ADVISER DESCRIPTION
Legion Global Capital Management LLC, d/b/a Legion Invest (hereinafter referred to as
“Legion”, “Adviser”, “we”, “us”, “our”) is a Delaware corporation with its principal office located
in New Jersey and is registered with the Securities and Exchange Commission (the “SEC”) as
an investment adviser. Legion is a subsidiary of Legion Invest Co, a Delaware corporation. Mr.
Steven Dong and Mr. Feras Abou Salim are co-founders of Legion.
ADVISORY SERVICE
Legion provides investment advisory services to retail individual investors, high net worth
individuals, registered investment advisors, family offices and other business entities
exclusively through a technology platform offered only through our application programming
interface (the “Platform”). The Platform may be offered to our clients via unaffiliated third-
party institutions with whom Legion has entered into agreements regarding the offering of
advisory services by Legion (“Partners”). These individuals will be considered clients of Legion
and will have access directly to the Platform. In certain cases, Legion may act as a sub-adviser
to a third-party investment adviser.
Legion is a technology company that owns and maintains the Platform through which advisory
clients have access via our Partners. Our clients receive investment recommendations via the
Platform for various quantitative investment strategies based on a detailed questionnaire that
clients complete at onboarding (further described below).
Our advisory services are offered as a wrap fee program to retail clients. Our wrap fee program
provides our clients the opportunity to obtain professional portfolio management for an
inclusive fee that is based upon the client’s assets under our management. This means clients
are free to add or withdraw money from their Legion advisory accounts whenever they choose,
with no additional fees, notwithstanding any fees assessed by a client’s own financial
institution. Legion charges clients a single bundled fee that covers our investment advisory
services as well as brokerage and custodial services associated with holding and trading
securities provided by our custodian.
Our investment strategies are offered and recommended to clients exclusively through our
Partners who will provide investors with access to the Platform. Our investment
recommendations are based on a detailed questionnaire that clients complete at onboarding.
Our advisory service delivers discretionary portfolio management services through the
strategies. Each strategy is designed to provide clients with an efficient way to invest in the
capital markets based on each client’s individual investment time frame, risk tolerance, and
liquid net worth. To get started, we ask prospective clients to respond to a sequence of
interactive questions that are important to the development of their portfolios, such as
investment objective, purpose for investing, risk/return tolerance, annual income, among
others. Following responses, clients receive a recommended investment strategy developed to
be appropriate for the client’s personal financial situation and that targets a client’s expected
risk and return, investment objective and purpose for investing. The recommended
investment strategies we offer are the Gold Tier or the Platinum Tier strategies. The
investment recommendation is delivered for viewing over our application programming
interface. If a client accepts our investment recommendation, clients are invested directly in
the securities found within the recommended investment strategy and such investment is
based on allocations produced by our proprietary algorithm. Otherwise, a client can elect to
override Legion’s recommendation and choose strategies that they are eligible for.
INVESTMENT STRATEGIES
We seek to provide personalized, long‐term oriented investment portfolios that are invested
in our strategies, either Platinum Tier or Gold Tier (further described below). Each strategy is
comprised primarily of a concentrated basket of stocks, ETFs or ETNs which are selected via
our proprietary and fully discretionary algorithmic research process and are actively
managed. Clients are invested in a personalized blend of these strategies based on personal
information provided during the onboarding process (see above). This information includes a
client’s investment risk and goals, investment objectives and various financial parameters
such as net worth. Our proprietary algorithm monitors clients’ portfolios that are invested in
each strategy. The minimum deposit to a client’s account will be $100.
PLATINUM TIER STRATEGIES
Platinum Tier investment strategies have a higher minimum investment and a differentiated
risk/return profile. A client must meet higher minimum eligibility requirements of
employment status, annual income, and investment goals to receive a recommendation into
the Platinum Tier. Prior to investing in the Platinum Tier clients will be provided with a
description and objective of each recommended strategy including the number of days the
strategy has been live, the type of securities the strategy invests in, the turnover rate, the
drawdown rate and the CAGR rate. Additionally, a document displaying an overview of the
recommended strategy will also be available for clients to view.
The Firm, via its proprietary algorithm, may purchase whole or fractional shares within a
client’s account. Through its discretionary authority the Firm will allocate and rebalance
shares within a client’s account as necessary. Purchases are based on the mandate of the
recommended Platinum Tier strategy and the amount invested by the client. The minimum
deposit to a client’s account will be $100.
GOLD TIER STRATEGIES
Gold Tier investment strategies will have a wide range of risk/return profiles. A client must
meet minimum eligibility requirements of employment status, annual income, and investment
goals to be part of the Gold Tier. Prior to investing in the Gold Tier investment strategies,
clients will be provided with a description and objective of each recommended strategy
including the number of days the strategy has been live, the type of securities the strategy
invests in, the turnover rate, the drawdown rate and the CAGR rate. Additionally, a document
displaying an overview of the recommended strategy will also be available for clients to view.
The Firm, via its proprietary algorithm, may purchase whole or fractional shares within a
client’s account. Through its discretionary authority the Firm will allocate and rebalance
shares within a client’s account as necessary. Clients approved to invest in the Platinum Tier
will have access to both Platinum Tier investment strategies and Gold Tier investment
strategies. This may change if the suitability information provided by the client is revised. The
minimum deposit to a client’s account will be $100.
INVESTING
We use information from the initial questionnaire that all clients are required to complete at
onboarding to create an investment portfolio that is customized to each clients’ risk tolerance,
financial parameters and investment objectives. For each client’s portfolio we consider,
through our proprietary algorithm, a client’s employment status, income, investment goals and
reasons to invest, and net assets. Our proprietary algorithms evaluate the responses for each
client and recommend investment strategies (described above).
Our recommendations are based solely upon the information provided by each client via the
Platform. As such, the suitability of our investment recommendations is limited by and relies
on the accuracy and completeness of the information provided by each client. The only type of
restrictions a client may impose on the portfolio is the degree of risk level (conservative,
moderate and aggressive growth) and the amount of funds invested in each investment
strategy. A client will not be able to restrict the purchase of specific securities, however clients
will be able to change his/her risk profile or select (switch to) a portfolio with a different risk
profile. Clients are obligated to update their information through the Platform as soon as there
are changes to their financial situation, goals, objectives, personal circumstances, or if other
relevant information changes or becomes available. Clients ultimately decide whether to
accept and act upon our investment recommendations.
Investing in securities involves risk of loss that clients
should be prepared to bear.
INVESTMENTS
In the event we decide to remove a stock, exchange traded fund and/or note from any of our
strategies, we will notify our clients and our Platform will show the removed or modified
position. We will also algorithmically rebalance our clients’ portfolio to its original desired risk
preference.
Interested parties must access our secure Platform where clients are offered this current Form
ADV brochure that describes our services, potential fees, etc., as well as any material conflicts
of interest that could be reasonably expected to impair the rendering of unbiased and objective
advice.
CLIENTS
We currently offer investment recommendations and advisory services to retail individual
investors, high net worth individuals, registered investment advisors, family offices and other
business entities via our Partners which provide access to the Platform. We interact with
investment advisory clients, as well as prospective clients, solely through our Platform. We do
not offer financial planning services, tax, accounting, or legal advice. Clients can only invest in
U.S. securities. Clients will not interact directly with investment advisory personnel.
We reserve the right to deny any prospective clients access to the Platform and to terminate
client accounts for reasons related, but not limited, to unsuitability and/or if clients fail to
timely maintain financial and other information previously provided by the client on the
Platform or update this information on at least an annual
basis. A client’s failure to timely
update this information could materially impact the quality and applicability of Legion’s advice
and recommendations.
CLIENT ONBOARDING
At account opening (“Client Onboarding”), the client will be prompted to complete a series of
personal financial questions as well as suitability questions prior to investing. Some of these
questions determine if the client can invest with Legion. For KYC purposes, clients will be
required to disclose their employment status, occupation, annual income, address and
citizenship status. Furthermore, clients are also required to disclose if the client or a family
member is a senior executive or a 10% shareholder of a publicly traded company; if the client
is related to a politically exposed person (PEP); and whether the client is employed by a
broker-dealer.
Client Onboarding is only complete once a client has (i) completed our initial questionnaire
which includes personal financial questions as well as suitability questions; (ii) electronically
accepted and countersigned our investment advisory agreement and brokerage agreement;
(iii) electronically received and accepted our Form ADV Part 2A, Form CRS and privacy policy;
and (iv) consented to electronic delivery of documents and written communication. Only when
Client Onboarding is complete will we provide personalized investment recommendations in
one or more of our Strategies. Clients have the availability to choose a strategy to purchase via
the Platform. It is important to note that none of our staff will have access to a client’s bank
account information or a client’s login credentials.
ASSETS UNDER MANAGEMENT
Legion does not currently have assets under management. We expect to update this brochure
as soon as we start servicing clients. The Firm will have sole discretion over the assets we
manage. The minimum deposit to a client’s account will be $100.
ADVISORY FEES
Client’s pay an investment advisory wrap fee which allows clients to pay a single fee for
investment advisory services (the “Wrap Program Fee”), as described below.
The Wrap Program Fee is a bundled fee, which includes the cost for advisory services,
execution, clearance, custody and account reporting. Legion charges clients a Wrap Program
Fee based on the total net deposits in their account and the investment strategy the client is
invested in. The Wrap Program Fee is separate from fees imposed by a client’s separate
relationship with a Partner.
For clients with less than $5,000 in net deposits, Legion charges a Wrap Program Fee of $5.00
per month (fixed fee). For clients with greater than $5,000 in net deposits, Legion charges a
Wrap Program Fee based on the assets under management that clients have invested in one of
our two investment strategies.
Legion charges clients who are invested in the Legion Gold Strategies (and have $5,000 or more
in net deposits) a 1.00% advisory fee, per annum, for the assets they have invested in Legion
Gold Strategies. Clients invested in Legion’s Platinum Strategies (and have $5,000 or more in
net deposits) are charged a 2.00% advisory fee, per annum, for the assets they have invested
in Legion Platinum Strategies.
We reserve the right, in our sole discretion, to negotiate, reduce, or waive the advisory fee. Our
fees are billed monthly, in arrears.
The asset-based fee is assessed based on the daily market value of a client’s portfolio summed
over the previous month. For the initial period of an engagement, the Wrap Program Fee is
calculated on a pro rata basis. In the event the Investment Advisory Agreement is terminated
by either party, the Wrap Program Fee for the final billing period is prorated through the
effective date of the termination and the outstanding portion of the Wrap Program Fee is
charged to the client. Clients authorize Legion to deduct fees directly from their client account
custodied at our custodian or from an external funding source provided by the client. Legion
will have no access to the client’s account or to a client’s external funding source except only
to debit investment advisory fees.
Although we have a financial incentive to encourage you to increase your assets under our
management, as part of our fiduciary duty as a registered investment adviser we endeavor at
all times to put the interests of our clients before our own. Furthermore, as a registered
investment adviser we have the utmost duty to provide investment advisory services in good
faith, honesty and loyalty to our clients.
Legion has entered into agreements with its Partners whereby Legion compensates its
Partners via a revenue sharing structure for referring Clients to Legion, however, there is no
differential in the Wrap Program Fee charged to the Client as a result of these agreements. For
additional information regarding this arrangement, please see Item 14, below.
DIRECT FEE DEBIT OF LEGION’S FEE
Clients authorize and direct Legion to instruct the custodian to deduct the Wrap Program Fee
directly from the client’s custodial account at our custodian or linked funding source and pay
those fees to Legion. Legion may also take the Wrap Program Fee from a client’s account by
instructing our broker to deduct such fee from the assets in the client’s account, including by
selling (liquidating) a sufficient amount of holdings to cover the Wrap Program Fee. Each time
a client uses our advisory services, they reaffirm their agreement that Legion may charge
the client’s account, as applicable.
In the event Legion cannot withdraw fees from the client’s account or the client’s funding
source, Legion reserves the right to terminate a client’s access to its advisory services. We
will notify clients in writing via the email the client has on file with their account of the
potential of termination of our advisory services. Termination of accounts will be undertaken
at Legion’s sole discretion with prior written notice to the client. Each client may also
terminate their account at any time. Upon full termination of a client’s account by the client,
assets are liquidated as soon as practicable, and money is returned to the client via the
client’s funding source less any Wrap Program Fee due and owing, if applicable. However,
with prior written notice, we may accommodate a client and transfer the client’s holdings to
another custodian. Clients are advised that transferring their holdings to another custodian
may generate fees that client should be prepared to pay. Once the account termination process
is initiated, Legion will receive the Wrap Program Fee from the client with respect to the
client’s account, which will be deducted from the transferring proceeds.
PAYMENT OF FEES
Fees are billed monthly in arrears and fee payments are generally withdrawn from the client’s
account within the first ten days of each month. Legion does not accept cash, money orders or
similar forms of payment for any of its engagements, nor do we allow for direct billing. The
client’s first billing cycle begins once the Advisory Agreement is virtually executed with Legion
at onboarding and assets have been invested. Fees for partial months are prorated based on
the remaining days in the reporting period in which Legion services the account. All fees
deducted will be clearly noted on account statements that the client receives from the
custodian.
Please note that each client shares in the responsibility to verify the accuracy of fee
calculations; the custodian may not necessarily verify billing accuracy for each client. Clients
will receive statements directly from our custodian at least quarterly. We urge clients to
carefully review those statements and compare the custodial records to the reports that we
provide them. The information in our reports may vary from custodial statements due to
accounting procedures, reporting dates or valuation methodologies of certain securities.
TERMINATION OF SERVICES
Either party may terminate the Investment Advisory Agreement at any time, which should be
done in writing. If a client orally notifies Legion of the termination and if, within two business
days following this notification Legion has not been sent the written notice by the client, Legion
will prepare and send a written notice of the termination to the client.
Upon receipt of a termination notice or when a termination is sent to a client, Legion will not
be responsible for future investment allocation, advice or transactional services (except for
limited closing transactions). Legion will inform our broker/custodian that the Investment
Advisory Agreement has been terminated and our broker/custodian will close the account
within seven days of termination.
ADDITIONAL CLIENT FEES
There are no sales loads, brokerage fees, mark-ups, mark-downs, spreads paid to market
makers, or brokerage termination or account surrender fees associated with our programs. A
client may, however, incur certain separate charges imposed by their separate relationship
with a Partner or the broker or custodian, such as: wire transfer and electronic fund fees,
retirement plan custodial fees, or account termination fees, in addition to certain taxes on non-
retirement brokerage accounts, which are described in the fee schedule that is provided to the
client prior to account inception.
SERVICES PURCHASED SEPARATELY
The total costs associated with our Wrap Fee Program may be more or less than separately
purchasing brokerage and advisory services by our clients. The factors that bear upon the
relative costs of our Wrap Fee Program includes the number and timing of transactions,
referral fees (if any), portfolio management and custody fees, regulatory, compliance, and
administrative charges, research costs, and promotional materials, among others. These and
other factors may affect the cost of obtaining these services separately from another provider.
Clients should always consider other programs offered by other firms, as well as whether
paying separately for investment advice, brokerage, and other services is more appropriate for
their personal situation.