Item 5 Fees and Compensation
Additional Fees and Expenses
A. Services and Fees
1. Program Overview and Features
Ant Money Advisors offers various investment services through the ATM.com, Inc. Investment
Program (the "Program").
The Program will be available just to individuals who are U.S. tax residents:
• ATM.com Clients: Users of the ATM.com app can earn money through revenue sharing of
advertising income and rewards received by ATM.com, Inc. ("ATMI"), an affiliate of
AMA. ATM.com users have an option to direct their earnings to the Program.
• There is an account minimum of $5 to open a new Client Account, which AMA can waive in its
discretion.
AMA establishes for each individual who participates in the Program ("Client") a securities account
("Client Account") through a financial institution AMA selects to help administer the Program (the
"Custodian"). AMA offers portfolio management and investment advisory services for Client
Accounts.
AMA arranges for a qualified Custodian to perform, among other things, one or more of the following
functions:
• maintaining each Client Account;
• holding each Client's securities and money in safekeeping;
• preparing and delivering to the Client periodic statements of holdings and activities in Client
Accounts;
• tax withholding and reporting for Client Accounts;
• executing, clearing, settling, and making available confirmations of transactions in Client
Accounts; processing deposits, withdrawals, disbursements, receipts and deliveries of Clients'
money and securities into and out of Client Accounts.
AMA communicates with the Custodian on Clients' behalf as necessary to conduct the Program and
Program-related transactions in Client Accounts.
The portfolio management services AMA provides in the Program consist of the following for each
Client Account (for each Client, the "Model Portfolio"):
• developing a model portfolio with target asset allocations ("Core Portfolio") comprised of
shares of exchange-traded funds ("ETFs");
• investing Core Portfolios for each Client Account in combinations of ETFs according to
proprietary algorithms in relative proportions that approximate the applicable Model Portfolio;
and
• adjusting applicable client holdings of ETFs in AMA's discretion in circumstances described
below by buying and selling ETF shares according to proprietary algorithms to continue to
approximate the Model Portfolio on an ongoing basis ("Rebalancing").
AMA offers an initial Model Portfolio comprised solely of ETFs. AMA may in the future, depending on
how its investing strategy evolves or opportunities arise, develop additional Model Portfolios and may
in the future invest all or part of any Model Portfolio in investment products other than ETFs, including
mutual funds or individual securities.
AMA conducts Rebalancing in the following circumstances:
• When a Client requests a deposit of money into, withdrawal of money from, or purchase or sale
of an Eligible Stock (as defined below) in a Client Account, AMA's algorithm automatically
trades a combination of ETF and, if applicable, Eligible Stock purchases or sales designed to
make the Client's Core Portfolio continue to approximate the Model Portfolio and to bring each
Eligible Stock holding closer to five percent of a Client Account value after the deposit or
withdrawal;
• AMA's algorithms will conduct automatic Rebalancing at least annually if the allocation of a
particular ETF in a Client Account diverges from the target allocation for that holding according
to the Model Portfolio by five percent or more of the total value of the applicable Client Account
at the previous close;
• The automatic Rebalancing will also include selling holdings of an Eligible Stock that exceed
five percent of the total value of the applicable Client Account at the previous close if that
Eligible Stock accounts for ten percent or more of the total value of the applicable Client
Account at the previous close.
AMA utilizes best efforts to make Client Accounts track the Model Portfolio through market fluctuation,
withdrawals, deposits, and other events that may cause deviations. There is no guarantee that the
allocations of holdings in any Client Account, match or approach the allocations of holdings in the
Model Portfolio or any other Client Account at any time.
Rebalancing does not take into account Clients' tax or legal situations. Clients should consult with a tax
or legal professional regarding questions about the tax or legal treatment of Rebalancing and other
transactions in the Program.
AMA's algorithm reinvests dividends automatically.
Clients may choose to impose reasonable management restrictions on their account by excluding from
their Core Portfolio one of the ETFs that otherwise comprise the Model Portfolio. Clients should only do
so after carefully reviewing and analyzing all pertinent information about the Model Portfolio available
on the AMA website or through the mobile device app. Clients may make restriction requests (or seek
to reverse such requests) at any time by emailing info@antmoneyadvisors.com. Due to the relatively
small number of ETFs in the Model Portfolio, it would not be reasonable to request the exclusion of
more than one ETF from any Core Portfolio. Excluding an ETF from a Selected Portfolio may
adversely impact its performance and may not be suitable with respect to a Client's investment
objectives, risk tolerance, age, financial condition or other facts and circumstances.
Explore Portfolio
AMA has designed the Explore Portfolio feature for Clients to learn to research and select individual
Eligible Stocks from the Eligible Stock List so they can pursue long-term "buy-and- hold" investment
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