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Disclosures

Advisory Business

Brains Investments, LLC was established in 2018. Christopher Poillon is the founder and President and has been in the financial services industry since 1992. Advisory Services Brains Investments LLC provides management services called Brains World View, which provides users with a recommended portfolio based on their world view, interests, and lifestyle. As of May 15, 2019, Brains Investments LLC has $0 assets under managementon a discretionary basis, and $0 of assets under management on a non-discretionary basis. Services are based on the individual needs of the client. An initial data gathering questionnaire is undertaken to determine the client's financial situation and investment objectives. Clients will receive from the custodian/brokerage firm timely confirmations and at least quarterly statements containing a description of all transactions and all account activity. The client will retain rights of ownership of all securities and funds in the account to the same extent as if the client held the securities and funds outside theprogram. In addition to custodial statements. Brains Investments LLC sends quarterly reports to the client through their custodian. Brains Investments LLC provides investment options consistent with the individual client's financial and risk/reward objectives.

Fees and Compensation

Fees for advisory services are at the monthly rate of $3 per month up to account balances of $5,000, and .25% of account balances above $5,000. Advisory fees are charged monthly through our custodian. These fees are for advisory services only and do not include any transaction fees or commissions, which may be charged separately by the broker/dealer custodial firm. See the section heading Brokerage Practices for more information. The first payment is assessed and due at the end of the first calendar month and will be assessed pro rata in the event the Agreement is executed at any time other than the first day of the current calendar quarter. Subsequent payments are due and will be assessed on the first day after the end of each calendar monthbased on the value of the account assets under managementas of the close of business on the last business day of that month. The custodian holding client funds and securities will deduct Brains Investments LLC advisory fees direct from the client account in accordance with statements prepared and submitted to the custodian by Brains Investments LLC. The custodian will provide periodic account statements to the client. Such statements will reflect all fee withdrawals by Brains Investments LLC. It is the client’s responsibility to verify the accuracy of the fee calculation. The custodian will not determine whether the fee is properly calculated. Fees are not negotiable. Brains Investments LLC is deemed to be a Fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, Brains Investments LLC is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. Brains Investments LLC only charges asset management or financial planning fees for our services and does not receive any commissions, 12b-1fees or other forms compensation. Fees are not collected for services to be performed more than six months in advance. Services will continue until either party terminates the Agreement on 30 business days written notice. If termination occurs prior to the end of a calendar month, the client will be invoiced for fees due on a pro-rata basis. If termination occurs prior to the end of a calendar month, a pro-rata refund of unearned fees will be made to the client. The Advisory Agreement contains a pre-dispute arbitration clause. Client understands that the agreement to arbitrate does not constitute a waiver of the right to seek a judicial forum where such a waiver would be void under the federal securities laws. Arbitration is final and binding on the parties.

Types of Clients and Account Minimums

Brains Investments LLC provides advisory services to individuals. Generally, the minimum account size is $50, subject to a minimum annual fee of $3.

Methods of Analysis, Investment Strategies, and Risk of Loss

Analysis utilized includes charting, fundamental, technical, and cyclical. Brains Investments LLC uses asset allocation strategies for portfolio management. By its nature, financial planning looks to the long-term. While there is risk in all investments, some carry a greater degree of risk or higher costs. There is no guarantee that the investment strategy selected for the client will result in the client’s goals being met, nor is there any guarantee of profit or protection from loss. For those investments sold by prospectus, clients should read the prospectus in full. Brains Investments LLC is disclosing those risks and opportunities for our investment strategy or for particular types of securities used. Debt securities are subject to interest rate risk...

  • There are tax consequences for short-term trading wherein capital gains are taxed as ordinary income.
  • Our investment style is a diversified approach, with the goal of reducing risks by spreading investments across multiple short-medium risk securities. Nonetheless, if the market overall goes down due to a recession, depression, or market correction, customers’ portfolios will decline in kind as Brains selects equity options across the Fortune 1000 list.

Disciplinary Informationain

An investment advisor must disclose material facts about any legal or disciplinary event that is material to aclient’s evaluation of the advisory business or of the integrity of its management personnel. Brains Investments, LLC does not have any disclosure items.

Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading

Code of Ethics

Brains Investments LLC maintains a Code of Ethics. The Code of Ethics sets forth standards of conduct expected of advisory personnel; requires compliance with federal securities laws; and, addresses conflicts that arise from personal trading by advisory personnel. Clients mayrequest a copy of the Code of Ethics.

Personal Trading

At times Brains Investments LLC and/or its IA Reps may take positions in the same securities as clients, and we will try to avoid conflicts with clients. The firm and its IA Reps will generally be “last in” and “last out” for the trading day when trading occurs in close proximity toclient trades. We will not violate our fiduciary responsibilities to our clients. Scalping (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading.

Buffer and Sweep

When a customer places an order to purchase securities through our Brains platform, Brains holds back 2% of this order as a buffer to account for the expected price difference of the securities at the time the order was placed and the time it was executed in the market. Any remaining funds from this sweep will be held in the customer’s cash account with our custodian. Brains may increase or decrease this 2% buffer at our discretion, given market conditions.

Refer a Friend Promotion (June 1, 2020 – September 30, 2020)

Brains Members can refer up to 100 friends for this promotion. Members who refer friends to join Brains can receive $100 per friend. Friends must sign up to become a Member (investing at least $50 through their Brains account) by September 30, 2020. In order for a Member to receive the $100 promotion, both the Member and their friend must have a verified account in good standing. Bonuses will be paid out one year after their friend invests their first $50 at Brains. Referees and Referrers who close their account before that one year period, make an investment that results in a reversal from their bank, or accounts that are otherwise not in good standing will not qualify for the promotion. Referral awards are made at the sole discretion of Brains. Rewards for inviting friends to join Brains are a limited time offer. Rewards are in the form of a purchase of investments in your Brains portfolio, which are at the sole discretion of Brains. Brains reserves the right to restrict or revoke this offer at any time, including setting a limit on the number of friends you can refer. Brains retains the right to extend the one year period to pay out promotion bonuses, and the referral amount is subject to change at discretion of Brains Investments LLC.

Review of Accounts and Reports on Accounts

Brains Investments LLC monitors the individual investments regularly. Portfolio performance is reviewed on a quarterly basis at a minimum. Our equity groupings are reviewed at a minimum of once per quarter. Market conditions that might cause a wide variance in the specified asset allocation, or other factors could cause a more frequent review. Customers portfolios and holdings are a snapshot in time and no ongoing reviews are conducted. We recommend clients engage in our Brains model, Discussion Board, and Library regularly. Reports All clients receive standard account statements and clients receive a written quarterly performance report from Brains Investments LLC’s broker/dealer.

Client Referrals & Other Compensation

Referral Fees Paid Brains Investments LLC may compensate for client referrals. All solicitor’s agreements are in compliance with the Investment Advisers Act of 1940. In addition, all applicable federal and state laws will also be observed. All clients procured by solicitors will be given full written disclosures describing the terms and fee arrangements between the advisor and the solicitor prior to or at the time of entering into the advisory agreement.

Custody

Although client assets are held at a third-party independent custodian, Brains Investments LLC is deemed to have custody of client funds because of the fee deduction authority granted by the client in the investment advisory agreement. Except for this fee deduction, we do not have authority to withdraw funds out of client accounts. If/when a client grants Brains Investments LLC the limited power in a Standing Letter of Authorization (“SLOA”) to the account custodian to disburse funds to a third party, we would be deemed to have custody. Under such circumstances, our firm will follow regulatory guidance in documenting this procedure. Inadvertent custody may occur if/when the custodial agreement signed by the client may grant our firm broader access to client funds or securities than our own agreement with the client contemplates. Under such circumstances, our firm will follow regulatory guidance in documenting this procedure. Clients will receive account statements at least quarterly from the broker-dealer or other qualified custodian. Client is urged to compare custodial account statements against statements prepared by Brains Investments LLC for accuracy. Minor variations may occur because of reporting dates, accrual methods of interest and dividends, and other factors. The custodial statement is the official record of your account for tax purposes.

Investment Discretion

Brains Investments LLC does not have discretion over any client accounts. A limited power of attorney, limited to the power of executing trades on a non-discretionary basis will be obtained from clients. Brains Investments LLC will not have authority to withdraw funds or to take custody of client funds or securities, other than under the terms of the Fee Payment Authorization clause in the Agreement with the client. Brains Investments LLC does have the ability to discount brokerage commissions.

Voting Client Securities

Brains Investments LLC does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Questions about proxies may be made via the contact information on the cover page.

Financial Information

An investment advisor must provide financial information if a threshold of fee prepayments is met; there is a financial condition likely to impair the ability to meet contractual commitments; or, a bankruptcy within the past ten years. Brains Investments, LLC does not have any disclosure items in this section.

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