Item 5 Fees and Compensation
Front does not currently charge any fees for basic advisory services and/or access to the app.
Currently, basic services include establishing a user account on the app, provision of single stock Front
Scores, linking of outside brokerage accounts, and provision of aggregated Front Score for such
portfolios. Front offers a premium service for which it will charge an access fee of $9.99 per month for
activities such as Front Score-based portfolio optimization. Fees for such premium services are
assessed on a monthly basis, in advance where clients elect to purchase a subscription to such
services. Currently, transaction facilitation is included in basic services, however, this service may be
identified as a part of Front’s premium services in the future and would therefore be accessible to
premium users who pay the monthly subscription fee. Additionally, Clients will incur brokerage and
Front Financial, Inc.
other transaction costs associated with transactions effected in their accounts as agreed upon with
each of their respective brokers and custodians. Clients should be aware of these transaction-related
fees, as well as any other fees associated with the maintenance of their brokerage account(s). Front
does not currently receive any payments from brokers, custodians or any other third parties relating
to its provision of investment advisory services.
Front compensates individuals for reviews, feedback, social media “mentions” (i.e., naming or
discussing Front on an individual or group’s social media profile), and opinions about Front and its
platform and related services. Any client’s statement of his or her experience with, or approval of
Front will be treated as testimonial, and any statement or endorsement made by a third-party about
Front’s services will be treated as an endorsement. Such endorsements or testimonials inherently
pose a conflict of interest and are considered misleading without proper disclosure and due diligence.
In addition, Front engages in cross-promotion with select third-parties whose services Front
recommends to clients. This creates a conflict of interest due to the fact that such cross-promotion
and related revenue sharing between third-parties and Front incentivizes Front to recommend such
third-party services to clients. All such relationships and related conflicts are disclosed to clients at the
time of promotion or recommendation of third-party services. Front associates itself with reputable
vendors who Front believes will provide beneficial services to clients.
Any arrangement whereby individuals or groups post reviews or opinions for which they were
compensated by Front are disclosed as such, as well as the fact that the review, feedback, or opinion is
representative of the reviewer’s own experience and not necessarily that of every Front Financial
client. Front performs due diligence to screen for “bad actors” prior to entering into any agreement
regarding testimonials and/or endorsements. Front is not responsible for providing disclosure for
unsolicited endorsements posted by third-parties and may share articles or statements relating to
such endorsements, provided they do not also include statements made by clients regarding their
experience with Front (i.e., testimonials).
Front’s management of its own social platform also poses a conflict of interest due to Front’s control
of the content. Front monitors content and reserves the right to remove harmful or abusive
commentary or any comments or posts that violate its Community Standards from its Social Platform.
However, Front does not remove negative opinions about Front or display positive comments to
visible locations on the platform. All commentary on the Social Platform is displayed fairly in equal
measure.