the Advisor may recommend buy, sell, or reallocate positions that
have been held less than one year due to market conditions, or to generate cash.
At no time will Goalsetter Gold accept or maintain custody of a Client's funds or securities. All
Client assets will be managed within their designated account[s] at the custodian, DriveWealth, pursuant
to the terms of the Platform agreement. Please see Item 12 – Brokerage Practices.
Clients visiting www.goalsetter.co/legal and other electronic sites maintained by the Advisor
will be provided with links to the Apple App Store or Google Play App store from which the
Platform may be downloaded in order to access to the Platform, including its investment and
financial literacy and educational features.
C. Client Account Management
Limited Access to Goalsetter Gold
Goalsetter Gold serves as an "Internet-Only" investment advisor pursuant to Section 203A-2(e) of
the Investment Advisers Act of 1940, as amended (the "
Advisers Act"). Under this registration, Goalsetter
Gold provides investment advice solely through the Platform. Goalsetter Gold is not available to Clients
for telephone conversations or communications through other means such as U.S. mail, courier, or email
(other than operational emails). Due to its virtual nature, Goalsetter Gold does not meet with Clients at its
offices. All advice, support, and inquiries are delivered through the Platform. To gain access to Goalsetter
Gold, the Client must join the Platform and agree to its terms of use.
The Advisor may, for a limited number of Clients annually, provide customized services, subject
to the limitations outlined in Section 203A-2(e) of the Advisers Act.
D. Wrap Fee Programs
This brochure describes the wrap fee program offered by Goalsetter Gold, which bundles or
"wraps" non-discretionary investment advisory services with other administrative services provided by an
affiliate and our custodian, DriveWealth. For more information about DriveWealth fees that are in addition
to the monthly fee, please visit
https://legal.drivewealth.com/ or review your investment advisory
agreement.
E. Assets Under Management
Goalsetter Gold does not provide continuous and regular supervisory or management services to
its Clients, nor does it have Clients for whom it has regulatory assets under management.