Effective Date: Upon First API Use
Version: 2.1
Last Updated: March 2026
PLEASE READ THIS ENTIRE DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION ABOUT THE NATURE, LIMITATIONS, AND RISKS OF THE API SERVICES AND DEFINES THE PERMISSIBLE USES OF API DATA.
Advisory API Systems LLC is registered as an investment advisor with the State of California (CRD #330083). Our firm’s Form ADV Parts 2A and 2B (brochure and brochure supplement) are delivered to all Clients via hyperlinks on the web interface at https://www.ria.us/api/api.html and on the Company’s home page at https://www.ria.us. Individual Clients are asked to acknowledge receipt and review of these documents before submitting any API request or payment. Additional copies are available upon request to [email protected] and at www.adviserinfo.sec.gov.
The Portfolio Optimization API provides investment advice to two categories of clients: (a) licensed investment advisers (“RIA Clients”) in a business-to-business capacity, and (b) individual members of the public (“Individual Clients”) in a business-to-consumer capacity. The API implements portfolio optimization methodologies based on modern portfolio theory, including:
API outputs include specific ETF allocations with dollar amounts and strategy recommendations.
RIA Clients: Advisory API Systems provides portfolio optimization analysis, including specific securities allocations and strategy recommendations, to RIA Clients in a business-to-business capacity. These outputs constitute investment advice provided to the RIA Client—a licensed investment adviser—not to the RIA Client’s clients (“End Users”). The RIA Client, as a licensed fiduciary, exercises independent professional judgment in determining whether and how to implement any API outputs for End Users. Advisory API Systems has no contractual, advisory, or fiduciary relationship with End Users.
Individual Clients: Advisory API Systems provides portfolio optimization analysis directly to Individual Clients who access the API or web interface on their own behalf. These outputs constitute investment advice provided directly to the Individual Client, with whom Advisory API Systems has a direct advisory and fiduciary relationship. Individual Clients are solely responsible for deciding whether and how to implement the recommendations. Advisory API Systems does not have discretionary authority over any Individual Client accounts.
Because Advisory API Systems is registered as an investment adviser only in California, by using the API, you represent and warrant that:
(a) If you are a registered investment adviser entity (RIA Client), your principal place of business is in California; or if you are an individual acting as a supervised person of a registered investment adviser (RIA Client), you reside in California;
(b) If you are an individual member of the public (Individual Client), you reside in California.
If you are an RIA Client, you further represent and warrant that you:
(a) Are a registered investment advisor (state or SEC registered), or a supervised person of a registered investment advisor, or operate under an applicable exemption from registration;
(b) Hold all licenses, registrations, and authorizations required by applicable federal and state laws to provide investment advisory services in all jurisdictions where you operate;
(c) Maintain current compliance with all applicable regulatory requirements;
(d) Have designated a chief compliance officer responsible for ensuring compliance with applicable securities laws.
If you are an RIA Client, you acknowledge that you—not Advisory API Systems—owe a fiduciary duty to your end clients (End Users). You are solely responsible for:
(a) Determining the suitability of investment recommendations for each End User;
(b) Understanding each End User’s financial situation, investment objectives, risk tolerance, and constraints;
(c) Making appropriate disclosures to End Users;
(d) Ensuring recommendations are in the best interest of End Users.
If you are an Individual Client, you acknowledge that:
(a) API outputs are generated by mathematical algorithms based on the data you provide;
(b) The quality and appropriateness of recommendations depend on the accuracy and completeness of the data you enter;
(c) You are solely responsible for deciding whether to implement the recommendations;
(d) You should consider consulting with a qualified financial adviser if you are unsure about any recommendation;
(e) All investments involve risk, including possible loss of principal.
If you are an RIA Client, you acknowledge that API outputs are one input among many that should inform your professional judgment. You shall:
(a) Exercise independent professional judgment in evaluating API outputs before implementation;
(b) Consider factors not captured by the API that may be relevant to each End User;
(c) Not present API outputs as guaranteed or risk-free strategies;
(d) Modify, reject, or supplement API outputs as appropriate for each End User.
RIA Clients may use the API and API Data to:
(a) Generate portfolio allocation recommendations for End Users;
(b) Support the RIA Client’s investment advisory process and decision-making;
(c) Create reports and visualizations for End User presentations;
(d) Conduct research and analysis for the RIA Client’s internal purposes;
(e) Integrate with the RIA Client’s existing advisory platforms and workflows.
Individual Clients may use the API and API Data to:
(a) Generate portfolio allocation recommendations for their own personal use;
(b) Support their own investment decision-making;
(c) Conduct research and analysis for their own purposes.
Users shall NOT use the API or API Data to:
(a) Unlicensed Advisory Services: Provide investment advice to others without proper licensing and registration;
(b) Fully Automated Advice (RIA Clients): Provide fully automated investment advice to End Users without appropriate human oversight and suitability review;
(c) Misleading Representations: Represent API outputs as guarantees, predictions, or certainties;
(d) Unsuitable Recommendations (RIA Clients): Implement recommendations for End Users without considering individual End User circumstances;
(e) Competing Products: Develop or offer products or services that compete with Advisory API Systems;
(f) Data Resale: Sell or redistribute API Data to third parties except as incorporated into services provided by RIA Clients to End Users;
(g) Regulatory Evasion: Evade or circumvent securities laws or regulations;
(h) Unlawful Purposes: Any purpose that violates applicable law.
ALL INVESTMENTS INVOLVE RISK, INCLUDING THE POSSIBLE LOSS OF PRINCIPAL. The risks associated with investment portfolios may include, but are not limited to:
Market Risk: The value of investments may decline due to general market conditions, economic factors, or events affecting specific sectors or companies.
Interest Rate Risk: Changes in interest rates may adversely affect the value of fixed-income investments and the present value of future cash flows.
Inflation Risk: Investment returns may not keep pace with inflation, resulting in a loss of purchasing power.
Liquidity Risk: Certain investments may be difficult to sell quickly at fair market value.
Foreign Exchange Risk: Investments denominated in foreign currencies may be affected by exchange rate fluctuations.
Credit Risk: Issuers of debt securities may default on their obligations.
Concentration Risk: Portfolios concentrated in particular sectors or asset classes may experience greater volatility.
Longevity Risk: Individuals may outlive their investment portfolios.
ADVISORY API SYSTEMS MAKES NO REPRESENTATION OR WARRANTY THAT:
(a) Any investment strategy will be successful;
(b) Portfolio returns will match historical patterns or projections;
(c) Investment objectives will be achieved;
(d) Losses will be avoided or limited.
PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS.
The API utilizes mathematical models that have inherent limitations. Model risk is the risk that a model used to estimate values or guide decisions produces inaccurate outputs, leading to adverse consequences.
Users acknowledge that the API models:
(a) Rely on Assumptions: Models are built on assumptions that may not hold in all market conditions. Key assumptions include market efficiency, log-normal return distributions, stable correlations, and rational investor behavior.
(b) Use Historical Data: Projections incorporate historical data that may not be representative of future conditions.
(c) Simplify Reality: Models necessarily simplify complex financial realities. Factors not captured by the model may significantly affect outcomes.
(d) Depend on Inputs: Model outputs are only as reliable as the inputs provided. Inaccurate, incomplete, or outdated inputs will produce unreliable outputs.
(e) Cannot Predict Black Swan Events: Models cannot anticipate rare, high-impact events that fall outside historical experience.
The API’s treatment of background assets (Social Security, pensions, Medicare, Medicare Savings Programs, Supplemental Security Income, real estate, human capital) involves estimates and projections that are subject to:
(a) Policy Changes: Government benefits may change due to legislative or regulatory action;
(b) Valuation Uncertainty: Present values of future benefits depend on discount rate assumptions;
(c) Mortality Risk: Life expectancy projections are probabilistic estimates;
(d) Employment Risk: Human capital projections assume continued employment;
(e) Means-Test Eligibility Risk: Eligibility for the Medicare Savings Programs (QMB, SLMB, QI, QDWI) and Supplemental Security Income depends on income and resource tests that may change over time; a client’s projected eligibility may not match actual eligibility at any given point in the future. Federal income and resource limits are indexed (or, in the case of SSI resources, not indexed) by statute, and California state-level eligibility rules may differ from the federal defaults applied by the API.
RIA Clients are responsible for understanding model assumptions and limitations, validating that model assumptions are appropriate for each End User, communicating limitations to End Users, and supplementing model outputs with professional judgment. Individual Clients are responsible for understanding model assumptions and limitations before acting on any API recommendations.
If you are an RIA Client, you shall provide the following disclosures (or substantially similar disclosures) to End Users:
(a) Nature of Recommendations: That investment recommendations are based in part on mathematical models with inherent limitations;
(b) Risk Warnings: That all investments involve risk, including possible loss of principal;
(c) No Guarantees: That past performance is not indicative of future results and that no investment strategy can guarantee success;
(d) Model Limitations: That mathematical models cannot predict all market conditions or outcomes;
(e) Professional Oversight: That recommendations involve professional judgment and are subject to the RIA Client’s independent analysis.
If you are an RIA Client, you shall ensure that your Form ADV Part 2A appropriately describes your use of algorithmic tools and models in the investment advisory process.
Users shall NOT represent to any person that:
(a) API outputs are guaranteed or risk-free;
(b) The API can predict market movements;
(c) Losses are not possible;
(d) Advisory API Systems provides advice directly to End Users (applicable to RIA Clients);
(e) Advisory API Systems guarantees any results.
The API may incorporate tax optimization algorithms. However:
THE API DOES NOT PROVIDE TAX, LEGAL, OR ACCOUNTING ADVICE. Tax calculations and projections are estimates based on current law and should not be relied upon without consultation with qualified tax professionals.
Tax laws change frequently. API tax parameters are updated periodically but may not reflect the most recent legislative changes.
Tax implications vary based on individual circumstances. The API cannot account for all factors that may affect a particular User’s or End User’s tax situation.
Advisory API Systems does not have any material conflicts of interest with regard to the investment advice it renders to Users. Neither the firm nor any of its investment adviser representatives, affiliates, or associated persons receives fees, commissions, or other compensation from: (a) the sale of insurance or real estate; (b) the sale of securities or any other products or services recommended in the investment advice provided; or (c) any ETF sponsor, fund company, or other third party whose products may be included in API recommendations.
The API’s portfolio recommendations may include specific ETF allocations with dollar amounts. Advisory API Systems does not receive revenue-sharing payments, distribution fees (12b-1 fees), placement fees, or any other form of compensation from any ETF sponsor or fund family in connection with these recommendations. The sole source of the Company’s revenue is the flat per-use fee charged to Users.
All material conflicts of interest regarding the firm, its representatives, or employees which could reasonably introduce a bias in, or impair the objectivity of, the Company’s investment advice have been, or will be, disclosed to Users. A full discussion of conflicts of interest is set forth in the Company’s Form ADV Part 2A, available at https://www.ria.us and at www.adviserinfo.sec.gov (CRD #330083).
THE API AND API DATA ARE PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. ADVISORY API SYSTEMS DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:
(a) Warranties of merchantability;
(b) Warranties of fitness for a particular purpose;
(c) Warranties of accuracy or reliability;
(d) Warranties of non-infringement.
Advisory API Systems does not guarantee uninterrupted access to the API. Service levels are set forth in the Service Level Agreement.
API calculations may incorporate data from third-party sources. Advisory API Systems does not warrant the accuracy or completeness of third-party data.
ADVISORY API SYSTEMS SHALL NOT BE LIABLE FOR ANY INVESTMENT LOSSES INCURRED BY ANY USER, END USER, OR ANY OTHER PARTY, regardless of whether such losses result from:
(a) Use of or reliance upon API outputs;
(b) Model errors or limitations;
(c) Inaccurate inputs;
(d) Failure to achieve projected results;
(e) Market conditions;
(f) Any other cause related to investment performance.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, ADVISORY API SYSTEMS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES.
In no event shall Advisory API Systems’ total liability exceed the fees paid by User during the twelve (12) months preceding the claim.
If User becomes subject to regulatory examination or inquiry related to User’s use of the API, Advisory API Systems will cooperate reasonably with such examination, subject to applicable confidentiality protections.
User shall promptly notify Advisory API Systems of any regulatory inquiry specifically concerning the API or Advisory API Systems.
Advisory API Systems does not provide advice on regulatory compliance matters. Users should consult with qualified legal counsel.
BY USING THE API, YOU ACKNOWLEDGE AND AGREE THAT:
You have read and understood this Investment Advice Disclaimer and Limitation of Use;
You understand the risks of investing and the limitations of mathematical models;
You accept responsibility for your own investment decisions and, if you are an RIA Client, for all investment recommendations made to End Users;
You will comply with all applicable laws and regulations;
If you are an RIA Client: Advisory API Systems provides investment advice to you in a B2B capacity, not to End Users, and you retain full fiduciary responsibility to End Users;
If you are an Individual Client: Advisory API Systems provides investment advice directly to you, and you are solely responsible for deciding whether and how to implement recommendations.
Advisory API Systems LLC
Email: [email protected]
Phone: (310) 839-0358
SEC Public Disclosure:
Additional information about Advisory API Systems LLC is available at www.adviserinfo.sec.gov (CRD #330083).
This Investment Advice Disclaimer and Limitation of Use is incorporated by reference into the User Agreement. By using the API, you acknowledge and agree to all terms set forth herein.