INVESTMENT RECOMMENDATIONS
Greenlight Investment Advisors, LLC (“Greenlight Advisors” or the “Adviser”) is an internet
investment adviser and provides investment advisory services to families, who reside in the
U.S.A., through an app that Greenlight Financial Technology, Inc. (“GFT”) (the Adviser’s parent
company) owns and operates (the “App”). The App is a mobile platform that was developed with
a mission to enable parents to raise financially smart kids while growing their own financial
knowledge. Greenlight Advisors has a licensing agreement with GFT for the Invest module
within the App (the “Invest Application”) and Greenlight Advisors manages and controls the
features available in the Invest Application. Parents can access the investing features by
subscribing to the Adviser's investment advisory services. When parents subscribe to the
investment advisory services, they, and their children ( “Clients”) have access to the Adviser's
investment recommendations, which primarily consists of various ETFs. The Adviser considers
a Client’s investment profile when recommending which ETF to purchase. A Client’s investment
profile is determined using a questionnaire that must be completed prior to account opening.
Based on a Client’s responses, the Adviser will place the Client in an appropriate risk category.
Although Greenlight Advisors reviews Client investment profiles before recommending an ETF,
the Adviser does not guarantee or ensure the success of any of the recommended investments.
The Adviser relies on the individual responses to the profile questions to provide investment
recommendations to Clients. Clients must provide accurate, complete, and truthful answers to
the Adviser's investment profile questions. In addition to the Adviser's ETF recommendations,
Clients also have access to research provided by Morningstar, a third-party research company.
Greenlight Advisors engages DriveWealth, LLC (“DriveWealth”), an SEC registered broker-
dealer and a member of FINRA, to provide execution and clearing services to its Clients. All
Client trades are placed through DriveWealth. Clients access the Adviser's investment advisory
services through the Adviser managed Invest Application; however, Clients may use the App for
non-investment advisory services provided and managed by GFT.
The Adviser does not offer any legal or tax advice with respect to its investment
recommendations, and accordingly, the Adviser strongly urges individuals to work with their
attorneys, accountants, or other professionals regarding their financial and personal situations.
Investments in ETF or other types of securities are not insured by Federal Deposit Insurance
Corporation or by any other federal government agency. ETF investments are not deposits or
other obligations of, or guaranteed by, Greenlight Advisors or any affiliate, including GFT. ETF
investments may lose value, including possible loss of principal.
Greenlight Advisors, which commenced operations in March 2020, is a Delaware limited liability
company and a wholly owned subsidiary of GFT, a privately-owned company. The Adviser’s
principal place of business is in Atlanta, Georgia.
INVESTMENT ADVISORY FEE
Greenlight Advisors charges a $0.02 monthly investment advisory fee to Clients who register
for the Investing for Parents Lite, Investing for Parents, or Investing for Kids account features
(collectively, the “Invest Accounts”) offered through the Greenlight Core Plan, Greenlight +
Invest Plan, Greenlight Max Plan, or any other future Card Plan offering Invest Accounts
(collectively, the “Card Plans”) offered by subscription through Community Federal Savings
Bank (the “Bank”). The Bank charges a monthly subscription fee for all Card Plans, which
includes the investment advisory services provided by Greenlight Advisors as well as a variety
of other services provided through the App. Although Greenlight Advisors charges each Client
$2.99 per month for investment advisory services, the Bank collects those fees through the
monthly Card Plan subscription fees and remits a portion of those
fees (approximately $2.99) to
Greenlight Advisors on a monthly basis.
The monthly investment advisory fee is only charged to the primary accountholder under each
Card Plan and not the up to five additional secondary account cardholders. Monthly subscription
fees and the related $0.02 investment advisory fee may be waived for new App customers for
varying periods of time, but once fees are charged, they will be no more than what has been
disclosed in the preceding paragraph. GFT may also, from time to time, enter into agreements
with marketing partners whereby the marketing partner may offer their customers a subscription
to the Greenlight App and services for varying periods of time. In these cases, the marketing
partner may pay a customer’s monthly Card Plan subscription fee or a portion thereof, including
the monthly investment advisory fee.
Greenlight Advisors does not limit the number of trades a Client can place; however, GFT limits
the amount a Client can load to their prepaid Greenlight account which serves to limit the amount
a Client can ultimately invest.
Greenlight Advisors does not have a revenue sharing arrangement with any of the ETFs
recommended to Clients. Clients can purchase any of the ETFs that Greenlight Advisors
recommends through other brokers or agents that are not affiliated with Greenlight Advisors.
Clients do not need to subscribe to Greenlight Advisors investing services to purchase or sell
those ETFs.
Even though the primary objective of this investing option is to enable parents to raise financially
smart kids while growing their own financial knowledge, the subscription fee structure may not
benefit those Clients who make few or infrequent trades or maintain small balances. The
investing option may result in Clients paying more than if they purchase such ETFs or stocks
separately, and/or directly with a broker.
ADDITIONAL FEES
Greenlight Advisors monthly investment advisory fee includes other fees charged by
DriveWealth. These fees are Pass-through Fees, and they are: an SEC fee (sell side only), TAF
fee (sell side only), and an ADR fee.
DriveWealth may also charge other fees (different from the Pass-through Fees) for providing
additional services to Clients. Clients will pay those other fees directly to DriveWealth. Other
fees may include fees for transferring a brokerage account from DriveWealth to another
brokerage firm, charges for miscellaneous requests such as requesting physical copy of a trade
confirmation or requesting a tax document to be faxed or sent by regular mail to the Client, as
well as charges for withdrawal or other administrative requests, such as ACH transfers (outgoing)
and wire transfers. To learn more about the different fees that could be charged by DriveWealth
to Clients, please see the fee disclosure located in Schedule 1 of the Greenlight Investment
Advisors Investment Advisory Agreement which can be found a
t https://greenlight.com/invest-
account-safety-features-other-products-and-services.
Clients who invest in ETFs may also indirectly pay management fees or other expenses to the
purchased ETF. ETFs pay their own management, transaction, and administrative fees and
expenses, and those fees and expenses are indirectly borne by the shareholders in those
investment vehicles. Depending on the activities or services (e.g., transferring an account to
another broker, requesting physical copy of a trade confirm, and so on), the broker could also
charge you other fees. These additional fees are deducted directly by the ETF and reflected in its
net asset value.
In the event a Client account is canceled, closed, or terminated for any reason (either by the
Client, by Greenlight Advisors, or by DriveWealth), a wind-down fee of $1.00 or less may be
charged to Invest Accounts with a balance amount less than $1.00. The wind-down fee will be
deducted from the Clients Invest Account balance(s).