A. Description of the Advisory Firm
Bloom was founded on September 14, 2021. Additional information about Bloom is available on the SEC’s
website at
www.adviserinfo.sec.gov. You can search this site by using a unique identifying number,
known as a CRD number. The CRD number for Bloom is #317405. The SEC’s website also provides
information about any persons affiliated with Bloom who are registered, or are required to be
registered, as investment adviser representatives of Bloom. Samuel Yang serves as Bloom’s Chief
Compliance Officer (“CCO”).
Bloom is a registered investment adviser (“RIA”) which offers non-discretionary online advisory services
to its advisory clients (each a “Client,” and collectively, “Clients”) through an online web-based and
mobile platform (the “Platform”).
Bloom is a privately held company headquartered in Ridgewood, New Jersey. Bloom is wholly-owned
by Contour Labs, Inc. Information about Bloom’s organizational and ownership structure is provided
on Part 1 of Bloom’s Form ADV which is available online at
www.adviserinfo.sec.gov.
Bloom operates an investment Platform available at
www.bloomapp.com (the “Website”) and as a
mobile application (“App”). When a Client opens an account (“Investment Account”) with Bloom, they
will be able to access the investment Platform through either the App or the Website. The Platform
provides Clients with investment advice in the form of certain recommended publicly traded equities,
Exchange Trade Funds (“ETFs”) (“Investment Opportunities”), and cryptocurrencies specifically tailored
and designed for each Client based on the Client’s investment profile. The Investment Opportunities
are developed solely by Bloom’s proprietary algorithmic model (the “Model”) that aggregates and
utilizes various data sets such as education data, GPS data and more, and processes it with machine
learning to provide short-term confidence indication in the stock movement. This data is then combined
with the Clients’ Suitability Questionnaire in order to provide tailored Investment Opportunities for
Clients. The Platform also provides content regarding finance and markets.
Clients open individual accounts, including accounts established under the Uniform Gifts to Minors Act
(“UGMA”) or the Uniform Transfers to Minors Act (“UTMA”) for the benefit of a minor. Through the
implementation of a written trading authorization (“Trading Authorization”), Clients may authorize
their minor children (including minor children for whom they serve as legal guardians) who are users of
the Platform (each a “Authorized User” and collectively, “Authorized Users”) to invest on their behalf,
subject to the their control and monitoring. Clients retain may revoke the Authorized Users’ Trading
Authorization at any time at their sole discretion.
Advisory services are delivered solely through the Website and App. The Website also provides general
education and content regarding finance and markets. Bloom does not provide investment advice in
person or over the phone or in any manner other than through the Website and App. Additional
information about Bloom’s products and services is provided in Bloom’s Form ADV Part 1 available
at
www.adviserinfo.sec.gov. Bloom encourages visiting the Website or the App for additional information.
B. Description of the Advisory Services
Form ADV Part 2A Page 5
Bloom provides purely non-discretionary advisory services through the Platform. The Platform
recommends one or more non-discretionary Investment Opportunities to each Client based on the
Model and on the Suitability Questionnaire (“Suitability Questionnaire”) completed by such Client. The
Client or Authorized User (as applicable) may then choose to purchase one of the recommended
Investment Opportunities. The Platform currently relies on questions relating to suitability (i.e., age,
income and liquid net worth, investment objectives, investment time horizon, and risk tolerance) in
recommending Investment Opportunities, and these questions are not weighted equally. Clients should
understand the recommendation of Investment Opportunities relies upon the information provided by
each such Client, and Bloom does not capture any additional information not covered in the Suitability
Questionnaire
in providing investment recommendations. No Client is recommended cryptocurrencies
regardless of their risk profile. Clients are advised to promptly update their financial information on the
Suitability Questionnaire if there are any changes to their financial situation, financial goals, objectives,
personal circumstances, time horizon or if other relevant information changes or becomes available, as
the Investment Opportunities recommended to each Client are reliant upon each Client’s Suitability
Questionnaire.
Clients input their personal information, including investment objectives, risk tolerance, and financial
resources via the Suitability Questionnaire within the Platform. Clients may impose restrictions on
investing in securities in certain sectors via the Suitability Questionnaire based on risk tolerance,
investment preferences, and financial goals. Bloom will utilize the information from the Suitability
Questionnaire to tailor its investment recommendations for Clients in accordance with the Clients’
investment risk and financial parameters and objectives. Bloom with recommend Clients invest in ETFs,
cryptocurrencies, and publicly traded equities. Bloom offers investment advice only with respect to a
limited type of investment, ETFs, cryptocurrencies, and publicly traded equities. Clients should
understand the investment recommendations rely upon the information provided by the Clients, and
Bloom does not capture any additional information not covered in the questionnaire in making its risk
assessment and providing its investment advice.
Interested parties may access the Platform at any time. This Brochure, which is available on the
Platform, describes, among other things, Bloom, its services, potential fees and any material conflicts
of interest that could be reasonably expected to impair the rendering of unbiased and objective advice.
Bloom’s privacy policy is also provided for reference on the Platform. Both the Brochure and the privacy
policy are available to interested parties for their download and/or printing.
The Investment Opportunities created by the Model and provided to Clients and Authorized Users (as
applicable) are updated on a daily basis, as determined by Bloom’s proprietary Model and the ongoing
changes in data that the Model relies upon and utilizes.
Clients and their Authorized Users (as applicable) may access the App or the Website in order to purchase or
sell equities, cryptocurrencies, and ETFs. When a Client or Authorized User (as applicable) accesses the
Investment Account, they will be provided with a list of Investment Opportunities that the Model
generates and determines are appropriate for a specific Client based on the information provided in
the Suitability Questionnaire. Clients and Authorized Users (as applicable) have the option to purchase
any of the Investment Opportunities provided through the Platform.
The investments in each Client’s Investment Account are held in a separate account in the name of the
Client at an independent custodian, and not with Bloom. All Investment Accounts managed through
the Platform are required to use the custodian selected by Bloom, Alpaca Securities LLC (the
Form ADV Part 2A Page 6
“Custodian” or “Alpaca”), as the independent custodian. Each account agreement with the Custodian
will grant Bloom the authority to manage each Client’s Investment Account on a non-discretionary
basis, seeking a Client’s authorization for each trade.
The equities, cryptocurrencies, or ETF shares purchased or sold by a Client and/or held in Client
accounts may be either whole shares or fractional shares. Bloom enables dollar-based investing,
whereby Bloom can buy a fixed dollar amount rather than whole shares on behalf of its Clients. Bloom,
through Alpaca aggregates all dollar-based purchases and places whole share orders for executions.
Thereafter, Bloom allocates the fractional shares to the individual Client accounts. Fractional shares,
however, are typically not transferrable outside of a Client’s advisory account because the financial
system in the United States currently is structured only to accommodate transfers of full shares. As a
result, fractional shares may not be marketable or transferrable to another brokerage account. In the
event of a liquidation or transfer of the assets in a Client’s account to another account, Bloom may
convert such fractional shares to cash.
Clients will receive Bloom’s Advisory Agreement, which further detail the services Clients will receive,
fees charged to Clients, and the conditions of the Bloom-Client relationship.
C. Assets Under Management
Bloom has $4,757,784 in non-discretionary assets under management as of March 6, 2024.
Form ADV Part 2A Page 7