between you and such organizations and/or individuals. You should make whatever investigation you feel necessary or appropriate before proceeding with any online or offline transaction with any of these third parties. You agree that Plenty shall not be responsible or liable for any loss or damage of any sort incurred as the result of any such dealings.
If there is a dispute between participants on this site or Services, or between users and any third party, you agree that Plenty is under no obligation to become involved. In the event that you have a dispute with one or more other users, you release Plenty, its directors, officers, employees, agents, and successors from claims, demands, and damages of every kind or nature, known or unknown, suspected or unsuspected, disclosed or undisclosed, arising out of or in any way related to such disputes and/or our Services. You shall and hereby do waive California Civil Code Section 1542 or any similar law of any jurisdiction, which says in substance: “A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.”
Will Plenty ever change the Services?
We’re always trying to improve our Services, so they may change over time. We may suspend or discontinue any part of the Services, or we may introduce new features or impose limits on certain features or restrict access to parts or all of the Services. We’ll try to give you notice when we make a material change to the Services that would adversely affect you, but this isn’t always practical. We reserve the right to remove any Content from the Services at any time, for any reason (including, but not limited to, if someone alleges you contributed that Content in violation of these Terms), in our sole discretion, and without notice.
Do the Services cost anything?
The Services may be free or we may charge a fee for using the Services. If you are using a free version of the Services, we will notify you before any Services you are then using begin carrying a fee, and if you wish to continue using such Services, you must pay all applicable fees for such Services. Note that if you elect to receive text messages through the Services, data and message rates may apply. Any and all such charges, fees or costs are your sole responsibility. You should consult with your wireless carrier to determine what rates, charges, fees or costs may apply to your use of the Services.
Paid Services. Certain of our Services may be subject to payments now or in the future (the “Paid Services”). Please see our Paid Services page for a description of the current Paid Services. Please note that any payment terms presented to you in the process of using or signing up for a Paid Service are deemed part of these Terms.
Subscription Billing. We use a third-party payment processor (the “Payment Processor”) to bill you through a payment account linked to your account on the Services (your “Billing Account”) for use of the Paid Services. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processor in addition to these Terms. Currently, we use Stripe, Inc. as our Payment Processor. You can access Stripe’s Terms of Service at https://stripe.com/us/checkout/legal and their Privacy Policy at https://stripe.com/us/privacy. We are not responsible for any error by, or other acts or omissions of, the Payment Processor. By choosing to use Paid Services, you agree to pay us, through the Payment Processor, all charges at the prices then in effect for any use of such Paid Services in accordance with the applicable payment terms, and you authorize us, through the Payment Processor, to charge your chosen payment provider (your “Payment Method”). You agree to make payment using that selected Payment Method. We reserve the right to correct any errors or mistakes that the Payment Processor makes even if it has already requested or received payment. Payment Method. The terms of your payment will be based on your Payment Method and may be determined by agreements between you and the financial institution, credit card issuer or other provider of your chosen Payment Method. If we, through the Payment Processor, do not receive payment from you, you agree to pay all amounts due on your Billing Account upon demand.
Investment Wrap Fee. Plenty charges a Wrap Fee based on amount of Assets under Management (“AUM”) in your account. The wrap fee is automatically collected by Plenty Financial RIA's sub-adviser, Helium. Additional details about our wrap fee are in Plenty’s Investment Advisory Agreement <LINK>
Recurring Billing. Some of the Paid Services may consist of an initial period, for which there is a one-time charge, followed by recurring period charges as agreed to by you. By choosing a recurring payment plan, you acknowledge that such Services have an initial and recurring payment feature and you accept responsibility for all recurring charges prior to cancellation. WE MAY SUBMIT PERIODIC CHARGES (E.G., MONTHLY OR QUARTERLY) WITHOUT FURTHER AUTHORIZATION FROM YOU, UNTIL YOU PROVIDE PRIOR NOTICE (RECEIPT OF WHICH IS CONFIRMED BY US) THAT YOU HAVE TERMINATED THIS AUTHORIZATION OR WISH TO CHANGE YOUR PAYMENT METHOD. SUCH NOTICE WILL NOT AFFECT CHARGES SUBMITTED BEFORE WE REASONABLY COULD ACT. TO TERMINATE YOUR AUTHORIZATION OR CHANGE YOUR PAYMENT METHOD, GO TO ACCOUNT SETTINGS<LINK>.
Current Information Required. YOU MUST PROVIDE CURRENT, COMPLETE AND ACCURATE INFORMATION FOR YOUR BILLING ACCOUNT. YOU MUST PROMPTLY UPDATE ALL INFORMATION TO KEEP YOUR BILLING ACCOUNT CURRENT, COMPLETE AND ACCURATE (SUCH AS A CHANGE IN BILLING ADDRESS, CREDIT CARD NUMBER, OR CREDIT CARD EXPIRATION DATE), AND YOU MUST PROMPTLY NOTIFY US OR OUR PAYMENT PROCESSOR IF YOUR PAYMENT METHOD IS CANCELED (E.G., FOR LOSS OR THEFT) OR IF YOU BECOME AWARE OF A POTENTIAL BREACH OF SECURITY, SUCH AS THE UNAUTHORIZED DISCLOSURE OR USE OF YOUR USER NAME OR PASSWORD. CHANGES TO SUCH INFORMATION CAN BE MADE AT ACCOUNT SETTINGS<LINK>. IF YOU FAIL TO PROVIDE ANY OF THE FOREGOING INFORMATION, YOU AGREE THAT WE MAY CONTINUE CHARGING YOU FOR ANY USE OF PAID SERVICES UNDER YOUR BILLING ACCOUNT UNLESS YOU HAVE TERMINATED YOUR PAID SERVICES AS SET FORTH ABOVE.
Change in Amount Authorized. If the amount to be charged to your Billing Account varies from the amount you preauthorized (other than due to the imposition or change in the amount of state sales taxes), you have the right to receive, and we shall provide, notice of the amount to be charged and the date of the charge before the scheduled date of the transaction. Any agreement you have with your payment provider will govern your use of your Payment Method. You agree that we may accumulate charges incurred and submit them as one or more aggregate charges during or at the end of each billing cycle.
Auto-Renewal for Paid Services. Unless you opt out of auto-renewal, which can be done through your account profile >> billing<LINK>, any Paid Services you have signed up for will be automatically extended for successive renewal periods of the same duration as the subscription term originally selected, at the then-current non-promotional rate. To change or resign your Paid Services at any time, go to account profile >> billing page<LINK>. If you terminate a Paid Service, you may use your subscription until the end of your then-current term, and your subscription will not be renewed after your then-current term expires. However, you will not be eligible for a prorated refund of any portion of the subscription fee paid for the then-current subscription period. IF YOU DO NOT WANT TO CONTINUE TO BE CHARGED ON A RECURRING MONTHLY BASIS, YOU MUST CANCEL THE APPLICABLE PAID SERVICE THROUGH YOUR ACCOUNT profile >> Billing <LINK> OR TERMINATE YOUR PLENTY ACCOUNT BEFORE THE END OF THE RECURRING TERM. PAID SERVICES CANNOT BE TERMINATED BEFORE THE END OF THE PERIOD FOR WHICH YOU HAVE ALREADY PAID, AND EXCEPT AS EXPRESSLY PROVIDED IN THESE TERMS, PLENTY WILL NOT REFUND ANY FEES THAT YOU HAVE ALREADY PAID.
Reaffirmation of Authorization. Your non-termination or continued use of a Paid Service reaffirms that we are authorized to charge your Payment Method for that Paid Service. We may submit those charges for payment and you will be responsible for such charges. This does not waive our right to seek payment directly from you. Your charges may be payable in advance, in arrears, per usage, or as otherwise described when you initially selected to use the Paid Service.
Free Trials and Other Promotions. Any free trial or other promotion that provides access to a Paid Service must be used within the specified time of the trial. You must stop using a Paid Service before the end of the trial period in order to avoid being charged for that Paid Service. If you cancel prior to the end of the trial period and are inadvertently charged for a Paid Service, please contact us at support@withplenty.com.
What if I want to stop using the Services?
You’re free to do that at any time by contacting us at support@withplenty.com; please refer to our Privacy Policy, as well as the licenses above, to understand how we treat information you provide to us after you have stopped using our Services.
Plenty is also free to terminate (or suspend access to) your use of the Services or your account for any reason in our discretion, including your breach of these Terms. Plenty has the sole right to decide whether you are in violation of any of the restrictions set forth in these Terms.
Account termination may result in destruction of any Content associated with your account, so keep that in mind before you decide to terminate your account.
If you have deleted your account by mistake, contact us immediately at support@withplenty.com – we will try to help, but unfortunately, we can’t promise that we can recover or restore anything.
Provisions that, by their nature, should survive termination of these Terms shall survive termination. By way of example, all of the following will survive termination: any obligation you have to pay us or indemnify us, any limitations on our liability, any terms regarding ownership or intellectual property rights, and terms regarding disputes between us, including without limitation the arbitration agreement.
What about Mobile Applications?
You acknowledge and agree that the availability of any Plenty mobile application is dependent on the third party stores from which you download the application, e.g., the App Store from Apple or the Android app market from Google (each an “App Store”). Each App Store may have its own terms and conditions to which you must agree before downloading mobile applications from such store, including the specific terms relating to Apple App Store set forth below. You agree to comply with, and your license to use our application is conditioned upon your compliance with, such App Store terms and conditions. To the extent such other terms and conditions from such App Store are less restrictive than, or otherwise conflict with, the terms and conditions of these Terms of Use, the more restrictive or conflicting terms and conditions in these Terms of Use apply.
I use the Plenty App available via the Apple App Store – should I know anything about that?
These Terms apply to your use of all the Services, including our iOS applications (the “Application”) available via the Apple, Inc. (“Apple”) App Store, but the following additional terms also apply to the Application:
Both you and Plenty acknowledge that the Terms are concluded between you and Plenty only, and not with Apple, and that Apple is not responsible for the Application or the Content;
The Application is licensed to you on a limited, non-exclusive, non-transferrable, non-sublicensable basis, solely to be used in connection with the Services for your private, personal, non-commercial use, subject to all the terms and conditions of these Terms as they are applicable to the Services;
You will only use the Application in connection with an Apple device that you own or control;
You acknowledge and agree that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the Application;
In the event of any failure of the Application to conform to any applicable warranty, including those implied by law, you may notify Apple of such failure; upon notification, Apple’s sole warranty obligation to you will be to refund to you the purchase price, if any, of the Application;
You acknowledge and agree that Plenty, and not Apple, is responsible for addressing any claims you or any third party may have in relation to the Application;
You acknowledge and agree that, in the event of any third-party claim that the Application or your possession and use of the Application infringes that third party’s intellectual property rights, Plenty, and not Apple, will be responsible for the investigation, defense, settlement and discharge of any such infringement claim;
You represent and warrant that you are not located in a country subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country, and that you are not listed on any U.S. Government list of prohibited or restricted parties;
Both you and Plenty acknowledge and agree that, in your use of the Application, you will comply with any applicable third-party terms of agreement which may affect or be affected by such use; and
Both you and Plenty acknowledge and agree that Apple and Apple’s subsidiaries are third-party beneficiaries of these Terms, and that upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as the third-party beneficiary hereof.
Can I refer other users?
From time to time Plenty may offer rewards or incentives for referring others to the Services. For details of any current referral offers, please see our referral page<LINK>. The referring user (“Referrer”) may refer individuals or entities who are neither current customers of Plenty nor registered users of the Services (“Referee”). A registered user is a person or entity that already has an existing account with Plenty. There is no limit to the number of referrals that Referrer can make, nor the cumulative rewards or incentives that the Referrer may receive through such special offer, unless otherwise indicated. Referrer will receive the stated reward or incentive for each Referee sent by the Referrer that completes the required action described in that specific offer (such as signing up for an account or making an initial investment). All Referees must be first-time recipients of the offer, and multiple referrals to the same individual or entity will be disregarded. Plenty reserves the right to modify or terminate any special offers at any time and to revoke from Referrer and Referee the special offer at Plenty's discretion for any reason or for no reason whatsoever. If Plenty determines that Referrer or Referee is attempting to obtain unfair advantage or otherwise violate the terms or spirit of such special offer, Plenty reserves the right to (a) revoke any rewards or incentives issued to either Referrer or Referee and/or (b) charge the Referrer or Referee for any rewards or incentives (1) used by Referrer or Referee prior to such revocation or (2) issued by Plenty to any ineligible Referrer or Referee. All special offers are subject to any other terms, conditions and restrictions set forth on the Services or presented in connection with the special offer.
What else do I need to know?
Warranty Disclaimer. Plenty and its licensors, suppliers, partners, parent, subsidiaries or affiliated entities, and each of their respective officers, directors, members, employees, consultants, contract employees, representatives and agents, and each of their respective successors and assigns (Plenty and all such parties together, the “Plenty Parties”) make no representations or warranties concerning the Services, including without limitation regarding any Content contained in or accessed through the Services, and the Plenty Parties will not be responsible or liable for the accuracy, copyright compliance, legality, or decency of material contained in or accessed through the Services or any claims, actions, suits procedures, costs, expenses, damages or liabilities arising out of use of, or in any way related to your participation in, the Services. The Plenty Parties make no representations or warranties regarding suggestions or recommendations of services or products offered or purchased through or in connection with the Services. THE SERVICES AND CONTENT ARE PROVIDED BY PLENTY (AND ITS LICENSORS AND SUPPLIERS) ON AN “AS-IS” BASIS, WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR THAT USE OF THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. SOME STATES DO NOT ALLOW LIMITATIONS ON HOW LONG AN IMPLIED WARRANTY LASTS, SO THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU.
Limitation of Liability. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL ANY OF THE PLENTY PARTIES BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF DATA, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, (B) ANY SUBSTITUTE GOODS, SERVICES OR TECHNOLOGY, (C) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) ONE-HUNDRED ($100) DOLLARS OR (II) THE AMOUNTS PAID AND/OR PAYABLE BY YOU TO PLENTY IN CONNECTION WITH THE SERVICES IN THE TWELVE (12) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM OR (D) ANY MATTER BEYOND OUR REASONABLE CONTROL. SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL OR CERTAIN OTHER DAMAGES, SO THE ABOVE LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU.
Indemnity. You agree to indemnify and hold the Plenty Parties harmless from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys’ fees) arising from or in any way related to any claims relating to (a) your use of the Services (including any actions taken by a third party using your account), and (b) your violation of these Terms. In the event of such a claim, suit, or action (“Claim”), we will attempt to provide notice of the Claim to the contact information we have for your account i.e. your email address (provided that failure to deliver such notice shall not eliminate or reduce your indemnification obligations hereunder).
Assignment. You may not assign, delegate or transfer these Terms or your rights or obligations hereunder, or your Services account, in any way (by operation of law or otherwise) without Plenty's prior written consent. We may transfer, assign, or delegate these Terms and our rights and obligations without consent.
Choice of Law. These Terms are governed by and will be construed under the Federal Arbitration Act, applicable federal law, and the laws of the State of California, without regard to the conflicts of laws provisions thereof.
Arbitration Agreement. Please read the following ARBITRATION AGREEMENT carefully because it requires you to arbitrate certain disputes and claims with Plenty and limits the manner in which you can seek relief from Plenty. Both you and Plenty acknowledge and agree that for the purposes of any dispute arising out of or relating to the subject matter of these Terms, Plenty's officers, directors, employees and independent contractors (“Personnel”) are third-party beneficiaries of these Terms, and that upon your acceptance of these Terms, Personnel will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as the third-party beneficiary hereof.
(a) Arbitration Rules; Applicability of Arbitration Agreement. The parties shall use their best efforts to settle any dispute, claim, question, or disagreement arising out of or relating to the subject matter of these Terms directly through good-faith negotiations, which shall be a precondition to either party initiating arbitration. If such negotiations do not resolve the dispute, it shall be finally settled by binding arbitration in San Francisco, California. The arbitration will proceed in the English language, in accordance with the JAMS Streamlined Arbitration Rules and Procedures (the “Rules”) then in effect, by one commercial arbitrator with substantial experience in resolving intellectual property and commercial contract disputes. The arbitrator shall be selected from the appropriate list of JAMS arbitrators in accordance with such Rules. Judgment upon the award rendered by such arbitrator may be entered in any court of competent jurisdiction.
(b) Costs of Arbitration. The Rules will govern payment of all arbitration fees. Plenty will pay all arbitration fees for claims less than seventy-five thousand ($75,000) dollars. Plenty will not seek its attorneys’ fees and costs in arbitration unless the arbitrator determines that your claim is frivolous.
(c) Small Claims Court; Infringement. Either you or Plenty may assert claims, if they qualify, in small claims court in San Francisco, California or any United States county where you live or work. Furthermore, notwithstanding the foregoing obligation to arbitrate disputes, each party shall have the right to pursue injunctive or other equitable relief at any time, from any court of competent jurisdiction, to prevent the actual or threatened infringement, misappropriation or violation of a party's copyrights, trademarks, trade secrets, patents or other intellectual property rights.
(d) Waiver of Jury Trial. YOU AND PLENTY WAIVE ANY CONSTITUTIONAL AND STATUTORY RIGHTS TO GO TO COURT AND HAVE A TRIAL IN FRONT OF A JUDGE OR JURY. You and Plenty are instead choosing to have claims and disputes resolved by arbitration. Arbitration procedures are typically more limited, more efficient, and less costly than rules applicable in court and are subject to very limited review by a court. In any litigation between you and Plenty over whether to vacate or enforce an arbitration award, YOU AND PLENTY WAIVE ALL RIGHTS TO A JURY TRIAL, and elect instead to have the dispute be resolved by a judge.
(e) Waiver of Class or Consolidated Actions. ALL CLAIMS AND DISPUTES WITHIN THE SCOPE OF THIS ARBITRATION AGREEMENT MUST BE ARBITRATED OR LITIGATED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS BASIS. CLAIMS OF MORE THAN ONE CUSTOMER OR USER CANNOT BE ARBITRATED OR LITIGATED JOINTLY OR CONSOLIDATED WITH THOSE OF ANY OTHER CUSTOMER OR USER. If however, this waiver of class or consolidated actions is deemed invalid or unenforceable, neither you nor Plenty is entitled to arbitration; instead all claims and disputes will be resolved in a court as set forth in (g) below.
(f) Opt-out. You have the right to opt out of the provisions of this Section by sending written notice of your decision to opt out to the following address: 576 Sacramento St, Floor 6 - Plenty, San Francisco, CA 94111 postmarked within thirty (30) days of first accepting these Terms. You must include (i) your name and residence address, (ii) the email address and/or telephone number associated with your account, and (iii) a clear statement that you want to opt out of these Terms’ arbitration agreement.
(g) Exclusive Venue. If you send the opt-out notice in (f), and/or in any circumstances where the foregoing arbitration agreement permits either you or Plenty to litigate any dispute arising out of or relating to the subject matter of these Terms in court, then the foregoing arbitration agreement will not apply to either party, and both you and Plenty agree that any judicial proceeding (other than small claims actions) will be brought in the state or federal courts located in, respectively, San Francisco, California, or the federal district in which that county falls.
(h) Severability. If the prohibition against class actions and other claims brought on behalf of third parties contained above is found to be unenforceable, then all of the preceding language in this Arbitration Agreement section will be null and void. This arbitration agreement will survive the termination of your relationship with Plenty.
Miscellaneous. You will be responsible for paying, withholding, filing, and reporting all taxes, duties, and other governmental assessments associated with your activity in connection with the Services, provided that the Plenty may, in its sole discretion, do any of the foregoing on your behalf or for itself as it sees fit. The failure of either you or us to exercise, in any way, any right herein shall not be deemed a waiver of any further rights hereunder. If any provision of these Terms are found to be unenforceable or invalid, that provision will be limited or eliminated, to the minimum extent necessary, so that these Terms shall otherwise remain in full force and effect and enforceable. You and Plenty agree that these Terms are the complete and exclusive statement of the mutual understanding between you and Plenty, and that these Terms supersede and cancel all previous written and oral agreements, communications and other understandings relating to the subject matter of these Terms. You hereby acknowledge and agree that you are not an employee, agent, partner, or joint venture of Plenty, and you do not have any authority of any kind to bind Plenty in any respect whatsoever.
Except as expressly set forth in the sections above regarding the Apple Application and the arbitration agreement, you and Plenty agree there are no third-party beneficiaries intended under these Terms.
Form ADV Part 2A Appendix 1 Wrap Fee Program Brochure
Updated as of March 25, 2024
Back to Top ^
This “Brochure” provides information about the qualifications and business practices of Plenty Financial RIA, LLC. (hereinafter “Plenty,” “we,” “us,” “our” or the “Firm”). If you have any questions about the contents of this Brochure, please contact our Chief Compliance Officer (“CCO”), Emily Luk, by email at compliance@withplenty.com. Information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (the “SEC”) or by any state securities authority.
Registration as an investment adviser does not imply that Plenty or any of its principals or employees possesses a particular level of skill or training in the investment advisory business or any other business.
Additional information about Plenty is also available on the SEC's website at www.adviserinfo.sec.gov.
Plenty Financial RIA, LLC | 576 Sacramento Street, Floor 6, San Francisco, CA 94111 628-333-3863
Item 2: Material Changes
Since the Firm’s last annual amendment on March 30, 2023, the Brochure has updated its Fees in Item 4 and additional risk factors have been included in Item 6 to include tax-loss harvesting, among others.
Item 3: Table of Contents
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Types of Clients
Item 6: Portfolio Manager Selection and Evaluation
Item 7: Client Information Provided to the Portfolio Managers
Item 8: Client Contact with Portfolio Managers
Item 9: Additional Information
Disciplinary Information
Item 4: Advisory Business
Plenty Financial RIA, LLC. (hereinafter “Plenty,” “we,” “us,” “our” or the “Firm”) is organized as a Delaware limited liability company with a principal place of business in San Francisco, CA. Plenty is principally owned by Plenty Financial, Inc. which is principally owned by Emily Luk and Christopher Allen.
Plenty was founded to democratize access to financial products and tools that accelerate wealth building. Plenty Financial, Inc. provides an interactive web‐based personal financial management and educational platform to consumers through a fee‐based subscription. Wholly owned subsidiary Plenty Financial RIA, LLC leverages industry‐leading technology to provide advisory services (“Advisory Services” or “Services”) in the form of software‐first financial planning and investment advisory services for Subscribers (“Subscribers” or “Clients”). Our investment advice guidelines are discretionary and available to our Subscribers via ongoing fee‐based subscription.
Program Description
This Wrap Fee Program Brochure is provided to help Clients understand the nature of the services offered by the Firm, whether the services offered by Plenty are right for the Client, and the potential conflicts of interest associated with the Client’s participation in the Plenty Wrap Fee Program.
Clients should review this Wrap Fee Program Brochure carefully. The discretionary investment management services are offered through a wrap fee program (the “Plenty Wrap Fee Program”) described herein.
Plenty Financial, Inc. provides interactive educational financial planning tools to help individuals and couples create their own goals‐based financial plan and understand their cashflow. Plenty collects information about a Client’s age, family, financial condition, employment status, investment goals/objectives, time horizon, and risk tolerance exclusively through an interactive website. Clients are then guided through estimates of their financial goals and given the ability to use an interactive tool to understand the impact of different saving and investment plans for each of their goals. Once an individual has made a decision to move forward with a given plan, Plenty provides investment recommendations including money‐market funds or an algorithm‐generated stock/bond portfolio provided by its subadvisor. Typically, individual stocks or domestic exchange traded funds (“ETFs”) are utilized for domestic equity exposure and ETFs are utilized for international equity and treasury/bond exposure. This asset mix also may vary depending on the type of account a Client is using to invest (individual, joint, retirement, etc.). Client’s investment objectives, financial profile, and risk tolerance impact the options Clients are initially shown, though a Client may override recommendations at any point and select their own risk tolerance-based allocation for Plenty to implement. Once a Client decides to move forward, the investment accounts are managed by the subadvisor.
Client accounts will have the ability to make reasonable restrictions for their account and the subadvisor’s software will monitor Clients’ accounts on an ongoing basis and periodically rebalance as changes in market conditions, additions, or withdrawals in the Client account and or a change in Client’s financial circumstances occurs.
In general, wrap fee programs allow Clients to pay a single fee (the “Wrap Fee”) which covers advisory fees (including subadvisory fees), trading commissions, fees for brokerage, and other administrative and advisory services provided by an investment adviser, broker, and/or the custodian. Clients are generally not charged separate fees for each component of the total services. Because wrap fee program advisers typically absorb Client transaction fees, an incentive exists to limit trading activities in the wrap fee account. Depending on the wrap fee account, Clients may also pay more for using a wrap fee program than they would for using non‐wrap fee program services.
Types of Advisory Services and Investment Strategy
Plenty provides interactive web‐based financial planning and educational tools that allow individuals to visually see the impact of different investing and savings plans. Clients are given options between money market funds or stock and bond portfolios (sometimes represented by ETFs), and the ability to see the impact on risk and return. These stock and bond portfolio recommendations are made through the subadvisor’s proprietary algorithmic‐based technology to provide discretionary asset management services through a web application.
A Client may update his or her risk profile at any time by updating the risk responses accessible through a Client’s account online. Clients also are able to set their risk tolerance on a goal-by-goal basis. Client assets are used to purchase the securities that align to the Client’s corresponding target asset allocation within the recommended portfolio or Client selected portfolio.
Investment services provided by Plenty and its sub-advisory partner are designed to encourage higher rates of saving and investing in non‐retirement and retirement accounts. At user onboarding, individual Clients undergo a financial situation review and risk assessment. Clients may optionally provide values‐preferences that lead to the inclusion / exclusion of different companies or industries in their stock-based portfolios. Clients have the option to additionally create individual investment goals with unique time horizons, risk tolerance, and liquidity needs that lead to the programmatic curation of a custom investment portfolio for each goal. For all investment portfolios, Clients may choose to override the algorithm‐based portfolios.
Fees and Compensation
The fees applicable to Clients are set forth in detail in each membership agreement. A brief summary of such fees is provided below.
Advisory Fees
Plenty’s Clients pay a combination of:
Subscription fee (“Subscription Fee”) to Plenty Financial, Inc. for non-advisory services including financial wellness and educational content.
Wrap Fee based on amount of Assets under Management (“AUM”) in your account for the advisory services described in this Item 4.
The Subscription Fee is $100 annually per Client. The asset‐based wrap fees are 0.20% of AUM and is billed in arrears and based on the Client’s average daily balance in the prior month. The Subscription Fee provides access to the personal financial management tools and financial educational tools and is collected by Plenty Financial, Inc. The wrap fee is collected by Plenty Financial RIA's subadvisor, Atomic Invest LLC. The wrap fee is based on the amount of assets in your account. As a general matter, the more money you invest with us the more fees you will pay; therefore, we have an incentive to encourage you to increase your assets in your account. The annual wrap fee includes investment advisory and subadvisory services (portfolio construction, rebalancing, and automated tax‐loss harvesting), custody services and brokerage commissions, and therefore may be higher than a typical asset‐based advisory fee that does not include the additional services described. Plenty reserves the right to waive or modify the Subscription Fee and/or the Wrap Fee for any Client, at its sole discretion.
Other Types of Fees or Expenses
The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm.
Neither the Firm nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.
Plenty may charge additional fees to Clients for specifically requested services or irregular occurrences that are not included in the wrap fee program. [All such fees are outlined in the Advisory Agreement].
Personal Financial Management and Education Platform: Plenty Financial, Inc. provides an interactive financial planning and educational web platform to Clients to link their external accounts and see their financial lives in a single place. The tools enable individuals to explore potential future financial scenarios including having children, retirement, getting married, college funding and purchasing a home, and provide investment related services (provided through Plenty Financial RIA and its subadvisor) for reaching their goals. The software‐first experience enables individuals to forego a traditional interview‐based onboarding experience. Clients are empowered with the tools to understand the financial consequences of different decisions, and given the ability to create their own plans to reach their financial goals. Clients choose to implement decisions entirely at their own discretion, and should consult with tax or financial advisors if there are additional personal circumstances that are not captured by Plenty’s platform. While the data used in financial models is believed to be reliable, Plenty cannot ensure the accuracy or completeness of data provided by third parties (including the subadvisor) or Clients.
Item 5: Types of Clients
Plenty is an internet‐only advisory firm that uses a software‐first approach to support individuals in financial planning and investment decisions.
Our investment advisory subscribers, as mentioned in Item 4 above, undergo verification to confirm that they are natural persons who are:
Legal US Residents or US Citizens;
Maintain and link a verified funding source with a US bank or financial institution to their Plenty Account;
Pass identify verification protocols; and
that Clients are 18 and above.
The minimum initial account size is $100.
Clients may choose to open joint accounts with another individual; additional identity verification is completed upon doing so.
Item 6: Portfolio Manager Selection and Evaluation
Selecting/Reviewing Portfolio Manager
Plenty evaluates a variety of information about subadvisors, which includes the subadvisor’s public disclosure documents, materials supplied by the subadvisor themselves and other third-party analyses it believes are reputable. To the extent possible, Plenty seeks to assess the subadvisor’s investment strategies, past performance, and risk results in relation to its Clients’ individual portfolio allocations and risk exposure. Plenty also takes into consideration the subadvisor’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
On an ongoing basis, Plenty monitors the performance of those accounts being managed by the subadvisor. Plenty seeks to ensure the subadvisor’s strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. No guarantees can be made that a Client’s financial goals or objectives will be achieved. Further, no guarantees of performance can be offered.
Performance‐Based Fees and Side‐By‐Side Management
We do not accept performance‐based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a Client. Furthermore, we do not manage both accounts that are charged a performance‐based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset‐based fee.
Method of Analysis, Investment Strategies and Risk of Loss
Plenty provides investment services through a website. This entails the use of a subadvisor-provided algorithm‐based portfolio and digital services, rather than in‐person investment services. These automated investment solutions are customized to each Client and based on individual characteristics, such as the Client’s age, risk tolerance, income, and current assets, among others. Clients are encouraged to update their account with any change in their objectives, risk tolerance, or other pertinent information, as that information factors into the algorithmic based portfolio recommendations.
The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, should not be understood to limit in any way our activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate. The investment strategies we pursue may be speculative and could entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved.
Risk Management
The firm focuses on diversification, limited exposure, position sizing, and management to mitigate risk on posted trade services, and for general portfolio guidelines. Plenty collects information about a client’s investment time horizon, risk preferences and investment goal size.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. All investment programs have certain risks that are borne by the investor. The investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks:
Market Risk: The risk that the price of a security, bond, or Fund may change in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors, independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events.
Tax-loss harvesting: Tax-loss harvesting involves certain risks, including the risk that the new investment could have higher costs than the original investment and may introduce portfolio tracking error into your accounts. There may also be unintended tax implications. Prospective Clients should consult with their tax or legal advisor prior to utilizing any tax-loss harvesting strategy. Neither Plenty nor its subadvisor provide tax or legal advice. Tax-loss harvesting may not be suitable for every investor and may have limited or no impact in retirement accounts. For example, tax-loss harvesting may not materially benefit investors in low-income tax brackets.
Tax-loss harvesting and wash sale rule: The wash sale rule prohibits the realization of a loss from selling a security if a “substantially identical” security is purchased 30 days before or after the sale. The wash sale rule also applies when the purchase is made in a different account or even the account of a spouse. In general, tax-loss harvesting seeks to avoid potential wash sales. Tax-loss harvesting techniques implemented by Plenty are not able to avoid wash sales associated with assets held or transactions conducted in accounts that are held outside of Plenty. This limitation includes outside accounts that may be linked in Plenty’s website for planning purposes, but that are not connected for Plenty to provide investment advice. Although the tax-loss harvesting algorithm available through the subadvisor seeks to avoid wash sales, situations may occur where tax-loss harvesting may result in a wash sale. Clients are responsible for their own analysis of whether wash sales may have occurred across the totality of their accounts.
Advisory Risk: Clients who choose to implement Plenty’s investment services are not guaranteed investment performance. There is no guarantee that Plenty’s services will be successful. Further, Plenty, through our subadvisor, recommends stock and bond investment portfolios. While the third‐party subadvisor partner has been vetted, there can be no assurance that services generated will be profitable.
Software Risk: Plenty’s services are delivered entirely through software. While all software is tested and vetted before implementation, the software may not always perform as intended, especially in unusual circumstances. Internet outages, third party hacks, malware, and other events may impact Plenty’s software and related services. Plenty has continuous monitoring, detection, and correction protocols to mitigate but not eliminate this risk. In addition, Plenty uses a third‐party’s software for investment portfolio recommendations and this exposes Plenty to third‐party software risk.
Security Selection Risk: The risk that individual securities may decline in value due to negative news or fundamental developments specific to the issuer. The rationale for selecting the security either may not be correct or the market may not recognize the value.
Stock Investments: Stock markets are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. In addition, stock investments are subject to risk related to market capitalization as well as company‐specific risk.
ETF Risks: Shares of an ETF may trade on an exchange at prices at, above, or below their most recent NAV. The NAV represents the value of each share’s portion of the ETF’s underlying assets and cash at the end of the trading day. The per‐share NAV of an ETF is calculated at the end of each business day. The trading prices of an ETF's shares fluctuate continuously throughout the trading day based on market supply and demand, which may not correlate to NAV. The trading prices of an ETF's shares may differ significantly from NAV during periods of market volatility, which may, among other factors, lead to the ETF’s shares trading at a premium or discount to NAV. Investment policies, management fees and other information can be found in the individual ETF’s prospectus. Please read the prospectus carefully before you invest. Investors should consider the investment objectives, risks, charges and expenses of each ETF carefully before investing. This and other information are contained in each ETF’s prospectus, which may be obtained by visiting the ETF sponsor’s website. Please read each prospectus carefully before you invest.
Volatility Risk: Plenty’s investment services rely upon historical securities data; past performance is no guarantee of future results and any historical returns, expected returns, or probability projections may not reflect actual future performance.
Tax and Regulatory Risk: Performance of investments may be impacted by government legislation or regulation including, changes in securities trading regulation, changes in the tax code, changes in tax reporting, and changes in income characterization.
Liquidity Risk: The risk that an investor will be unable to buy or sell a security at a reasonable price at a certain point in time. This may occur if there is a limited quantity available or only a few market makers willing to trade. For example, U.S. Treasuries are quite liquid, while an equity security subject to a regulatory halt would be illiquid.
Inflation Risk: The risk that the value of a dollar will not be worth as much as anticipated. That is, inflation will be higher than expected.
Values Based Investing Risk: Clients who choose to modify their investment portfolios for the explicit inclusion or exclusion of specific companies, themes, or industries may result in lower returns compared to non‐modified portfolios.
Portfolio Allocation and Rebalancing: The subadvisor portfolio recommendations may not successfully achieve an investor’s goals for a variety of reasons, including unexpected market events or trends that the algorithm does not anticipate, as well as inaccurate, incomplete, or otherwise faulty data used by the algorithm and/or provided by the investor. While the subadvisor seeks to continually improve its algorithmic system, it does not guarantee it will result in positive returns on investment. In addition, when the subadvisor rebalances the portfolios, it is possible that the system could error and fail to execute a requested trade.
Some of the additional general risks that clients should consider include, but are not limited to:
Software & Technology Risk: Once Plenty gathers clients' interests, goals, and risk tolerance, the Firm’s investment analysis software uses this information to suggest multiple investment portfolios that a client may select. Account rebalances are also executed programmatically using the subadvisor’s proprietary software platform. Clients should note the following risks:
Software may still make incorrect assumptions about a client’s financial situation. There is always a possibility that the simulator may experience technical malfunctions that would cause its recommendations to be inaccurate.
The software can only base its output on the input from the client. As such, the software’s output is only as accurate as the data the client inputs.
The output that the software generates may not assess all of the client’s particular situation. Special circumstances, qualitative characteristics, and other intangible components of a client’s personal background that are not captured by the software may cause the software’s assumptions to be incorrect.
Clients will have tax risk exposure if there are future changes in taxation legislation that impact their net returns.
Item 7: Client Information Provided to the Portfolio Managers
At account opening, Clients provide their age, financial condition, employment status, investment objectives, time horizon, and risk tolerance, Plenty’s goal based financial planning software enables Clients to create a saving and investing plan that helps them plan to meet their goals. Should they choose to invest with Plenty, Clients have the option of money market accounts or stock and bond (or ETFs containing stocks and bonds) based portfolios. These portfolios are provided by Plenty’s subadvisor’s algorithm which constructs, revises, and recommends portfolios with target asset allocations. Client accounts will be managed in accordance with their risk profile and the subadvisor will use its internal algorithm to monitor each Client’s account performance on an ongoing basis and rebalance the portfolio as required by changes in market conditions or other factors. On a periodic basis, Plenty asks Clients to update their profile.
Item 8: Client Contact with Portfolio Managers
We provide our investment services exclusively through the website. You may contact the web application’s customer service during normal business hours for technical assistance or to answer any questions regarding your account. For the avoidance of doubt, our customer service team is not permitted to provide you with investment advice.
Item 9: Additional Information
Disciplinary Information
There are no legal or disciplinary events that are material to a Subscriber’s evaluation of our advisory business or the integrity of our management.
Other Financial Industry Activities and Affiliations
Neither the Firm nor any of its management persons are registered, and do not have an application pending for registration, as a broker‐dealer, broker‐dealer representative, futures commission merchant, commodity pool operator, commodity pool trading adviser, or an associated person of the foregoing entities.
Code of Ethics
The Firm has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act. The Firm believes that high ethical standards are essential if the Firm is to earn and maintain the confidence of the Firm’s investment partners.
The Code is designed to: (i) establish guidelines for professional conduct and personal trading procedures; (ii) prevent improper personal trading by the Firm employees; (iii) prevent improper use of material, non-public information about security recommendations made by the Firm or security holdings of clients; (iv) identify conflicts of interest; and (v) provide a means to resolve any actual or potential conflict in favor of firm clients, and other areas as described fully in the Code.
Compliance with the Code is a condition of employment. Every employee must acknowledge the terms of the Code of Ethics annually, or as amended.
Any employee found to have engaged in improper or unlawful activity faces appropriate administrative and legal action. It is the responsibility of each employee to ensure that they and those they manage are conducting business professionally and are complying with the procedures and policies governing the Firm’s collective responsibility. Any employee becoming aware of others engaged in wrongdoing or improper conduct must immediately report such activity to the Firm’s CCO. Failure to do so may result in additional action being taken against that individual.
The Firm endeavors to ensure that the investment management and overall business of the Firm complies with applicable U.S. federal and state securities laws and regulations.
All employees may invest in the same securities recommended by Plenty to its clients. Our financial professionals may have personal accounts at our firm that are managed like clients’ and may also, with limited exception, have personal accounts held and managed outside of our firm. This could give rise to conflicts of interest if trading by clients is expected to change the value of a security to be purchased or sold by an employee. It could also incentivize employees to favor their personal accounts over clients.’ Plenty, as a fiduciary, endeavors to always make decisions in the best interest of its clients if a conflict of interest arises between the Investment Manager’s transactions on behalf of its clients and those of Plenty’s personnel and related persons. In order to monitor any conflicts of interest, Plenty employees are required to pre-clear certain contemplated transactions in their personal accounts which may present the appearance of impropriety, including investing in securities traded through the Plenty program, and must disclose on an initial and annual basis the holdings of all personal accounts, as well as all transactions on a quarterly basis.
Resolution of Conflicts of Interest. In the case of all conflicts of interest, the Firm’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using the Firm’s best judgment, but in its sole discretion. The Firm seeks to address these potential conflicts through the use of:
A robust Code of Ethics (which is described above).
Annual requirement that Employees complete a questionnaire detailing their other activities and potential conflicts.
Requirement that Employees pre-clear outside business activities (other than outside activities related to charities, non-profit organizations/clubs, civic/trade organizations).
Disclosure of potential conflicts of interests and risks in this Form ADV.
Material Non-Public Information and Insider Trading. The Firm has adopted Insider Trading Policies and Procedures designed to mitigate the risks of the Firm and its employees misusing and misappropriating any material non-public information that they may become aware of, either on behalf of the Firm’s clients or for their own benefit. The policy applies to every employee of the Firm and extends to activities both within and outside of their duties to the Firm, including for an employee’s personal account.
The Firm may from time to time acquire confidential, material non-public information (“MNPI”) about issuers, corporations, or other entities and their securities. The Firm will not use MNPI obtained during making investment decisions for its clients. Additionally, the Firm may not be free to divulge or to act upon such information with respect to its activities and, on occasion, may be restricted from buying or selling certain securities on behalf of clients because of these circumstances. These restrictions may adversely impact the investment performance of client accounts. The Firm has implemented procedures, including those described below relating to information barriers, that prohibit the misuse of such information by the Firm, its employees, and on behalf of its clients. Although the procedures do not provide absolute assurance as to the correct handling of MNPI, these procedures have been reasonably designed to aid the Firm’s personnel in avoiding insider trading, and to aid the Firm in preventing, detecting, and imposing sanctions against, insider trading.
Review of Accounts
Our subadvisor monitors the Client accounts they manage on Plenty’s behalf.
Voting Client Securities
Plenty and its subadvisor will not ask for, nor accept voting authority for Client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security.
Client Referrals and Other Compensation
We do not receive economic benefits from non‐Subscribers for providing investment advice and other advisory services. Neither we, nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for Subscribers referrals.
Promotions: Plenty Financial RIA, LLC has periodic promotions for technology products, fee waivers on management fees, or reduced management fees. Client referrals, or other referral arrangements as outlined below may, from time to time, be combined with promotional offers. Any combination of benefit and promotional items will not result in a Client paying a higher advisory fee. Plenty Financial RIA, LLC will disclose the terms of the promotional offers to Clients at the time of the offer.
Referrals: Plenty Financial RIA, LLC may offer free subscription months for existing subscribers who refer new clients. From time to time, Plenty Financial Inc, may also offer other incentives for client referrals. Plenty Financial Inc will disclose the details of those incentives to existing and referred Clients at the time of the offer. Prospective clients that are referred by existing Clients should be aware that the referring Client will receive an economic benefit for making the referral. The free advisory Services awarded or any other incentive provided does not increase the fees or costs for the referring or referred Client. Referral arrangements create an incentive for third parties and existing Clients to recommend Plenty over other similar advisers which may have lower fees.
Affiliate Marketing Program: Plenty Financial RIA, LLC offers an affiliate marketing program for web‐based authors and participates in co‐registration agreements, where the participants (“affiliate” or “affiliates”) are compensated for each person who uses the affiliates’ webpages to register with Plenty and create a financial profile. These affiliates are eligible for compensation even if the referred person does not become an advisory Client. As a result of these arrangement, affiliates will financially benefit from referring users to Plenty Financial RIA, LLC. This creates a conflict of interest and incentivizes affiliates to present content favorable to Plenty Financial, Inc. because of the compensation structure of the affiliate marketing program.
Other Referral Arrangements: Plenty Financial RIA, LLC enters into referral agreements with third parties who refer prospective clients to Plenty (“Referrer” or “Referrers”) under which Referrers may receive compensation for each individual who creates a Plenty financial profile. Individuals referred by Referrers may also be given a promotional offer for a waiver on management fees or a waiver on subscription fees for a given time period.
Testimonials and Endorsements: Plenty Financial RIA, LLC enters into agreements with Clients and non‐Client Third Parties (“Promoters”) to provide testimonials or endorsements of our Advisory Services. Any advertisement that displays a testimonial or endorsement provided by a promoter will disclose clearly and prominently whether the Promoter i) is a Client of Plenty Financial RIA, LLC, ii) is paid or unpaid, and iii) creates any other material conflict of interest. If the promoter is paid, Plenty Financial
RIA, LLC confirms that the Promoter is not disqualified under Federal Securities Laws and discloses the compensation.
Individuals who become Clients as a result of our various referral programs acknowledge in our client agreement that they have reviewed, read, and understood Plenty Financial RIA, LLC’s disclosures and Form ADV.
Financial Information
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance; therefore, we are not required to provide a balance sheet.
We have not been the subject of a bankruptcy petition at any time during the past ten years, and we do not have any financial circumstances that would impair our ability to meet our contractual responsibilities to our clients.
Form CRS - Client Relationship Summary
Updated as of March 25, 2024
Back to Top ^
Item 1: Introduction
As a financial professional, what is your relevant experience, including your licenses, education, and other qualifications? Do you have any disciplinary history? For what type of conduct?
Plenty Financial RIA, LLC (“Plenty” or the “Firm”) is an investment adviser registered with the U.S. Securities and Exchange Commission. Free and simple tools are available to research firms and financial professionals at https://www.investor.gov/CRS, which also provides educational materials about investment advisers, broker-dealers and investing. To learn more about our backgrounds, education and licenses, advisor specific information may be obtained at www.adviserinfo.sec.gov. Additionally, the Form ADV Part 2A, Appendix 1 (“Wrap Fee Program Brochure”) mentioned in this summary is available at https://adviserinfo.sec.gov.
Item 2: What Investment Services and Advice Can You Provide Me?
Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me?
Description of Services: Plenty provides interactive financial planning tools and access to investment products to fee-based Clients through its website which is described in the Wrap Fee Program Brochure. Plenty provides automated investment services over the internet through a wrap fee program, utilizing an online interactive website. Plenty provides access to money market funds, and stock and bond based portfolios. Plenty will typically use individual stocks or domestic exchange traded funds (“ETFs”) for domestic equity exposure and ETFs are utilized for international equity and treasury/bond exposure. Portfolios are provided through its subadvisor.
Our investment advisory services are discretionary, which means that the algorithm-based portfolios offered will buy and sell securities in your account on your behalf without your prior approval. Clients have the option to additionally create individual investment goals with unique time horizons, risk tolerance, and liquidity needs that lead to the programmatic curation of a custom investment portfolio for each goal. For all investment portfolios, the Client may choose to override the algorithm‐based portfolio
Assets Under Management Fee Minimums: Plenty requires an initial minimum account balance of $100.
Item 3: What Fees Will I Pay?
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 fees will I pay?
Description of Principal Fees & Costs: Fees charged for our asset management services are charged on an annual fee based on a percentage of assets managed or advised, calculated in accordance with each Client’s advisory agreement. The management fee is typically a percentage based on the market value of all assets in the account, including cash holdings and is generally a 0.2% annual management fee. Our parent company, Plenty Financial Inc. also charges a separate annual subscription fee of $100 for access to its educational content and financial planning tools.
Additionally, if we invest in ETFs with underlying management fees, you will be responsible for those underlying fund fees as well. Please see Item 4 of our Wrap Fee Program Brochure.
Additional Information: 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 more information about the fees we charge and the other fees and expenses you will incur, please see Item 4 of our Wrap Fee Program Brochure.
Item 4: What are your legal obligations to me when acting as my investment adviser? How else doesyour firm make money and what conflicts of interest do you have?
How might your conflicts of interest affect me, and how will you address them
Standard of Conduct: When we act as your investment adviser, we are required 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. Our firm makes money from the management fees that you pay us for managing and servicing your account. Our parent company, Plenty Financial Inc. also charges a separate annual subscription fee for access to non-advisory services including financial wellness and educational content.
We actively manage our own personal accounts while at the same time managing your accounts and other Client accounts. This creates different conflicts of interest for which we have developed procedures to mitigate and control for those conflicts. For more information see Item 11 of Form ADV Part 2A.
Additional Information: For more information about our conflicts of interests and the ways we are compensated, please see Item 5 and Item 10 of our Form ADV Part 2A.
Item 5: How do your financial professionals make money?
Description of Salary/Payment of Financial Professionals: Our financial professionals are paid a fixed salary and do not have any incentive-based compensation structures. All employees of Plenty Financial RIA are eligible to receive a discretionary bonus, as determined by management.
Item 6: Do you or your financial professionals have legal or disciplinary history?
No. Neither the firm, nor our employees have a legal or disciplinary history to report. You can look up more information about us and our investment adviser representatives at https://www.investor.gov/CRS.
Item 7: Additional Information
Who is my primary contact person? Is he or she a representative of an investment advisor or a broker-dealer? Who can I speak to if I have concerns about how this person is treating me?
Additional information about Plenty Financial RIA is available at https://www.withplenty.com/. You can also find our disclosure brochures and other information about us at https://adviserinfo.sec.gov. If you would like a copy of our Wrap Program Brochure disclosure brochure and/or have any questions or want an up-to-date copy of this relationship summary, we can be reached by phone at (628) 333-3863, where you will speak to an investment advisor, who is a representative of the firm. If you have concerns about your financial advisor, you may request to speak to the Chief Compliance Officer at Plenty Financial RIA.