Form CRS – Frequently Asked Questions & Conversation Starters

About the Form CRS

Form CRS (which stands for client relationship summary) is a uniform disclosure document prepared by broker-dealers and investment advisers registered with the Securities and Exchange Commission (“SEC”). Investment advisers and broker-dealers are required to deliver to retail investors a brief relationship summary written in plain English that provides information about the firm’s relationships and services, fees, costs, conflicts of interest, standard of conduct, disciplinary history and where to find additional information. The relationship summary also includes key questions (“conversation starters”) for investors that Trinary has provided answers for below. The relationship summary available at https://trinarycapital.com/legal-docs/Trinary_Capital_CRS.pdf is in addition to the Form ADV Part 2 narrative brochure that investment advisers provide to their clients (in addition, Trinary Capital also provides a Wrap Fee Program Appendix and supplemental information about its executive team). You can contact our customer service team at support@trinarycapital.com if you have any further questions or clarifications about how Trinary Capital works, but be aware that our customer service team members are not licensed to give financial advice.

Learn more at https://www.investor.gov/CRS.

Trinary Capital is an investment advisor. As an investment advisor, Trinary (and all its team members) are held to a fiduciary standard that covers our entire investment advisory relationship with you. A fiduciary has both a duty of care and a duty of loyalty to its clients. The duty of care requires us to place your best interests ahead of our own at all times. We are also required to monitor your portfolio, investment strategy, and investments through our Roboadvisory algorithmic tool throughout the duration of our advisory relationship with you. The duty of loyalty, on the other hand, mandates that Trinary eliminate any conflicts of interest or notify you about them beforehand in a way that you can understand, so that you can make an informed decision whether or not to agree to them.

Trinary does not act as a broker-dealer; instead, all broker-dealer services are provided through Trinary’s contracted-for broker-dealer, Altruist. Broker-dealers are not fiduciaries and are not required to monitor your portfolio or investments on an ongoing basis. Altruist’s role as Trinary’s chosen broker-dealer is to place and execute transactions pursuant to your chosen investment strategy and to maintain an appropriate custody solution.

At Trinary, our proprietary Roboadvisory algorithmic tool continually monitors your client account on an ongoing basis. Typically, broker-dealers have no such ongoing duty to monitor client accounts. Broker-dealers typically charge transaction-based fees (i.e., you will pay a fee every time you buy or sell an investment), and may charge additional fees, such as custodian fees, account maintenance fees, and account inactivity fees. Investment advisors like Trinary, however, charges clients a “wrap fee,” which encompasses transaction costs and custody services. You will not pay fees on a per-transaction basis as a Trinary client.

Trinary’s services include guided investing portfolios and retirement planning tools. Because our advice is automated, we are considered a “roboadvisor.” What this means is that you give us discretionary authority over your investment account, which means we—through our fully automated, proprietary Roboadvisory algorithmic tool—can buy and sell investments on your behalf when we determine it is appropriate to do so. We trade in response to your actions (such as asset allocation changes, deposits, or withdrawals), to rebalance your accounts, or to otherwise further your investment goals. Roboadvisory managed accounts are convenient—you don’t have to research investments, follow the market, or worry about any of the other actions listed above (although it always makes sense to review your account periodically to protect against fraud, as well as to ensure that the account continues to be appropriate for your needs by updating your personal information and financial and investment goals). As a fiduciary, Trinary will act in your best interests at all times. You may benefit from our services if you want ongoing investment advice, a fiduciary to manage your investments, and/or someone to make investment decisions for you.

The tradeoff for this ongoing advice and convenience is that you give up day-to-day control over the investments in the account. This includes the timing of each trade. If you are the type of investor who follows the market closely and wants to dictate the precise moment at which your assets are bought and sold, as well as which specific securities are traded, a managed account may not be the right option for you, and you may prefer to open a self-directed account at a broker-dealer.

When you sign-up for an account with Trinary Capital, our online client onboarding interface will prompt you to answer a series of questions about yourself, including information about your financial and investment goals. For example: are you investing for a long-term goal, such as education, a safety net, a major purchase; interested in just getting your feet wet in general investing; saving for retirement; trying to manage spending; or creating a discretionary investment account to better utilize cash reserves for upcoming expenses? For each goal, we will ask about the target amount of the goal and the date when you anticipate you will need the money for your goal. Based on the information you provide, we will recommend a portfolio that has an allocation of various financial instruments (stocks, bonds, etc.) with a risk level designed for your goal’s investment horizon. This risk level is determined by weighing the trade-offs between potential gains from higher risk investments and the potential for falling short of your goal by playing it too safe. You can also choose to modify your recommended allocation to select an allocation that is weighted more towards stocks or bonds, depending on your risk appetite. Our portfolio strategy is tailored to your goals and are typically built of low-cost exchange-traded funds (“ETFs”) that are designed to provide exposure to a diversified set of global assets, and seeks to maximize expected returns while taking into account your risk level. We receive no financial benefit from recommending particular securities or strategies, which helps align our incentives with yours. A fulsome description of the various methods of analysis and investment strategies, along with corresponding risk of loss analyses, can be found in our publicly available Form ADV Part 2A Client Brochure.

As an internet advisor, all of our investment advice is automated through our proprietary Roboadvisory algorithmic tool. The Roboadvisory tool was developed and overseen by investment advisory personnel that include, investment professionals, engineers, lawyers, behavioral scientists, and traders. All members of our team have a commitment to act as a fiduciary. Detailed information about each member of our executive and advisory teams is available on our Form ADV Part 2B Client Brochure Supplement.

Members of our customer service team are available to assist with questions about how Trinary Capital’s services work or to help with your account. but please be aware that they are not licensed to give financial advice. You can contact our customer service team at support@trinarycapital.com.

The fees that you pay may significantly impact the value of your account over time. Whether an asset-based fee (like Trinary Capital’s) or a transaction-based fee (typically offered by broker-dealers) is right for you depends on the level of fees and your personal circumstances, including the frequency of trades you wish to make. Our current fee schedule, based on your client “assets under management,” or “AUM,” is as follows:

Standard Rates

$250 - $10,000 AUM = 1.0%
$10,001 - $15,000 AUM = 0.9%
$15,001 - $25,000 AUM = 0.8%
$25,001 - $50,000 AUM = 0.7%
$50,001 - $250,000 AUM = 0.6%
$250,001 AUM and up = 0.5%

For example, if you gave us $5,000 dollars to invest, we would invest the full $5,000 for you. Based on our current retail client account fees, Trinary would charge an annual management fee of 1.0% on the daily average balance of assets in your account for an account of that size, which equals just $50 per year if your account balance does not change over the course of the year. If the value of your account goes up beyond the $10,000 threshold (because, for example, your investments appreciate), our fee would be 0.9% (or at least $90 but no more than $135) in that year.

We typically construct our core client portfolio with exchange-traded funds (or “ETFs”), a type of security that generally tracks a broad-market stock or bond index but trades like a stock on a listed exchange, which often have embedded fund fees. Trinary Capital does not receive any portion of the fund fees and these fees are in addition to our management fee. Fees and expenses for the securities in these and other portfolios can be accessed through your personal monthly brokerage reports, available via our online interface.

Clients will incur additional fees from our technology partner, Quartz Partners Investment Management ("Quartz"), and our broker-deal, Apex Clearing ("Apex"). Quartz charges an annual account fee 0.025% of total account value(s) and $50 per account; Apex charges 0.08% of total account value(s). The total fees for a household at Trinary will use the formula:

(Trinary Fees + Quartz Fees + Apex Fees) * AUM + ($50 * # of accounts)

Therefore, the total annual fee for a $5,000 account would be

(0.01 + 0.00025 + 0.0008) * 5,000 + ($50 * 1) = $105.25

We work hard to minimize any conflicts of interest. As an investment advisor, we are legally required to act as a fiduciary for our clients at all times, which essentially means that we are mandated by law act in your best interest at all times in our client relationship with you. With that in mind, the nature of our business model has incentives that can create conflicts of interest. For example, we are paid based on assets under management and have a financial incentive to recommend you increase the value of your accounts. We also require that you appoint Altruist, our contracted-for broker-dealer for all client accounts, as the broker-dealer for your account to perform transaction and custody services. Other broker-dealers provide different services and have different capabilities, which you should consider when deciding whether to become a Trinary Capital client. Please consult our Form ADV Part 2 Client Brochure and the Wrap Fee Program Appendix for additional details on conflicts.

Trinary Capital does not have a disciplinary history, nor is Trinary involved in any other legal matters that would have a significant impact on its advisory business. Visit https://www.investor.gov/CRS for a free and simple search tool to research us and our financial consultants, or you can visit https://adviserinfo.sec.gov/.

Trinary Capital operates differently from other investment advisers. Because we provide investment advice entirely over the internet via our proprietary Roboadvisory algorithmic tool, your primary way of interacting with us as your investment adviser will be through our website or mobile application. If you have questions about how Trinary works or are concerned about your account, please contact our customer service support team at support@trinarycapital.com. Members of our Customer Support Team are not investment adviser representatives and are not licensed to give financial advice. We take all complaints seriously and will endeavor to provide you with a timely response as soon as reasonably practicable.