A. Firm Information
Fingage Advisors LLC (“Fingage”), established in 2016, is a registered investment adviser registered with
the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940,
as amended. It is a wholly owned subsidiary of Fingage Holdings Inc. (“Fingage Holdings”), a privately held
company. Fingage operates the following website
www.fingage.com (“Site”). Additional information
about Fingage is provided in Fingage’s Form ADV part 1, which is available online at
http://www.adviserinfo.sec.gov.
B. Overview of Services
Nothing on Fingage’s Site should be construed as a solicitation or offer, or recommendation, to buy or sell
any security. Financial advisory services are only provided to investors who become Fingage clients
("Clients") pursuant to a online Client Agreement, which investors are urged to read and carefully consider
in determining whether such agreement is suitable for their individual facts and circumstances.
Fingage offers Clients investment advice related to accounts held for a retirement objective. The
investment advice consists of a diversified portfolio of mutual funds, exchange traded funds (ETFs), or
units in separately managed accounts (“Funds”), chosen from a retirement plan’s investment options or
from the general universe of mutual funds and securities. In addition, Fingage provides Clients with a
personalized glide path, and simulated forecasts of wealth and retirement readiness. Fingage will monitor
Clients’ accounts and either automatically rebalance their portfolio to the most recent recommendation
from their respective personal glide path or notify the Clients that they need to manually rebalance their
portfolio and provide them with instructions. The services of Fingage taken all together represent a
personalized alternative to target date funds.
Fingage will also provide some Clients with retirement readiness indicators and projections of wealth
based on their existing portfolio holdings - and not an optimized glide path - using Fingage’s asset return
and risk assumptions of their portfolio holdings.
Fingage’s approach builds on modern portfolio theory and incorporates recent advances in asset
allocation, risk management, portfolio optimization and retirement planning to provide Clients with
optimized goal-based investment strategies. Fingage offers personalized investment management
services, which are designed to help Clients achieve their investment objectives with the least risk
possible.
Fingage provides investment advice to Clients through its Online Advisor only. Fingage offers Clients a
personalized investment strategy and glide path where exposure to the different asset classes is obtained
through the investments options which are made available to them through their retirement plan (“Plan”)
or from the general universe of mutual funds and securities. The personalized glide path consists of a mix
of asset classes such as equity, fixed income, or other asset classes. As the investor approaches retirement
age, the allocation to growth asset classes such as equity will decline gradually and the allocation to
defensive asset classes such as fixed income will increase. The following factors are taken into account
when determining the personalized glide path and investment strategy: age, desired retirement age,
wealth, income, and saving rate. Changes to any of these factors may lead to a change in the optimal
investment strategy for the investor. A large number of Monte-Carlo simulations (a technique used to
model future behavior of stocks and bonds) are used to evaluate the range of outcomes of the different
possible investment strategies and the strategy which maximizes the expected wealth of the investor at
retirement and minimizes the expected risk of income shortfall is considered to be optimal and is chosen
for the investor. These Monte Carlo simulations are based on the investor’s financial situation as provided
to Fingage by the investor or
by his retirement plan on his behalf. In addition, these simulations and the
resulting investment advice depend on Fingage’s chosen approach and on estimates of expected returns
and expected risk of the major asset classes as well as publicly available forecasts of inflation and wage
growth over time.
Fingage determines for each client the optimal level of risk tolerance which will maximize the wealth at
retirement and minimize the risk of income shortfall based on a large number of Monte-Carlo simulations.
Fingage offers Clients the ability to increase or decrease the risk level of their portfolio as well as to revise
the information about their financial situation, through the Fingage interactive website portal. Clients may
be offered depending on availability an optional service of automatic portfolio rebalancing “Portfolio
Rebalance Program”. Otherwise, Fingage notifies the Clients that they need to manually rebalance their
portfolio and provides them with detailed instructions.
Fingage researches each investment option on the Plan to determine which one is the best representative
of each asset class and Fingage creates as diversified a portfolio as possible given the set of Funds (mutual
funds, ETFs, separate accounts, or other investment vehicles) available on the plan. The set Funds is not
selected by Fingage but by the plan sponsor or plan fiduciary. Alternatively, for clients without a
retirement plan, Fingage will choose the investment securities from the general universe of mutual funds
and securities.
Fingage is an Independent Investment Adviser and does not receive any compensation from those who
provide or manage the Funds available through the Plan. Fingage charges a fee that is based upon a
percentage of plan assets, and/or a flat dollar amount, and/or a percentage of a plan participant’s account
balance. As such, Fingage has no incentive to direct a Client to invest in one investment option over
another. The investment advice provided to a Client is based on the information supplied by the Client
(and, if applicable, information supplied by the Plan) and the market and economic conditions prevailing
(or reasonably believed to occur) at the specific time that the investment advice is provided to the Client,
and Fingage’s best efforts to evaluate the different investment strategies under Fingage’s approach. In
rendering Independent Participant Investment Advice to a Client, Fingage is a fiduciary under the
Employee Retirement Income Security Act of 1974 (“ERISA”) and the Investment Advisers Act of 1940 (the
“Act”) and will act solely in the best interest of its Clients. Unless Fingage is also providing Independent
Plan Investment Advice to the Plan, Fingage, has no obligation, fiduciary or otherwise, to select and
monitor the investment options made available under the Plan.
C. Sub-Advisory Services
In addition to providing investment advisory and related services directly to clients under arrangements
with employer-sponsored or public plans and plan sponsors, Fingage may also have arrangements with
financial institutions to provide similar services on a sub-advisory basis. Fingage Holdings Inc. may license
certain technology and software, and provide other services to financial services firms to enable those
firms to provide investment advisory and related services. For example, the parent of Fingage Advisors
LLC, Fingage Holdings Inc., may develop and host customized or private-labeled websites to enable a
financial institution to make investment advisory and related services available to that institution’s clients.
Depending on the particular arrangement with the financial institution, Fingage may act as sub-advisor to
the financial institution, or Fingage Holdings Inc. may act as a technology vendor and the financial
institution will be responsible for making investment recommendations to its clients.
D. Assets Under Management
As disclosed in Fingage Advisors LLC’s Form ADV Part 1, Fingage currently manages $682,647 on a
discretionary basis on behalf of 5 clients and $1,100,165 on a nondiscretionary basis as of December 31,
2023.
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