Valur Robo Advisors LLC was founded on January 7th, 2022. Additional information about Valur Robo Advisors is available on the SEC’s website atwww.adviserinfo.sec.gov. You can search this site by Valur Robo Advisors’s CRD number, 318675. The SEC’s website also provides information about any persons affiliated with Valur Robo Advisors who are registered, or are required to be registered, as investment adviser representatives of Valur Robo Advisors.
Valur Robo Advisors is a registered investment adviser (“RIA”) which offers a wrap fee program to its advisory clients (each a “Client,” and collectively, “Clients”) through an online web-based platform. The online platform is designed to collect various pieces of information from Client’s, provide the recommendations on asset allocation (with ETFs and public equities) Valur Robo Advisors is a privately held company headquartered in Dover, Delaware.
Information about Valur Robo Advisors’s organizational and ownership structure is provided on Part 1 of Valur Robo Advisors’s Form ADV, which is available online at http://www.adviserinfo.sec.gov.
Wrap Fee Program Valur Robo Advisors provides web-based discretionary investment advisory services through a wrap fee program that bundles or “wraps” services together and charges a single fee based on the value of assets under management (the “Program”). The Program is provided via Valur Robo Advisors’s proprietary platform, which is located at www.valurfinance.com (the “Website”).
The advisory services are delivered solely through the Website with software-based models or applications. Valur Robo Advisors does not provide investment advice in person or over the phone or in any manner other than through the Website. Additional information about Valur Robo Advisors’s products and services is provided in Valur Robo Advisors’s Form ADV Part 1 available athttp://www.adviserinfo.sec.gov.Valur Robo Advisors encourages visiting the Website for additional information.
Clients utilize the Website to access investment advice from Valur Robo Advisors, which seeks to help them meet their financial goals, within their respective investment risk and financial parameters. The investments offered through the Program include exchange traded funds (“ETFs”) and publicly traded equities.
As part of the investment advisory services, Valur Robo Advisors, exclusively through the Website, will: review a client’s present financial situation; curate and recommend investment options based on a client’s risk profile and financial objectives; suggest appropriate diversification and portfolio construction actions; monitor and track assets under management; provide annual portfolio reviews; and provide account statements and trade confirmations.
Client’s have access to the Program at anytime, by simply logging into the Website they are able to see their: ● Account information ● Responses to the Suitability Questionnaire ADV Part 2AMarch 2024Page 4 of 21 ● Target portfolio allocation ● Request functions for updating or changing responses to the Suitability Questionnaire or preferred portfolio allocation Each Client is expected to complete a straightforward questionnaire, designed to evaluate a Client’s investment objectives, risk tolerance and investment interest, the “Suitability Questionnaire.” The questionnaire direct contains questions, including: ● What is your current annual income? ● What is your total net worth? ● What are you most focused on when investing? ● What would you do if your portfolio lost 10% of its value in a month? ● Are you interested in any of the following assets? Select all that apply.
The questionnaire also provides access to educational questions/answers, such as: ● Why are my investing objectives important? ● What is portfolio risk? ● Why was this portfolio selected for me? Based solely on the information provided by the Clients via the interactive questionnaire, the Program analyzes the information and provides the Clients with access to a curated selection of suitable investment options. Valur Robo Advisors provides investment advice only with respect to limited types of investments, ETFs and publicly traded equities. Clients should understand the investment portfolios and software rely upon the information provided by the Clients, and Valur Robo Advisors does not capture any additional information not covered in the questionnaire in making its risk assessment and providing its investment advice. Clients, within the Program, are able to place restrictions on various types of securities as well as indicate preferred placements into specific ETFs or publicly traded equities. Ultimately, the selection of suitable investment options are only a suggestion and Clients have the right and responsibility to consider variations to suggested investments.
Clients are obligated to update their information through the Website promptly if there are changes to their financial situation, goals, objectives, personal circumstances, time horizon or if other relevant information changes or becomes available.
The investments in each Client’s account are held in a separate account in the name of the Client at an independent custodian, and not with Valur Robo Advisors. All accounts managed through the Website are required to use Charles Schwab & Co. as the independent custodian. Valur Robo Advisors has the authority to manage Client accounts on a discretionary basis, but does not trade in any Client’s account except for the following reasons: ● To adjust a portfolio’s allocation, as requested by a customer based on information shared by Valur or on an updated investment questionnaire; or ● To sell necessary assets in order to meet fee requirements.
The equities and ETF shares purchased or sold on behalf of a Client and/or held in Client accounts may be either whole shares or fractional shares.Valur Robo Advisors enables dollar-based investing, whereby Valur Robo Advisors can buy a fixed dollar amount rather than whole shares on behalf of its Clients. Valur Robo Advisors, through Charles Schwab & Co.
aggregates all dollar-based purchases and places whole share orders for executions. Thereafter, ADV Part 2AMarch 2024Page 5 of 21 Valur Robo Advisors allocates the fractional shares to the individual Client accounts. Fractional shares, however, are typically not transferable 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, Valur Robo Advisors

may convert such fractional shares to cash.
Clients will receive Valur Robo Advisors’s Advisory Agreement, which further details the services Clients will receive, fees charged to Clients, and the conditions of the Valur Robo Advisors-Client relationship.
Fees and Compensation The Program charges a “wrap” fee which allows Clients to pay a single fee for investment advisory services (the “Fee”). The Fee is not based upon transactions in a Client account, but rather is a bundled fee which includes the costs for internet advisory services, execution, clearance, custody and account reporting.
The Fee will, generally, consist of a quarterly cost of 2.5 basis points of the Client’s assets under management. On an annual basis, this percentage represents a fee of .10% of a Client’s assets under management (i.e., 0.025% per quarter x 4 quarters = .10% per year). The Fee is charged quarterly, in advance, based on the value of the Client’s account on the first business day of the quarter. Investment advisory fees are prorated for partial quarters. Fees are negotiable. Any proposed changes to fees will be properly disclosed beforehand to Client’s and require their informed consent before new fees will come into effect.
Valur Robo Advisors will deduct the quarterly advisory Fee from the Client’s account. This Fee will be paid from funds in the account or from funds resulting from the sale of investments from the Client’s account. Valur Robo Advisors will send an invoice to Charles Schwab & Co.
indicating the amount of the Fee to be deducted from the Client’s account at the beginning of the quarter. The amount due is set forth in the Advisory Agreement. In addition, Valur Robo Advisors will provide each Client a report itemizing the Fee, including the formula used to calculate the Fee, the value of the assets under management on which the Fee is based, and the time period covered by the Fee. Clients will be provided with a statement from Charles Schwab & Co. reflecting deduction of the applicable Fee on a quarterly basis. Clients are encouraged to compare the account statements from Charles Schwab & Co. with the report received from Valur Robo Advisors. Clients provide Valur Robo Advisors with written authorization to be paid directly from their accounts held by Charles Schwab & Co. in the Advisory Agreement and in separate account forms provided by Charles Schwab & Co., as applicable.
Each time a Client uses Valur Robo Advisors’s internet advisory services, they reaffirm their agreement that Valur Robo Advisors may charge the account, as applicable. If Valur Robo Advisors cannot take the Fee from the Client’s custodial account, it may charge the Client’s credit card. In the event Valur Robo Advisors cannot charge the applicable accounts, it reserves the right to terminate a Client’s access to its advisory services. Termination of accounts will be undertaken at Valur Robo Advisors’s sole discretion. Each Client may also terminate its account at any time. Upon termination of a Client’s account, Valur Robo Advisors’s access to a Client’s ADV Part 2AMarch 2024Page 6 of 21 account will cease within a reasonable timeframe and the client will solely be responsible for managing the assets with the respective custodian. Once the account termination process is initiated, Valur Robo Advisors will no longer receive any additional fees from the Client with respect to the Client’s account.
Valur Robo Advisors reserves the right to waive the Fee or any part thereof for any period for any Client in Valur Robo Advisors’s sole discretion. To this end, Valur Robo Advisors may, from time to time, elect to launch programs or initiatives whereby the Fee may be waived, in whole or in part, for certain categories of Clients. Any such program or initiative (i) is entirely discretionary to Valur Robo Advisors, and may be expanded, narrowed, suspended, canceled or modified at any time by Valur Robo Advisors, and (ii) will be subject to any rules, guidelines and/or terms and conditions created by Valur Robo Advisors in connection therewith (which rules, guidelines and/or terms may be included in website landing pages on the Website and/or elsewhere). To the extent any such program or initiative is canceled or terminated, Clients will once again be charged the then-current Fee on a going-forward basis. Valur Robo Advisors shall have sole discretion in determining whether or not any existing Client or potential Client meets the requirements to participate in and/or benefit from any such program or initiative, and Valur Robo Advisors shall not be liable to the Client or any other party in connection with any such decision and/or in connection with the administration of any such program or initiative generally.
Valur Robo Advisors believes its wrap fee is reasonable considering the quality and scope of the services it provides and the fees charged by other investment advisers offering similar services/programs. However, by participating in a wrap fee program, Clients may end up paying more or less than they would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to the Client by the executing broker. In that scenario, Clients would be responsible for any other fees charged by other parties, including the custodian, Charles Schwab & Co.. Clients could also invest in ETFs, and other securities directly without Valur Robo Advisors’s services. In that case, Clients would not receive the web-based services provided by Valur Robo Advisors, which are designed, among other things, to assist in determining which investments are appropriate for the portfolio and the Client’s account.
Other Account Fees The Program includes all trade charges applicable to an account.However, Valur Robo Advisors’s fees do not include other related costs and expenses. A Client may incur certain charges imposed by custodians and other third parties.These include transfer fees, administrative fees and other fees and taxes on brokerage accounts and securities transactions.
The issuer of some of the securities or products purchased for Clients, such as ETFs, may charge product fees that affect Clients. Valur Robo Advisors does not charge these fees to Clients and does not benefit directly or indirectly from any such fees. An ETF typically includes embedded expenses that may reduce the fund’s net asset value, and therefore directly affect the fund’s performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. These fees are in addition to the Fee Clients pay to Valur Robo Advisors. Clients should review all fees charged to fully understand the total amount of fees they will pay.
Valur Robo Advisors does not receive any compensation in connection with the sale of securities or other investment products apart from the advisory fees described above.
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