A. Description of the Advisory Firm DiversiFi Capital LLC (hereinafter “DiversiFi”) is a Limited Liability Company organized in the State of California.
The firm was formed in May 2015 and approved as an investment advisor in June 2015 and the Managing Member is Nathan Dingler.
B. Types of Advisory Services Portfolio Management Services DiversiFi offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DiversiFi creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
•Investment strategy •Personal investment policy
•Asset allocation•Asset selection
•Risk tolerance•Regular portfolio monitoring DiversiFi evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DiversiFi will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. DiversiFi makes reasonable efforts to document and annually update client suitability information.
At DiversiFi’s discretion, investment management service will aim to invest in socially impactful investments. These social impact investments are determined by three sets of criteria. The first is investing in companies that help to advance environmental sustainability and improve resource efficiency as a society. The second is investing in companies that respect human rights and provide contribution towards a more equitable society. The third is investing in companies that are building transparent businesses and promote accountable governance. The investment vehicles that will be used for these social impact investments will be individual equities and mutual funds that filter for investments as noted above; additionally, mutual fund companies that are able to pass these filters (as a firm) are also eligible for inclusion. The qualifications for these discretionary investments will be made using resources available to DiversiFi Capital LLC through publicly documented resources. ETFs may be used to track specific market benchmarks (i.e., S&P 500 ETF), and may be outside the realm of social impact investing.
DiversiFi seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of DiversiFi’s economic, investment or other financial interests. To meet its fiduciary obligations, DiversiFi attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, DiversiFi’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is DiversiFi’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients that is consistent with the Adviser’s fiduciary duty.
Private equity fund DiversiFi is the manager and provides advice to DFi Venture Fund I, LP DFi Venture Fund II, LP, and DiversiFi Ventures Fund IV, LP. The advisory fees that DiversiFi receives for providing those services are set forth in the agreement between DiversiFi and the Fund. Additional details about the fees charged to an investor in such fund is available in the current prospectus for the fund. Pooled investment vehicles are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, accounting/audit fees, administration fees, etc.). Those fees are separate and distinct from the fees and expenses charged by DiversiFi.
Financial Planning Services DiversiFi provides financial planning services to clients on three different levels. Clients can choose from Starter, Core, or Plus. These services include but are not limited to the following: ●Financial plan tracking ●Investment performance reporting ●Education center access ●General email support ●Life event meetings ●Financial plan review ●Tax check in ●Tax review ●401(k) rebalance ●Estate planning review ●Employee stock benefits strategy ●Life insurance audit ●Disability insurance audit ●Long term care insurance audit ●Holistic investment portfolio review ●Fixed insurance Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; insurance planning; real estate planning; estate planning; tax planning; retirement planning; college planning; and debt/credit planning.
In

offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2.
FINANCIAL PLANNING Our financial planning service is intended for individuals who prefer a more virtual classroom approach to financial planning education while still offering on-demand advisor support for individualized questions.
One-Time Initiation Fee: $500 StarterCorePlus $175 per month$250 per month$450 per month Our Starter level is for individuals who are looking to start developing healthy financial habits such as budgeting, saving, and investing.
Personal Financial Advisor (1-2 yrs experience) Annual tax return review Tax estimates Help with 401(k) rebalancing Strategy: Account restructuring and consolidation, stock vesting, budget, savings, investment & tax The Core level offering is geared toward senior-level employees/Managers whose net worth is heavily tied to company stock.
All the services of Starter, and: Personal Financial Advisor (4+ yrs experience) In-depth employer stock analysis Multi-year tax simulations Advanced stock compensation strategies (liquidity/public events) Plus level is for Senior Management, Founders, or established individuals who need to manage many complexities across their investments and taxes.
All the services of Starter, Core, and: Senior-level Advisor (6+ yrs experience) Priority access to invest in DiversiFi Ventures Coordinated communications with referrals to save you time (ie: real estate, tax, loans, etc) All service levels include the following: Annual Tax Return Review Blueleaf Access Client Resource Center Access Financial Planning Workbook Financial/Retirement Model Quarterly Newsletters Weekly Wrap-Up Emails The following are stand-alone services provided by DiversiFi Capital LLC and their respective fees charged: ●Tech Layoff Package ○One-Time Cost of $1,500 ●Managed Estate Planning through EncoreEstates ○Starter/Core: One-Time Cost of $1,700 ○Plus: One-Time Cost of $1,500 Estate Planning We offer Estate Planning services to our ongoing financial planning clients and our investment management clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for clients. The fees associated with estate planning services are separate, in addition to your ongoing financial planning or advisory fees, and are disclosed in Item 5.
Depending on the client's needs and desires for estate planning document review, preparation, or updates, we will engage with EncorEstate Plans, a third-party scrivener service or estate planning attorneys. Based on the complexity of the client’s estate planning needs, this third-party service may not be the best fit, and this will be determined at the start of engagement. DiversiFi does not provide legal advice as we are not estate planning attorneys.
Services Limited to Specific Types of Investments DiversiFi generally limits its investment advice to mutual funds, fixed income securities, real estate funds, fixed insurance, equities, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), and commodities. DiversiFi may use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions DiversiFi offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement that outlines each client’s current situation (Age, income, tax levels, Total net worth, Liquid net worth, Employment status, Fair market value of primary residence, Investment objectives, Investment experience, Investment time horizon, Liquidity, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs.
D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. DiversiFi does not participate in any wrap fee programs.
E. Assets Under Management DiversiFi has the following assets under management: Discretionary Amounts:Non-discretionary Amounts:Date Calculated: $ 287,593,800.00$ 15,000.00December 2023