Composer Technologies Inc

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Composer Technologies Inc
CRD #311289
SEC #801-119952
CIK #
AUM
Employees 7 (29% Investors, 0% Brokers)
Fees
Minimum
Phone647-254-3904
Address240 Richmond Street W
Toronto Ontario, Canada
Source [IAPD] [Website] [Twitter] [LinkedIn]
Total AUM ($M)
504030201002009201420192025
Fees and Compensation — Form ADV Part 2A (3/14/2024) [Brochure]
Item 5 Fees and Compensation

Management Fees

The Platform gives Clients the opportunity to test Model Portfolios on a trial-basis at no cost
without the payment of any funds or making any real investments (the “Test Client”). Test Clients
are afforded the opportunity to sample the Model Portfolios on a trial basis and test how such Test
Client would have performed if such Client had actually invested real funds into the Model
Portfolios. Thereafter, if the Test Client choses to become a Client by using actual funds to invest
in the Model Portfolios, the Platform charges a fixed monthly “subscription” fee for investment
advisory services of $30 per month or $288 annually (the “Subscription Fee”). The Subscription
Fee is not based upon the total assets or transactions in a Client’s Investment Account, but rather
is an upfront fee charged for access to Composer’s Platform.

There is a $50 minimum to open an account with Composer. Composer believes the Subscription
Fee is reasonable considering the quality and scope of the services it provides and the fees charged
by other investment advisers offering similar services/programs. However, by participating in the
Subscription Fee program, Clients may end up paying more or less than they would with other
registered investment advisers who charge a wrap fee calculated as a fixed or tiered percentage of
the assets managed, or charge a higher or lower subscription fee. Clients could also invest in ETFs,
stocks and other securities directly without Composer’s services. In that case, Clients would not
receive the services provided by Composer, which are designed, among other things, to assist in
determining which investments are appropriate for the Client’s Investment Account. Clients
should be aware that Composer is designed with frequent investing in mind. The fee structure may
not be appropriate for individuals looking to make few or infrequent small-dollar investments. The
Subscription Fee will be paid by direct debit from the Client’s bank account. In the event Composer
cannot debit Subscription Fees from the Client’s bank account, it reserves the right to terminate a
Client’s access to its advisory services. Each Client may also terminate at Composer’s services at
any time.

Other Account Fees

In connection with the Composer’s advisory services, and any purchase or sales by a Client, Clients
may incur fees and/or expenses separate from Composer’s services. A Client may incur certain
charges imposed by custodians and other third parties. These include transfer fees, brokerage fees,
administrative fees and other fees and taxes on brokerage accounts and securities transactions. The
issuer of some of the securities or products purchased for Clients, such as ETFs or other similar
financial products, may charge product fees that affect Clients. Composer does not charge these
fees to Clients and does not benefit directly or indirectly from any such fees. Additionally, 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. These fees are in addition to the management fee Clients pay to
Composer. Clients should review all fees charged to fully understand the total amount of fees they
will pay.
Account Minimums and Types of Clients — Form ADV Part 2A (3/14/2024) [Brochure]
Item 7 Types of Clients

Composer’s Platform is intended for use by anyone to gain access to customized portfolios built
from ETFs and publicly traded equities.
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 1,800 20.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 1,515 20.0
By Discretionary
Discretionary 313 1.7
Non-Discretionary 1,202 18.3
Total 1,515 20.0
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 20.0
Total 1,515 20.0
Firm Profile (Form ADV)
Discretionary AUM$0.0B
ServesRetail
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