A.Description of the Advisory Firm Ola Invierte, LLC (the “Firm” or “Ola Invierte”) is a Delaware limited liability company formed in November 2021. As described in more detail below, Ola Invierte provides advice regarding potential investment plans to investors (the “Investors”) through a mobile application platform.
Ola Invierte generates proposed investment allocations in stocks, bonds, and exchange-traded funds (“ETF”s) based on data inputted by Investors, which are designed with the goal of enhancing a particular Investor’s returns.
B.Types of Advisory Services Ola Invierte sponsors the website and iOS application “Ola”, which allows Investors to build and manage securities portfolios and investment plans. Ola and its associated services are available in Spanish and English. Ola allows Investors to trade stocks, bonds, ETFs, and other public securities on the app, and provides general securities and market information. Individualized investment advice is offered to Investors who enroll in Ola’s Premium Subscription Plan (“Ola Premium”).
Ola generates customized, goal-based investment portfolio recommendations for Ola Premium Investors for, among other things, investments in stocks, bonds, and ETFs. The recommendations are customized for the Investor based on an analysis of data inputted by the Investor, including (1) the amount of an Investor’s desired investment goal (e.g. annual retirement income); (2) the amount of capital currently available for this goal (e.g. $100,000); (3) the amount of time until the goal needs to be satisfied (e.g. 25 years); (4) the amount of the Investor’s annual savings contributions for goal (e.g. 25,000 / year); and (5) the Investor’s risk tolerance. Ola Invierte’s algorithm, based on analysis of historic pricing and risk data, takes these data points and generates a recommended portfolio, which is a proposed allocation of stocks, bonds, and ETFs, based on the information provided by the Investor. The recommended portfolio serves as a benchmark for the Investor. Investors have full discretion over the securities they choose to trade.
Investors will also have access

to investment related periodicals, newsletters, and seminars/workshops on the application to provide them with general financial market information and general education related to investing. Ola Invierte will not provide any investment advice or investment recommendations through these publications or workshops.
Ola Invierte will require Investors establish brokerage accounts with Alpaca Securities LLC, a registered broker-dealer, to maintain custody of Investor assets and to effect trades for their accounts. Ola Invierte is independently owned and operated and not affiliated with Alpaca Securities, LLC.
Because Ola Invierte provides investment advice solely through its apps, it is registering as an adviser with the SEC under Rule 203A-2 under the Investment Advisers Act of 1940, which allows such registration to advisers that (among other things) provide investment advice to their clients exclusively through an interactive website. Ola Invierte is treating the app as a form of website for these purposes. Ola Invierte will not interact with Investors in any other way.
The investment advice an Investor receives rely on the information the Investor provides to Ola Invierte. To the extent any of that information is incorrect, it could negatively affect the quality of an Investor’s advice they receive. Ola Invierte has no responsibility for any incorrect, false, or misleading information provided by an Investor or for any investment or financial decision an Investor makes based on that information. C.Client Tailored Services and Client Imposed Restrictions Ola Invierte provides tailored advisory services by using its algorithm to recommend investment portfolios based on information provided by the Investor, which are designed to help Investors achieve their investment goals.
Ola Invierte does not execute any trades or make any financial or investment decisions on the Investors’ behalf.
D.Wrap Fee Program Ola Invierte does not participate in wrap fee programs.
E.Amounts Under Management Ola Invierte does not currently have any assets under management.