Overview
Path is an SEC registered investment adviser formed in 2020 as a limited liability company in the
State of Illinois. Path is a wholly-owned subsidiary of Path Finance Corporation, a Delaware
corporation, and is indirectly owned by our founders, Stephen Beavis and Joel Birch, and
MediaTech, Ltd. Information about Path’s organizational and ownership structure, as well as
information about its advisory business, is provided in Part 1 of Path’s Form ADV, which is available
online at http://www.adviserinfo.sec.gov. Path’s eligibility for SEC registration is based on its
activities resulting in it qualifying as an internet adviser.
As an internet adviser we provide investment advice to our clients exclusively through an
interactive website, except for a de minimis exception that permits us to provide investment
advice to fewer than 15 clients through means other than the interactive website during the
preceding twelve months. Specifically, our interactive website uses computer software-based
models or applications to provide investment advice to clients based on personal information each
client supplies through the website. We primarily service retail clients.
Our niche investment advisory services are digital assets. A “Digital Asset” as used in this brochure,
refers to an asset that is issued and transferred using distributed ledger or blockchain technology,
including, but not limited to, so-called
“virtual currencies,” “coins,” and “tokens” and other
cryptocurrency.
A “Managed Account Client” is a client that uses the interactive website to invest, giving
investment discretion to Path for the client’s account. Investment decisions for Managed Account
Clients will be made based on Path’s investment models. Through the website, Path works with
each Managed Account Client to establish an appropriate investment profile. Managed Account
Clients can choose from 3 portfolios - balanced growth, strategic growth, and opportunistic
growth. Path reserves the right to offer additional portfolio strategies in its absolute discretion.
Managed Account Clients can also impose reasonable restrictions on Path’s management of their
accounts. Managed Account Clients must provide Path with suitability information concerning
their personal financial situation, goals, and objective.
A “Self-Directed Account Client” is a client that elects access to Path’s research, investment
recommendations and portfolio management tools, but retains investment discretion regarding
its account. Path provides recommendations to Self-Directed Account Clients, but these clients
ultimately make their own investment advisory decisions with respect to their accounts.
Each Managed Account Client or Self-Directed Account Client is referred to herein as “Client”, and
collectively, as “Clients”.
As of March 1, 2024, we managed $155,766 of client assets on a discretionary basis only.