1 Cover page

Firm name: Advisory API Systems LLC
Firm CRD number: 330083
Firm address: 10667 Cranks Road, Culver City, CA 90230
Firm phone number: (310) 839-0358
Firm email address: [email protected]
Firm chief compliance officer: Thomas Seehusen

This brochure provides information about the qualifications and business practices of Advisory API Systems LLC. If you have any questions about the contents of this brochure, please contact us by phone at (310) 839-0358, or by email at [email protected]. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.

Additional information about Advisory API Systems LLC is available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov, which displays registration information for both SEC-registered and state-registered investment advisers.

Please note that use of the term “registered investment adviser" or “registered" to describe Advisory API Systems LLC or its associates does not imply a certain level of skill or training. You are encouraged to review this brochure and brochure supplements for more information on the qualifications of our firm, its officers, or employees.

2 Material changes

Advisory API Systems LLC (“the Firm" or “Us") is required by law to inform you of any material changes made to our firm brochure since its previous annual update. However, we are not required to provide this information to a client, or prospective client, who has not received a previous version of our brochure.

Advisory API Systems LLC is a registered investment advisor in the state of California. The following material changes have been made to our brochure:

• Expansion to Retail Clients: The Firm now offers its portfolio optimization API to two categories of Clients: (1) other registered investment advisers (“RIA Clients") in a business-to-business (B2B) capacity, and (2) individual members of the public (“Individual Clients") in a business-to-consumer (B2C) capacity. Previously, the Firm served only other registered investment advisers.

• Change in Fee Structure: The Firm charges Individual Clients a flat fee of $79.95 per API use, and charges RIA Clients on a graduated monthly tier schedule ($34.95 per call for the first 25 calls in a calendar month, $27.95 per call for calls 26 through 100, and $21.95 per call thereafter), as set forth in Schedule A of the User Agreement.

• Client Eligibility: Because the Firm is registered only in California, all Clients must reside in or maintain their principal place of business in California.

New, or prospective, Clients are asked to read this entire brochure and its supplements before using the Firm’s API services.

The firm’s brochure is available upon request by contacting its chief compliance officer, Thomas Seehusen, by phone at (310) 839-0358, or by email at [email protected].

3 Table of contents

Go to the beginning of this brochure.

4 Advisory business

4.1 About our firm

Advisory API Systems LLC provides investment advice through a portfolio optimization application programming interface (API) and web interface to two categories of clients: (1) other registered investment advisers (“RIA Clients") and (2) individual members of the public (“Individual Clients"). The firm was formed in early 2024 and is registered as an investment advisor in the state of California. Thomas Seehusen is the sole owner and managing member of Advisory API Systems LLC.

4.2 Types of investment advice we offer

Advisory API Systems LLC provides investment advice to two categories of clients through its portfolio optimization application programming interface (API): (1) other registered investment advisers (“RIA Clients") in a business-to-business (B2B) capacity, and (2) individual members of the public (“Individual Clients") in a business-to-consumer (B2C) capacity.¹ The Firm delivers investment advice through its Portfolio Optimization API, which provides specific portfolio allocation recommendations including ETF allocations with dollar amounts. Detailed descriptions of the type of investment advice we offer can be found below in sections 4.3 and 8.1.

RIA Clients: When the Firm provides investment advice to RIA Clients, the Firm’s advisory relationship is with the RIA Client—not with the RIA Client’s end clients (“End Users"). RIA Clients are licensed investment advisers who exercise independent professional judgment in determining whether and how to implement any API outputs for their End Users. The Firm has no contractual, advisory, or fiduciary relationship with End Users. The Firm does not know the identities of End Users and does not communicate with them.

Individual Clients: When the Firm provides investment advice to Individual Clients, the Firm’s advisory and fiduciary relationship is directly with the Individual Client. Individual Clients receive portfolio allocation recommendations from the API and are solely responsible for deciding whether and how to implement those recommendations. The Firm does not have discretionary authority over any Individual Client accounts.

With respect to any investment advisory services offered by us, we are required by law to disclose if any conflicts exist between your interests and ours. Neither the firm nor any of its investment adviser representatives, affiliates, or associated persons will receive fees, commissions, or other compensation from: (a) the sale of insurance or real estate, or (b) the sale of securities or any other products or services recommended in the investment advice we provide to you. We do not have any material conflicts of interest with regard to the investment advice we render to you.

In any case, and especially if a conflict of interest ever arises in connection with our investment advice, you are under no obligation to act on the recommendations made to you by the firm or any of its representatives. And, if you do act on any of our recommendations, you are under no obligation to make any transactions through us or any person (broker-dealers or their agents) associated with us.

All material conflicts of interest regarding the firm, its representatives, or employees which could reasonably introduce a bias in, or impair the objectivity of, our investment or financial planning advice to you have been, or will be, disclosed to you.

4.3 Advisory relationship with RIA Clients

Advisory API Systems LLC provides portfolio optimization analysis, including specific securities allocations and strategy recommendations, to its 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. The RIA Client acknowledges and agrees that:

• API outputs require professional evaluation before implementation;

• The RIA Client retains full responsibility for advice provided to End Users;

• The RIA Client must determine suitability of any recommendations for each End User;

• The RIA Client may modify, reject, or supplement API outputs as appropriate;

• The Company’s registration covers only its relationship with RIA Clients, not End Users.

4.4 Advisory relationship with Individual Clients

Advisory API Systems LLC also 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 the Firm has a fiduciary relationship.

Individual Clients should be aware that:

• API outputs are generated by mathematical algorithms based on the data the Individual Client provides;

• The quality and appropriateness of the recommendations depend on the accuracy and completeness of the data entered by the Individual Client;

• The Individual Client is solely responsible for deciding whether to implement the recommendations;

• The Firm does not have discretionary authority over the Individual Client’s accounts;

• The Individual Client should consider consulting with a qualified financial adviser if they are unsure about any recommendation;

• Investing in securities involves risk of loss, including possible loss of principal (see Section 8.1).

4.5 Advisory agreement and brochure delivery

The Firm enters into an advisory relationship with each Client through its User Agreement and Terms of Service (the “User Agreement"), which constitutes the advisory contract between the Firm and the Client.

Individual Clients: Before submitting any API request or payment, Individual Clients are presented with hyperlinks to (a) the Firm’s Form ADV Part 2A (this brochure), (b) the Firm’s Form ADV Part 2B (brochure supplement), and (c) the User Agreement, all of which are prominently displayed on the web interface at https://www.ria.us/api/api.html and on the Firm’s home page at https://www.ria.us. By clicking the “Run ALLOCATOR Now" button, the Individual Client acknowledges receipt and review of these documents and agrees to the terms of the User Agreement. No API request is processed and no fee is collected until the Client has had the opportunity to review these documents.

RIA Clients: The Firm’s Form ADV Part 2A and Form ADV Part 2B are delivered to RIA Clients electronically prior to or upon first API use. RIA Clients may also access these documents at any time at https://www.ria.us.

Annual Updates: Updated versions of the Firm’s Form ADV Part 2A and Form ADV Part 2B are posted at the URLs above. Material changes are communicated to Clients in accordance with applicable regulations. Copies of both documents are available at any time upon request to [email protected] and at www.adviserinfo.sec.gov (CRD #330083).

4.6 API methodology

The API implements portfolio optimization methodologies based on modern portfolio theory, including Merton continuous-time portfolio optimization, Constant Relative Risk Aversion (CRRA) utility framework, background asset integration (Social Security, pensions, real estate, human capital), and tax-aware optimization algorithms. The investment philosophy underlying the API is that individuals should hold a widely diversified portfolio of different types of securities, with the exact allocation determined by rigorous mathematical optimization based on the household’s complete financial picture and scientifically measured risk tolerance.

4.7 Wrap fee programs

We do not participate in any wrap fee programs.

4.8 Assets under management

Regulatory Assets Under Management (RAUM): $0

Advisory API Systems LLC does not manage client assets. Our business model provides investment advice through an API to RIA Clients and Individual Clients; we do not have discretionary or non-discretionary management authority over any client accounts. RIA Clients and their End Users, as well as Individual Clients, retain full control over their own investment accounts and are responsible for implementing any recommendations they choose to act upon. Because we do not manage assets, we do not calculate or report regulatory assets under management.

5 Fees and compensation

5.1 Our fees

We charge fees on a per-API-use basis, with different fee structures for the two categories of Clients:

• Individual Clients are charged a flat fee of $79.95 per API use. This fee is collected upon successful delivery of a portfolio optimization result; Individual Clients are not charged for API requests that fail due to system errors or data errors.

• RIA Clients are charged on a graduated monthly tier schedule, applied per calendar month against the cumulative count of successful API uses recorded against the RIA Client’s Stripe customer record:

  • Calls 1 through 25 in a calendar month: $34.95 per call;

  • Calls 26 through 100 in a calendar month: $27.95 per call;

  • Calls 101 and above in a calendar month: $21.95 per call.

  RIA Clients are not charged for API requests that fail due to system errors or data errors.

The fee schedule is set forth in Schedule A of the User Agreement and may be modified by us with sixty (60) days’ written notice pursuant to Section 5.5 of the User Agreement.

Lower fees for comparable services may be available from other sources.

5.2 How we collect our fees

For RIA Clients, we charge monthly in arrears via the payment method that the RIA Client maintains on file with our payment processor, Stripe, Inc. At calendar month-end, Stripe finalizes a metered invoice covering all of the RIA Client’s successful API Uses from the closing month and automatically charges the RIA Client’s default payment method on file. RIA Clients are responsible for keeping a valid payment method on file at all times. For Individual Clients, payment is collected at the time of each successful API use via credit card or other electronic payment method. The Individual Client’s credit card is authorized before the API request is processed, but the charge is captured only after the API has successfully returned a portfolio optimization result. We do not deduct fees directly from any client’s investment accounts.

5.3 Other fees and expenses

There are no other fees charged by us besides those described in section 5.1 above. However, Clients should note that implementing API recommendations may result in transaction charges, transfer taxes, wire transfer charges, or other fees and taxes on securities transactions charged by the broker-dealers through which Clients (or, in the case of RIA Clients, their End Users) execute trades. These transaction-based fees will be disclosed and assessed by those third parties, not by us.

In addition, Clients and End Users may incur operating expenses and other related fees imposed by exchange traded funds or other investment vehicles. These types of fees will be disclosed in these funds’ prospectuses.

5.4 Prepaid fees

We do not require or solicit prepayment of fees. RIA Clients are billed monthly in arrears. Individual Clients’ credit cards are authorized before each API request, but the charge is captured only after the API has delivered a successful result; accordingly, Individual Clients pay concurrently with the delivery of advisory services rather than in advance. In no case does the Firm collect more than $1,200 per Client more than six months in advance.

5.5 Sales commissions and other compensation

5.5.1 Conflicts of interest

Our goal is to render completely unbiased investment advice. We do not accept commissions, or any indirect compensation, on the recommendation or sale of any investment products besides our per-API-use fees.

5.5.2 No compensation from sales commissions

We currently receive no revenue from commissions or other compensation on the sale of investment products we recommend. Our only compensation is for the investment advisory services we provide through our API.

6 Performance based fees and side-by-side management

Neither the firm nor any of its supervised persons receive performance-based fees (fees based on a share of the capital gains on, or capital appreciation of, the assets in a client’s account). Not charging performance-based fees allows us to avoid having an incentive to recommend riskier investments.

7 Types of clients

The firm renders investment advice to two categories of clients:

• RIA Clients: Other registered investment advisers who use the API in a business-to-business capacity to obtain portfolio optimization recommendations for their own End Users.

• Individual Clients: Individual members of the public who use the API or web interface directly to obtain portfolio optimization recommendations for their own personal use.

Client eligibility requirements: Because Advisory API Systems LLC is registered as an investment adviser only in California, all Clients must meet the following eligibility requirements:

• If Client is a registered investment adviser entity (RIA Client), Client’s principal place of business must be in California;

• If Client is an individual acting as a supervised person of a registered investment adviser (RIA Client), Client must reside in California;

• If Client is an individual member of the public (Individual Client), Client must reside in California.

RIA Clients must hold all licenses, registrations, and authorizations required to provide investment advisory services in all jurisdictions where they operate.

8 Methods of analysis, investment strategies, and risk of loss

8.1 Analysis, strategies, and risk

The Portfolio Optimization API implements sophisticated mathematical optimization based on Nobel Prize-winning financial economics. The API solves the Merton portfolio problem for a household, determining the optimal allocation between the empirical global market portfolio and a risk-free asset.

Key methodological features:

• Household-Level Optimization: The API treats married couples or domestic partners as a single economic unit, considering aggregate household assets across all accounts and owners.

• Background Asset Integration: The API comprehensively values non-tradable assets including Social Security benefits, pensions and annuities, Medicare benefits, Medicare Savings Program benefits (QMB, SLMB, QI, and QDWI), Supplemental Security Income, real estate, and human capital.

• Scientific Risk Measurement: Risk tolerance is determined through revealed preference methodology using willingness-to-pay elicitation rather than subjective questionnaires, converting responses into a CRRA gamma parameter.

• Tax-Aware Optimization: The API incorporates federal and state income taxes, capital gains taxes, and tax-advantaged account considerations.

The investment philosophy underlying our API assumes that financial markets are efficiently priced and that investors cannot “beat the market" by attempting to pick winning stocks or predict market movements. The API typically recommends a passive style of investing (i.e., a buy and hold strategy) along with a well-diversified portfolio of investments expressed in terms of specific ETF allocations.

Please keep in mind that although risk can be minimized by investing in a diversified mix of assets, it can never be eliminated completely. There will always be some risk of loss to investment income or principal. All investments involve risk, including possible loss of principal.

8.2 Model risk

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. Clients should be aware that:

• Models are built on assumptions that may not hold in all market conditions;

• Projections incorporate historical data that may not be representative of future conditions;

• Models necessarily simplify complex financial realities;

• Model outputs are only as reliable as the inputs provided;

• Models cannot predict rare, high-impact events outside historical experience.

RIA Clients are responsible for understanding model assumptions and limitations, validating that assumptions are appropriate for each End User, and communicating limitations to End Users. Individual Clients are responsible for understanding model assumptions and limitations before acting on any API recommendations.

8.3 Types of investment risk

All investments involve some risk of loss to the investor. Here are some examples:

8.3.1 Market risk

Market risk is the possible loss of value of a particular securities investment due to economic conditions or events that affect the securities market as a whole.

8.3.2 Interest rate risk

The present value, or price, of investments that return a fixed series of future cash flows (e.g., bonds) will rise or fall with a decrease or increase in interest rates, respectively.

8.3.3 Liquidity risk

Liquidity risk is the possible mismatch between the timing of future investment income and needs for cash to meet future expenses.

8.3.4 Inflation risk

This is the possibility that current or future money holdings, or the future cash flows from investments, will lose purchasing power due to an overall rise in prices.

8.3.5 Foreign exchange risk

This is the possibility that the value, in units of domestic currency, of foreign investments will decrease due to unfavorable changes in exchange rates.

8.3.6 Longevity risk

The risk that an investor will outlive the ability of their investments to provide needed income.

8.3.7 Model risk

This is the possibility that a theoretical model used to estimate the value or risk of securities is inaccurate, resulting in a loss to the investor. See Section 8.2 for additional information.

8.3.8 Cybersecurity and electronic transmission risk

The Firm delivers investment advice exclusively through electronic channels (API and web interface), which necessarily involves the transmission and storage of sensitive personal financial data over the Internet. Although the Firm implements technical and organizational security measures—including encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256), API key authentication, rate limiting, firewall protection, and intrusion detection—no method of electronic transmission or storage is completely secure. Clients should be aware that there are inherent risks associated with transmitting personal financial information electronically, including the risk of unauthorized access, data breach, or interception. A detailed description of the Firm’s security measures is set forth in the Security Practices Documentation, which is available to Clients and is incorporated by reference into the User Agreement.

9 Disciplinary Information

We are required by law to disclose any legal or disciplinary events to you that would be important for deciding whether to use our advisory services or for evaluating the integrity of our management or supervised persons.

Neither our firm nor any of its management personnel have any legal or disciplinary events to disclose under this section.

9.1 Criminal or civil action in a domestic, foreign, or military court involving the firm or a management person

Neither our firm nor its management have any events to disclose in this section.

9.2 An administrative proceeding before the Securities and Exchange Commission, or any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority involving the firm or one of its management persons

Neither our firm nor its management have any events to disclose in this section.

9.3 A proceeding before a self-regulatory organization involving the firm or one of its management persons

Neither our firm nor its management have any events to disclose in this section.

10 Other financial industry activities and affiliations

10.1 Registration as a broker-dealer or agent

Neither the firm nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or registered representative of a broker-dealer.

10.2 Other registrations

Neither the firm nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of any of these entities.

10.3 Relationships with certain related persons

Neither the firm nor any of its management persons have any relationships or arrangements with any entities that would materially affect our advisory business or that would cause a material conflict of interest with our Clients.

10.4 Compensation for recommending other advisors

Neither the firm nor any of its management persons receive any direct or indirect compensation for recommending other advisors to our Clients.

11 Code of ethics, participation or interest in client transactions, and personal trading

11.1 Code of Ethics

A copy of the firm’s Code of Ethics will be provided promptly to any Client or prospective Client upon request (see our contact information at the head of this brochure).

As an investment advisor, the firm, together with its investment advisor representatives, officers, associates, and supervised persons are considered fiduciaries concerning the affairs of its Clients. As a fiduciary, the firm has a duty to provide full and fair disclosure of all material facts and to act solely in the best interest of our Clients. The firm expects all of its personnel to conduct business to the highest ethical standards and to comply with all applicable state and federal securities laws.

11.2 Interest in recommended securities

The firm or its supervised persons may own the same exchange-traded funds (ETFs) that the API may include in recommendations to Clients. These are broadly diversified market ETFs (such as total stock market or total bond market ETFs) held as personal investments, not proprietary products created or sponsored by the firm. The firm does not recommend individual securities, only broad market ETFs. This potential conflict is mitigated by the fact that any personal trading by the firm or its supervised persons in these widely-held, highly liquid ETFs would have no material effect on market prices or Client outcomes. The firm maintains records of personal securities transactions.

11.3 Investing in the same securities as our Clients

As disclosed above, the firm or its supervised persons may own the same ETFs that the API recommends. The firm does not engage in “front-running” or other trading practices that would disadvantage Clients. Personal trading is reviewed by the Chief Compliance Officer to ensure compliance with our fiduciary duty and Code of Ethics.

11.4 Purchasing the same securities as our Clients

This issue is addressed in section 11.3 above.

12 Brokerage practices

12.1 Factors in recommending broker-dealers

The firm does not recommend brokers or dealers to its Clients. Clients and their End Users may execute transactions through any broker or dealer of their choice. Therefore, this section and its subsections are not applicable to the firm.

12.1.1 Research and other soft dollar benefits

Not applicable. The firm does not receive any soft dollar benefits.

12.1.2 Client referrals from brokers

Not applicable. The firm does not receive client referrals in exchange for selecting or recommending brokers or dealers.

12.1.3 Directed brokerage

Not applicable. The firm does not recommend, request or require that its Clients direct the firm to execute transactions through a specified broker-dealer.

12.2 Aggregation of securities transactions

Not applicable. The firm does not have discretionary access to any accounts so it does not have an opportunity to aggregate the purchase or sale of securities.

13 Review of accounts

13.1 Periodic review

The firm does not have discretionary power over any accounts and does not manage portfolios. Our API provides investment advice in response to specific requests submitted by Clients. Each API request is processed independently based on the data provided at the time of the request.

Clients are responsible for determining when to request updated recommendations from our API based on changes in their (or, in the case of RIA Clients, their End Users’) circumstances.

Currently, Thomas Seehusen is the Managing Member, Chief Compliance Officer, and sole investment advisor representative of the firm.

13.2 Regular reports to Clients

Our API provides investment recommendations in response to each request. All API requests and responses are logged and stored for audit and compliance purposes. Clients may request their usage history and billing records at any time.

14 Client referrals and other compensation

14.1 Compensation from third parties

The firm does not accept any form of compensation from non-Client third parties for recommending specific securities or investment products.

14.2 Client referrals

The firm does not compensate any person for client referrals.

15 Custody

The firm does not have custody of any Client or End User accounts or assets. This section is not applicable to us.

16 Investment discretion

The firm does not accept discretionary authority to manage securities accounts on behalf of Clients or End Users. This section is not applicable to us.

17 Voting client securities

17.1 Authority to vote securities

The firm does not have, nor will it accept, authority to vote any securities. Clients and End Users are responsible for exercising their own voting rights on securities they own.

17.2 No authority to vote securities

The firm does not have the authority to vote any securities.

18 Financial information

18.1 Require or solicit prepayment of fees

The firm does not require or solicit prepayment of fees. RIA Clients are billed monthly in arrears. Individual Clients’ credit cards are authorized before each API request, but the charge is captured only after the API has delivered a successful portfolio optimization result; accordingly, Individual Clients pay concurrently with the delivery of advisory services rather than in advance. In no case does the Firm collect more than $1,200 per Client more than six months in advance.

18.2 Discretionary authority or custody of client funds or securities

The firm does not have discretionary authority over, or custody of, any funds or securities. This section is not applicable to the firm.

18.3 Financial condition

The firm does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to Clients. Because the firm does not require prepayment of fees more than $1,200 per client, more than six months in advance, the firm is not required to include a balance sheet with this brochure.

18.4 Bankruptcy

Advisory API Systems LLC has not been the subject of a bankruptcy petition in the last ten years. This section is not applicable to the firm. For bankruptcy information about our supervised persons see the brochure supplement provided with this brochure.

19 Requirements for state-registered advisers

19.1 Principal executive officers and management persons

Thomas Seehusen is the sole owner and managing member of Advisory API Systems LLC. Thomas Seehusen holds a Bachelor of Science degree in Physics from UCLA. Thomas Seehusen also holds a Master of Business Administration (MBA) in Finance from the University of Technology, Sydney (UTS). Thomas received an MBA International Scholarship from UTS in recognition of his high academic accomplishments, having achieved an overall average mark of High Distinction in his studies at UTS. Before joining Advisory API Systems LLC, Thomas Seehusen was managing member of VIA LLC from 2018 to 2023.

19.1.1 Business Continuity Plan

In order to meet its obligations to its Clients, the firm maintains a Business Continuity Plan which details procedures for maintaining business operations in the event of the death or incapacity of its principal officers or representatives, a natural disaster, technology failures, or civil unrest. The Business Continuity and Data Portability Statement is available to Clients and incorporated by reference into the User Agreement.

19.2 Business activities other than giving investment advice

Neither the firm nor its management engages in any other business besides the offering of investment advice through its API and web interface to RIA Clients and Individual Clients.

19.3 Calculation of performance-based fees

Neither the firm nor any of its supervised persons are compensated for advisory services with performance-based fees. This section is not applicable.

19.4 Civil liability

19.4.1 Found liable in an arbitration claim

Neither the firm nor any of its management persons has been found liable in an arbitration claim alleging damages in excess of $2,500 involving: (a) an investment or investment-related business or activity; (b) fraud, false statement(s), or omissions; (c) theft, embezzlement, or other wrongful taking of property; (d) bribery, forgery, counterfeiting, or extortion; or (e) dishonest, unfair, or unethical practices. This section is not applicable.

19.4.2 Found liable in a civil, self-regulatory organization, or administrative proceeding

Neither the firm nor any of its management persons has been found liable in a civil, self-regulatory organization, or administrative proceeding involving: (a) an investment or investment-related business or activity; (b) fraud, false statement(s), or omissions; (c) theft, embezzlement, or other wrongful taking of property; (d) bribery, forgery, counterfeiting, or extortion; or (e) dishonest, unfair, or unethical practices. This section is not applicable.

19.5 Relationship with any issuer of securities

Neither the firm nor any of its management persons have any relationship or arrangement with any issuer of securities. This section is not applicable.

20 Privacy policy

The Firm maintains a Privacy Policy describing how it collects, uses, discloses, retains, and protects the personal information of its Clients and website visitors, in accordance with the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Gramm-Leach-Bliley Act (GLBA), and other applicable federal and state privacy regulations. The Firm does not sell or share personal information for cross-context behavioral advertising. The Firm does not use cookies, web beacons, tracking pixels, or third-party analytics services on its website or web interface. A copy of the Privacy Policy is available at https://www.ria.us/agreement/Privacy_Policy.html and is provided to all Clients as part of the User Agreement documentation. Clients may also request a copy by contacting the firm at [email protected] or (310) 839-0358.

21 Brochure supplement delivery

This brochure is accompanied by a brochure supplement (Form ADV Part 2B) for Thomas Seehusen, the firm’s sole supervised person who formulates investment advice. Although the firm delivers investment advice through an API rather than through direct client interaction, Thomas Seehusen is responsible for developing, validating, and overseeing the algorithms and methodology that generate the API’s recommendations. Accordingly, the brochure supplement is provided to give Clients information about his qualifications and background.