Broker-Dealer and Registered Representative Registration

FinacleAI is not registered, nor does it have an application pending to register as a broker-dealer.

Certain of FinacleAIs IARs may be dually registered as representatives of unaffiliated broker-dealers. As such, these individuals may receive compensation from the unaffiliated broker-dealer in the form of commissions resulting from implementing product transactions on behalf of advisory clients through their respective broker-dealers. Customers of FinacleAI are under no obligation to accept a recommendation that may result in a commission paid to an IAR from their respective broker-dealer. Finacle’s Code of Ethics requires IARs to always act in the best interest of clients.

Futures and Commodity Registration

FinacleAI is not registered, nor does it have an application pending to register, as a futures commission merchant, commodity pool operator or commodity trading advisor.

Financial Industry Affiliations

FinacleAI has no financial industry affiliations. 

Other Business Activities

You should be aware that Investment Adviser Representatives may be engaged in other business activities, as described more fully below. Further information regarding such activities may be found in your IAR’s ADV Part 2B: Brochure Supplement. Some of these activities may be deemed a conflict of interest. Investment Adviser Representatives are prohibited from engaging in any practice that could jeopardize or disadvantage a client or a client account(s). Accordingly, each representative is further required to acknowledge and adhere to the policies and procedures mandated within the firm’s Code of Ethics (please see Item 11 for further information regarding the Code of Ethics).

Clients should be aware that the receipt of additional compensation by FinacleAI and its IAR’s creates a conflict of interest that may impair the objectivity of our firm and these individuals when making advisory recommendations. FinacleAI endeavors at all times to put the interest of its customers first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict:

• We disclose to clients the existence of all material conflicts of interest, including the potential for the Firm and its IAR’s to earn compensation from subscription services regardless of whether customers make money;

• We disclose to clients that they are not obligated to take trades recommended from FinacleAI or its IAR’s trading signal generation systems or commentary;

• We disclose that market trading signals are not customized but generated based upon proprietary algorithms and AI systems, whose internal computational processes are opaque, constituting a “black box;”

• We require that our IAR’s seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed;

• We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and

• We educate our IAR’s regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients.

Clients are encouraged to contact FinacleAI’s compliance office at 312-982-5059 if they have questions regarding any recommendations being proposed by IARs relating to trading strategies or investment or software products that are not described in this Brochure.

Solicitation of Outside Money Managers

The Firm will not enter into agreements with any non-affiliated investment advisors (“NIA’s”) to offer asset allocation and asset management services to certain Firm customers.