Pefin Advisors Investment Advisory Agreement

Pefin Advisors, LLC (“Advisor”, “Us”), Pefin, Inc. and Client (“You/Your”), (individually known as a “Party” or together as “Parties”) enter into this Pefin Advisors Investment Advisory Agreement (“Agreement”), as of the “Effective Date” (the date in which You accept the Terms of Use of Pefin, Inc.). This Agreement sets forth the terms and conditions with regard to the Information Advisor will provide to Pefin, Inc., on behalf of the Client and the responsibilities of the parties.

Pefin Advisors, LLC (Advisor) is a 100% owned subsidiary of Pefin, Inc. It is an internet only Investment Advisor, which means that it provides all its investment services and advice via AI algorithms via the App. Pefin Advisors is registered with the SEC and follows a strict set of rules designed to protect our investors’ accounts.


Pefin Advisors provides personalized investment advice based on your life plans and objectives. From the information provided to Pefin Advisors about your Financial Plans and Financial behavior, Pefin Advisors helps you determine the savings strategy that works best for you. This may include:

  1. how best to pay off high interest rate debt,
  2. determining how much you can save every year towards achieving your goals,
  3. determining the optimal allocation of savings between retirement, other goals, and cash on hand for savings you can tap into today.

Pefin Advisors uses AI algorithms to determine your personalized Savings Strategy.

Next, Pefin Advisors uses a questionnaire to understand your knowledge of financial markets and risk preferences. Pefin Advisors uses this information in addition to your Financial Plans to determine the type of Investments you need, and the risk level of your investments. This is not just a one-off determination but an expected risk level across your entire lifetime, in order to achieve all your financial plans and retire comfortably.

As ongoing information arrives from your income and spending behavior, or financial markets, or changes to inflation, or changes to government rules and regulation like Social Security, Pefin Advisors' AI technology rebalances your plans to keep them current, to keep your savings and investments on track, so that your plans are always achievable. Investment advice is incorporated into your overall Financial Plan and the information conveyed to you in a simple and easy to understand way on the App.

FIDUCIARY STANDARD: Pefin Advisors offers all of its Services (both Investment Advice and Portfolio Management) to a fiduciary standard, which means we are committed to working in your best interests, above our own.

Accessing the Investment Advisory Services:

Pefin Advisors is an internet-only Investment Advisor. Client can access the Investment Advisor by visiting the website This website, provides both non-investment related financial planning services provided by Pefin, Inc. (which is not regulated by the SEC), and investment advice, provided by Pefin Advisors, LLC. Information displayed on the website, may include assumptions on investment returns, which are generated by Pefin Advisors and provided to Pefin, Inc. as duly authorized by the client.


You agree to the following:

  1. Information generated by Advisor for Client

    Information displayed to Pefin, Inc. customers on the application, may include assumptions on investment returns, which are generated by Pefin Advisors and provided to Pefin, Inc. as authorized by the Client. You authorize Advisor to provide this information to Pefin, Inc.

    Advisor evaluates a Risk Profile that is suitable for You, based upon answers to questions, as well as information derived from your Financial Plans provided to Advisor by Pefin, Inc.

    Advisor provides information on how much of Your savings should be invested, how much debt should be paid back and into what types of investment account types they should be allocated.

    Based on the information received by Pefin Advisors on Your comprehensive financial plans, Pefin Advisors may recommend that you enter into investments. Any suggestions regarding the investment portfolio will be based on the evaluation of Your risk/return and fee preferences.

  2. Information sharing approval process on behalf of Client

    Advisor provides expected returns, per the Client determined risk profile, to Pefin, Inc. This enables You to visualize the impact of Advisor’s portfolio recommendations on Your overall finances (as facilitated per the Service Agreement.)

    Advisor evaluates Your ability to save and invest in the financial markets, as per the information You have provided to Pefin, Inc., which is authorized to be shared with Advisor.

    You authorize Pefin Advisors, LLC to provide a copy of the Investment Advice it provides you to Pefin, Inc. and you agree to authorize Pefin, Inc. to use this Investment Advice, in the calculation of your life plans and providing recommendations to you via the App. You further authorize Pefin, Inc. to electronically provide the AI Financial Plan and the underlying data generated by Pefin, Inc., to Pefin Advisors, in order to understand your financial profile and base the AI investment advice it provides you on this information received from Pefin, Inc. All of this information, is automatically transferred electronically via

  3. Cost of Service

    Pefin Advisors offers these services at no cost to clients of Pefin, Inc. It is necessary that clients of Pefin, Inc. make use of these free services to get appropriate analysis, information and advice regarding their entire portfolio, even if they are not engaging with Pefin Advisors to invest.

  4. Liability

    Except as otherwise provided by law, Advisor, Pefin, Inc., or its officers, directors, employees or affiliates will not be liable to Client for any loss:

    1. Client may suffer as a result of Advisor’s investment information or other action taken or omitted in good faith and with the degree of care, skill, prudence and diligence that a prudent person acting in a similar fiduciary capacity would use in conducting an enterprise of a similar nature and with similar objectives under the circumstances;
    2. Caused by using inaccurate, outdated or incomplete information provided by Client and/or by Client’s failure to promptly inform Advisor of changes in his or her financial and/or economic situation, investment objectives or any restrictions that may affect the management of Client’s account;
    3. Resulting from the failure or delay in performance of any obligation under this Agreement arising out of or caused by circumstances beyond Advisor’s reasonable control, including, without limitation, acts of God, earthquakes, fires, floods, wars, terrorism, civil or military disturbances, sabotage, epidemics, riots, interruptions, loss or malfunctions of utility, computer software or hardware, transportation or communication service, accidents, labor disputes, acts of a civil or military authority, governmental actions or inability to obtain labor, material, equipment or transportation; or
    4. Consisting of any indirect, special, incidental or consequential damages.

    In certain instances, federal or state securities laws, including but not limited to the Advisers Act and the Employee Retirement Income Security Act (“ERISA”), impose liabilities on persons who act in good faith, and this Agreement does not waive or limit Client’s rights under those laws.

  5. Confidentiality

    During the term and following the termination of this Agreement, the Parties agree to treat as confidential all information and advice furnished by either party, including their agents and employees, and all transactions and investments held in Client’s account. This confidential information shall not be disclosed to any third parties except as agreed upon in writing, or as required by federal or state law, regulatory authorities.

    Client has received and reviewed a copy of the Pefin Privacy Policy detailing how Client’s non-public personal information is protected.

  6. Representations

    Each party executing this Agreement represents that:

    1. If an individual, it is of legal age and capacity;
    2. It has full legal power and authority to enter into this Agreement;
    3. This Agreement will be legally binding and enforceable against such party when executed;
    4. The terms of this Agreement and the performance of the actions called for under the Agreement by such party will not violate any law, regulation or contractual obligation to which such party is subject; and
    5. If one of the parties is an entity, that party represents that:
      1. The entity is validly organized under the laws of the applicable jurisdiction;
      2. This Agreement has been entered into by an appropriate agent with power to bind the entity who is of legal age and capacity; and
      3. This Agreement has been duly authorized by appropriate entity action and when executed and delivered will be binding in accordance with its terms.

    Client confirms that the terms of this Agreement and his or her engagement of Advisor do not violate any obligations of Client, whether arising by contract, operation of law or otherwise.

    Client agrees to notify Advisor in writing, via the application, of any event that might affect his or her authority or the validity of the Agreement. Client and Advisor agree to immediately notify each other in writing if any of the representations set forth in this section of the Agreement cease to be accurate.

    Client represents that it is not a retirement plan “Plan” organized under ERISA.

  7. Investment Services

    Pefin Advisors offers to open an Investment Account and manage the portfolio for You. It is in the sole discretion of Client whether an Investment account is opened, and opening an Investment Account is not required to benefit from the other services provided by Pefin, Inc., or the free advice provided by Pefin Advisors described herein.

By executing this Investment Advisory Agreement, the parties acknowledge, understand and accept their respective rights, duties, and responsibilities.