Interest Financial, LLC (the “Firm”) is a Florida limited liability company formed in October 2017.
The Firm is wholly-owned by Interest Investments, Inc., a Delaware corporation (“Interest
Investments”). Grifin LLC, a Florida limited liability company (“Grifin”), also wholly-owned by
Interest Investments, operates a mobile application and website (referred to in this brochure as
the “Grifin Platform”) that provides only a tool designed to aid you in automatic purchases of
securities. We provide our investment advisory services to you solely through the Grifin Platform.
Services
Our program is designed to make investing in securities easier and more accessible to
individuals. We do this by assisting you in purchasing fractional shares of the publicly-traded
companies where you typically shop, as well as putting aside cash in your brokerage account if
you opt-in to do so. This brochure provides a brief overview of our services. Users are
encouraged to review Help Center articles on our website for additional details.
To use the Grifin Platform, you need to complete a risk profile to determine your risk tolerance.
We use this information to assign you to a risk profile of Conservative, Moderate, or Aggressive.
We categorize the securities that are available for purchase in the program as being
Conservative, Moderate, or Aggressive using a risk rating methodology that considers asset
volatility, beta, and market capitalization. Volatility is a statistical measure of the dispersion of
returns for a given security or market index. Beta is a concept that measures the expected move
in a stock relative to movements in the overall market. Market capitalization refers to the total
dollar market value of a company’s outstanding shares of stock. On a quarterly basis, we review
these factors and update the risk ratings.
The securities available are a limited universe of publicly-traded stocks, as defined by the Broker,
which is subject to change. The platform provides access to a subset of this stock universe. All
users have access to the same universe of securities. We will provide an alert if you attempt to
purchase a security that does not fit your risk profile; however, you can approve that security. In
that case, all future transactions involving that security are allowed. You can opt out of
purchasing a security at any time. Other than providing these alerts, we do not tailor our services
to your individual financial circumstances. The accuracy of your risk profile selection will affect
the alert functionality of the Grifin Platform. If your risk profile changes, you need to update your
risk profile in the Grifin Platform on the Profile tab promptly. If you choose to make an investment
in a security that is outside of your risk profile, the investment may not be suitable based on your
risk tolerance.
We have established a relationship with Alpaca Securities LLC (“Alpaca”), an SEC-registered
broker-dealer and FINRA member (the “Broker”). You must open a brokerage account with the
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Broker and provide discretionary trading authority over that account to us. The Broker will
provide custody, clearing, and settlement services for your account. All account opening
functionalities, including identity verification and approval, are handled digitally by Broker. The
Broker provides all brokerage services to you; therefore, you must agree to the terms of the
Broker’s “Customer Account Agreement” to establish an account with Broker. Only individuals
will be permitted to establish accounts with the Broker, which shall be in their own name;
accounts for legal entities are not supported in the Grifin Platform at this time. You will be
required to complete all applicable Broker forms and agreements, including a limited power of
attorney, which authorizes us to place trades on your behalf and authorizes the Broker to deduct
our fees from your accounts pursuant to your agreements with us. The Broker reserves the right to
reject any account application for any reason whatsoever.
The Broker has the sole discretion to determine the universe of available securities, and to add or
remove any security from the universe at any time. The Firm provides access to a subset of this
stock universe. If a security is removed from the universe, the Broker will limit transactions in that
particular security to the liquidation of positions only.
You will need to securely link your bank account to the Grifin Platform, and also elect which
debit cards and credit cards to link. For security reasons, you will periodically be required to
reauthorize the connection of your bank account and credit or debit card connection. All
purchase transactions that you make using the linked debit cards and credit cards (referred to
as “purchase transactions'' throughout this brochure), will be monitored and analyzed by the
Grifin Platform using proprietary algorithms. Each time you make a purchase transaction, your
designated stock purchase amount, which is set at one dollar ($1.00) by default, will be debited
from your bank account and transferred to your brokerage account. The designated stock
purchase amount is set by the user and can range from $1 to $99. Your bank account will be
debited once a week, on the day you designate (Monday through Friday). You can opt out of
purchasing stock for the week by disabling the purchase before 3:30 pm ET on the business day
prior to your designated debit day. Automatic debits for purchase transactions will be
combined into one weekly debit. We attempt to help you prevent overdrafts by checking your
bank balance to see if you have at least 150% of the accumulated debits and a bank account
balance of at least $5.00. If this balance is not available, we will not be able to process the
withdrawal. More detailed information about the program is available in the Advisory
Agreement and on our website. We encourage you to read the Advisory Agreement and review
the Frequently Asked Questions on our website carefully to understand how the Program works
and your obligations with regard to your bank account and debit/credit card accounts.
By initiating or directing a withdrawal or a deposit, you authorize your bank to facilitate the use
of the Automated Clearing House (“ACH”) payment system for the transfer of money to or from
the Broker. You are responsible for any fees, charges, or expenses imposed by your bank in
connection with any deposit or transfer of money to or from your brokerage account. You will
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further be responsible for all fees associated with failed ACH transfers. Although we have
measures in place to avoid overdrafts, we cannot control the timing of your other transactions
against your
account. It is your responsibility to make sure that sufficient funds are available in
your account to support your participation in this program.
When you make a purchase transaction at a publicly-traded company, this signals an instruction
to us to purchase, using money debited from your bank account, your designated stock
purchase amount’s worth of a share of that publicly-traded company’s stock. When you make a
purchase transaction at a private company, you are instructing us to deposit your designated
stock purchase amount in cash in your brokerage account, if you opt in to do that. Note that
the cash feature is disabled by default at account setup. If you wish to use this feature, you will
need to turn on the functionality in the app.
(Please see important disclosures about our fees
and how they are affected by the cash balance in your brokerage account.) You have the
ability to place restrictions on the securities that are purchased or the amounts of cash
deposited in your brokerage account by using the Grifin Platform to opt out of certain
transactions or opt-in to cash deposits.
We aggregate the amounts that we receive from your bank account and use those funds to
purchase shares of the publicly-traded companies at which you’ve shopped, or deposit cash in
your brokerage account. The timing of the purchases of securities is at our discretion, using the
proprietary algorithm of the Grifin Platform. We then distribute the fractional shares of the
publicly-traded companies to your brokerage account. We pay all brokerage and transaction
costs for the stock purchase.
The Grifin Platform includes functionality for a system-wide circuit breaker which will cause the
algorithm to be halted in certain cases, such as technology malfunction, unauthorized access,
or presumed fraud. As a result, there may be interruptions to the Grifin Platform. Additionally, the
Grifin Platform utilizes multiple third-party resources and APIs. Therefore, the functionality of the
Grifin Platform is dependent on the operation of those services.
By using the Grifin Platform, you authorize and direct us to place all trades in your account
through the Broker. We do not accept directed brokerage arrangements. Consequently, we
maintain all client accounts and execute all securities transactions without separate commission
costs or other fees. In seeking best execution, the determinative factor is not just cost, but
whether the transaction represents the best qualitative execution, taking into consideration the
full range of the Broker’s services. The appointment of a registered broker-dealer as the sole
Broker for your accounts may result in less favorable executions than may be available through
the use of a different broker-dealer. We do not receive research or other products or services
from a broker-dealer or third-party in connection with client securities transactions (“soft dollar
benefits”). We do not receive client referrals from the Broker.
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Note that trades do not occur in real-time when purchase transactions are madet. We place
orders on an individual basis once funds are received. Alpaca executes trades upon receipt of
the Client’s order. Despite this, there may, depending on the liquidity and demand in the
market, be a material change in the market price of the security being bought or sold.
We do not maintain custody of client assets. Client assets are maintained in an account with the
Broker, a qualified custodian.
Any information provided by the Grifin Platform, within our marketing materials, or by Support is
for informational and general educational purposes only and is not investment or financial
advice. Any graphs, charts, and other visual aids that are provided are for informational
purposes only, not to be used to make investment decisions.
Certain hypothetical scenarios that are described in the Grifin Platform or in our marketing
materials are for illustrative purposes only and the securities described are not actual securities
held by client accounts. The inclusion of such scenarios is not intended as a recommendation to
purchase or sell any security and performance of these scenarios does not indicate actual
results.
Our program only offers publicly-traded securities. We do not provide comprehensive financial
planning services and the investment advisory services provided through the Grifin Platform are
not a complete investment program. We encourage you to consider additional asset classes,
strategies and investments to supplement your overall investment plan. You should not use the
Grifin Platform as the sole component of your investment program. Trades do not occur in real
time and the timing is at our discretion. We do not recommend specific securities, and we do not
monitor the securities in your account or rebalance your portfolio to any predetermined
allocation. Trading instructions are based solely upon your purchase transactions and your
instructions given through the Grifin Platform. This program allows you to purchase securities in
dollar amounts rather than share quantities. Trading in fractional shares has unique risks and
limitations that you should understand prior to participation in the Grifin Platform.
Fees and Compensation
Our Program is a wrap fee program, which means you pay one fee that covers our advisory fee
and certain Broker fees, including trading activity fees for the purchase and sale of securities.
However, the Broker imposes other service fees for actions such as overdrafts, transfers, or copies
of documents. See our website for a complete list of the
Broker’s fees.
As our compensation for making this program available, we charge an asset-based fee which is
calculated on the amount of cash held in your brokerage account on a monthly basis.The rate
used to calculate the fee is equal to a percentage of the current prevailing interest rate used by
the Broker for cash accounts, which changes over time.You should be aware that the more
cash you hold in your brokerage account, the higher your program fee will be. Clients who hold
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no cash in their brokerage account pay no program fee.At our sole discretion, we can offer fee
waivers or discounts due to special promotions or based on individual client circumstances.
Although we believe our fees are competitive, lower fees for comparable services may be
available from other investment advisers.
Neither the Firm nor its supervised persons accept compensation for the sale of securities or other
investment products.