In March of 2021, Onesta (formerly Finance Friends, Inc) applied to be registered with the U.S. Securities and Exchange Commission as a registered investment advisor. In March of 2023, Finance Friends, Inc changed its name to Onesta Inc.
Onesta created and provides an interactive website to individuals and high net worth individuals (“user”) whose primary function is to advise the user in the selection of an investment advisor firm or representative (“RIA”).
Onesta processes RIA Form ADV data and makes it available on an interactive website. Onesta utilizes statistical methods to visually represent the Form ADV information made available by the SEC. When ranking and recommending RIAs, Onesta uses a combination of statistical scoring, user input, and our proprietary algorithm to rank the RIA matches. The algorithm is an automated representation of our RIA evaluation system and asymmetrical weighting of Form ADV data.
Any information collected or recommendations made to the user is performed through the interactive website. Onesta personnel will not elaborate or expand upon the investment advice provided by its interactive website, or otherwise provide investment advice to its clients, except as permitted by the de minimis exception. Additionally, Onesta does not enable personnel to ask follow-up or clarifying questions about the user’s input, address inconsistencies in the user’s input, provide assistance when filling out the questionnaire, or explain important concepts; the online disclosures and interactive website are designed to assist in these functions (more in Item 11). Any non-website communication is restricted to administrative or technical purposes.
All SEC and state registered investment adviser firms, whom the SEC has made available via Form ADV filings, are included as possible recommendations for the user. The recommendations are presented to the user through a combination of user input and algorithmic processing - a questionnaire.
After completing the questionnaire, the user is presented a ranked list of recommendations. The number of items included in the list depends entirely on the user’s input and subsequent

algorithmic processing.
Additionally, the algorithm has the capacity to recommend no matches if the user’s input is inconsistent or overly restrictive. In the event of a no-match, the interactive website will prompt adjustment of the user’s input.
After receiving the recommendation list, the user is presented the option to inquire further into each of the recommendations. Whether or not the RIA has an established agreement with Onesta plays no part in the ranking or recommending of RIAs.
If a user inquires about an unsigned RIA, Onesta will attempt to verify the identity and contact information of the RIA prior to the continuation of the referral process; additionally, the RIA must agree to the Onesta Fee Arrangement and Terms and Conditions to be onboarded. The process of onboarding RIAs is entirely administrative, no advisor will be denied the opportunity to join the Onesta platform for reasons other than refusing the Onesta Fee Arrangement/Term and Conditions, or failing to confirm identity.
In the situation where the inquired about RIA fails to complete the onboarding process, the user who inquired about the RIA will be made known of the RIA’s refusal to complete the process and be presented the with option to either continue pursuing the RIA independently of the Onesta platform or to inquire about other advisor(s) from the recommendation list. The website’s recommendation is not adjusted, amended, or otherwise altered unless done so by the user through the interactive website - re-submitting the questionnaire.
In accordance with the record keeping requirements, Onesta employs a digital user classification system that tracks which of the users are provided advice exclusively through the interactive website and which are not. The number of users to receive advice not through the interactive website will be fewer than 15 clients in the preceding 12 months according to the de minimis exception.
Onesta’s services are primarily to advise about the selection of other RIAs through an interactive website. Onesta does not manage any assets. As of March 2022, Onesta manages $0 on behalf of any clients.