A. General Description of the Company Savvy Labs is a corporation organized in the State of Delaware, with its principal office located at 4 World Trade Center, 29th Floor, New York, NY 10007. Savvy Labs was formed in August 2021 by David Mike and Justin Palma, who are its principal owners. Savvy Labs currently has no subsidiaries.
All employees at Savvy Labs are currently considered to be supervised persons, and they cover material functions such as investment advisory services, business operations, and compliance/risk functions.
B. Types of Advisory Services This Brochure is meant to help you understand the scope and nature of the advisory services offered by Savvy Labs, whether the advisory services offered by Savvy Labs are right for you, and the potential conflicts of interest associated with Savvy Labs’ services. You should review it carefully.
Savvy Labs uses proprietary technology (a website and marketplace known as the “Platform”) and experienced investment professionals to provide its advisory services to institutional investors, including but not limited to corporations, partnerships, trusts, family offices, and foundations (“Institutional Users”) and registered investment advisers (“Adviser Users,” and together with the Institutional Users, “Users”). Through the Platform’s offerings, Users are able to directly own securities that allow for customization of risks, exposures, and strategies provided by a variety of different institutional asset managers or index providers (hereinafter referred to as “Creators”). This allows Users to better meet their specific investment objectives in an efficient and cost effective way that may not be possible in traditional pooled investment vehicles and mass-marketed fund products.
Savvy Labs reduces costs and increases transparency for Users through its portfolio management, compliance, operational, and reporting services. Instead of Users opening multiple accounts directly with different Creators, incurring the expense and time to establish and maintain these accounts, Savvy Labs’ Users are able to get the exact investment exposure they want across various asset classes, strategies, and Creators, all with just one account, requiring one onboarding process through Savvy Labs and its proprietary Platform.
Upon establishing an account on the Platform, Users are able to enter information regarding their investment objectives and goals through various filters contained within the search functionality on the Platform. Savvy Labs’ proprietary technology takes this information into account and provides Users with access to a curated set of recommended “SAVVY Blueprints” that are aligned with the User’s investment objectives and goals. Users may view and consider additional SAVVY Blueprints beyond those recommended to them and may direct Savvy Labs to implement and/or customize those SAVVY Blueprints if desired.
Users are also able to receive investment advice directly through conversations with Savvy Labs’ investment professionals who are able to recommend SAVVY Blueprints and customization strategies.
Designed by a Creator, a SAVVY Blueprint is an investment strategy, which includes certain risk or exposure characteristics, based on a market thesis, along with a corresponding design of implementation. SAVVY Blueprints detail the securities holdings and their respective weightings for purchase needed to achieve the investment objective of the SAVVY Blueprint. Certain SAVVY Blueprints include rules-based methodologies for re-weighting of the composition of securities.
Unlike generic, broad, market-based portfolios or models, specific factors or market conditions may drive Blueprint creations, including but not limited to the shape of the yield curves, fundamental data, economic releases, and other market-based analysis. A SAVVY Blueprint may also contain rules detailing the parameters needed for the thesis to be considered complete or no longer viable or feasible in the market. Savvy Labs investment professionals can help to advise Users with respect to which of these parameters meet the User’s investment objectives.
In general, SAVVY Blueprints are dynamic and evolving and are not based on static or generic, broad, market exposure or allocations. Savvy Labs advises Users through its enhanced search functionality and technology tools on its Platform as well as through direct conversations with Users to help Users select and customize a SAVVY Blueprint that best meets the User’s investment objectives. Additionally, in order to ensure the recommendations continue to remain suitable, Users will be asked to reaffirm or update investment objectives information regularly or to confirm that there have been no changes in these regards.
Savvy Labs implements a User-selected SAVVY Blueprint, whether or not customized, by placing orders with designated third-party broker-dealers to implement allocations as outlined by the User-selected or -customized SAVVY Blueprint. The executed portfolio of positions, known as a “SAVVY,” is then held in a separate, segregated account, or unified investment account (“UIA”) owned solely by the User. Savvy Labs, as an adviser to the User, uses its proprietary software to continuously manage each User’s SAVVYs and UIA.
Savvy Labs uses its discretion to manage the intended SAVVY Blueprint’s allocation percentages across assets, taking into account any customization(s) selected by the User, and directs the third-party broker-dealer to buy and sell securities in order to keep the SAVVY in line with its User-selected SAVVY Blueprint.
Each User will have a unique set of securities in its UIA based on the SAVVY the User owns. Because SAVVY Blueprints have an initial implementation of weighting and securities, a User implementing at a given time on a given day will have different weightings and securities than a User implementing at another time, even if on the same day, as the weightings are changing and required reallocations occur for each User independently of any other User due to the natural course of market movements. Unless two Users instruct Savvy Labs to implement the same SAVVY Blueprint at the exact same time, in the exact same amount and without customization, no two SAVVYs will contain an identical set of underlying securities and weightings, and no two SAVVYs will achieve the same performance.
Creator Vetting Advisory Services Savvy Labs performs due diligence on each prospective Creator by reviewing various aspects of the Creator’s business, including, but not limited to, the Creator’s licensing, credentials, and market standing and assessing the Creator’s area of expertise, historical risk/return characteristics, assets under management or advisement, years of business, reputation in the industry, and, where applicable, regulatory history. In addition, Savvy Labs will assess a Creator’s business operations for operational risk and may screen for negative news regarding the Creator.
Once Savvy Labs has vetted a Creator and found the Creator to be an acceptable participant on the Platform, the Creator will be able to propose to Savvy Labs for publication on the Platform, SAVVY Blueprints and certain supplemental content, including but not limited to commentaries on the Creator’s SAVVY Blueprints and their underlying strategy, general commentary on markets, the economy, and historical performance and biographical information about the relevant personnel at the Creator (“Creator Content”).
A Creator will provide SAVVY Blueprints and Creator Content pursuant to a contractual arrangement between Savvy Labs and the Creator. Creators and their individual employees will not, based on the aforementioned contracts, become employees of Savvy Labs.
Because Savvy Labs, rather than the Creators, will act as an adviser to the Users with respect to content made available to the Users through the Platform, and because Users will not establish an advisory or contractual relationship with Creators solely by virtue of Users’ usage of SAVVY Blueprints and consumption of Creator Content through the Platform, SAVVY Blueprints and Creator Content will contain prominent disclosures explaining that: (i) the creation and publication of a SAVVY Blueprint or piece of Creator Content does not establish an investment adviser relationship between a User and the Creator that devised the SAVVY Blueprint or Creator Content and (ii) as published in the first instance, the SAVVY Blueprint or Creator Content does not

constitute investment advice and has not been tailored by a Creator to the needs or preferences of any User. Each SAVVY Blueprint will also contain a disclosure explaining that the Creator makes no statement, representation or recommendation to any User regarding the likely success of any SAVVY Blueprint or the suitability of such SAVVY Blueprint for any particular User.
Savvy Labs will continue to monitor Creators throughout the relationship to ensure they remain suitable Platform participants.
SAVVY Blueprint Advisory Services Prior to publication of a particular SAVVY Blueprint to the Platform, Savvy Labs will perform due diligence on the SAVVY Blueprint to confirm that the SAVVY Blueprint is “fit for purpose” and seems reasonably likely to meet the investment objectives set forth by the Creator. During the diligence process, Savvy Labs will assess key statistical metrics and data points and submit each SAVVY Blueprint to the Savvy Labs Investment Committee for final approval. If approved, Savvy Labs will include the SAVVY Blueprint on the Platform.
Thereafter, Savvy Labs may recommend the SAVVY Blueprint to certain Users based on Savvy Labs’ interactions with and information received from Users about the type of risk, exposures, or strategies that the Users wish to implement to meet their investment objectives. Savvy Labs will also conduct due diligence prior to posting additional Creator Content on the Platform and will not publish the Creator Content if it is deemed inaccurate or misleading. All published SAVVY Blueprints will continue to be reviewed on an ongoing basis to confirm that they continue to stay “fit for purpose” and remain viable investment options in light of changing market conditions. In the event a SAVVY Blueprint is no longer a viable means of pursuing an investment thesis, Savvy Labs will remove the SAVVY Blueprint from the Platform and will advise existing investors with SAVVYs that track the removed SAVVY Blueprint so they may decide whether they would like to reallocate their investments.
A User may choose either to direct Savvy Labs to implement a SAVVY Blueprint as it has been designed or to implement a customized version of a SAVVY Blueprint. If a User elects to customize a SAVVY Blueprint, it may increase, decrease, or eliminate exposure to individual securities, sectors or risk factors. Once that choice has been made, Savvy Labs will implement the SAVVY Blueprint on behalf of the User. Implementation of the SAVVY Blueprint is done through sending orders to third-party broker-dealers through Savvy Labs’ automated order routing system. All broker-dealers used will have had to go through Savvy Labs’ third-party due diligence process and have been approved by the respective Savvy Labs internal risk committee.
SAVVY Investment Management Advisory Services Once a SAVVY Blueprint is implemented by Savvy Labs, that investment portfolio becomes known as a (“SAVVY”). All underlying securities in that SAVVY are held directly by the User, in a separate and segregated UIA. A User may hold one or multiple SAVVYs in their UIA.
Savvy Labs provides continuous and regular supervisory and management services over its Users’ SAVVYs and the securities in the Users’ UIAs. In connection with these services, Savvy Labs uses its proprietary technology to assess whether the proportional allocation of the securities within a User’s UIA continues to be in line with the allocations set forth in a User’s chosen SAVVY Blueprint. In the event it is not, Savvy Labs will have the discretion to manage a User’s portfolio by directing the purchase and sale of securities to bring a SAVVY in line with the investment allocation strategy established by a SAVVY Blueprint and, ultimately, a User’s investment objectives.
Although Savvy Labs provides continuous supervisory and management services over all current portfolios in User’s accounts, Users who invest in the same SAVVY Blueprint are not expected to have the same returns or results due to a variety of reasons including the timing of initial investment and other customization considerations. As the market moves, the weightings of each of the underlying securities for the Savvy Blueprint will shift, and, therefore, the subsequent managing activity conducted by Savvy Labs will also vary between different Users’ accounts.
Summary of Savvy Labs Advisory Services: ● Vetting of Creators: Savvy Labs conducts a due diligence review of each potential Creator, including to ensure that it has the proper licensing, credentials, and market standing and is well suited to publish materials on the Platform. For example, Savvy Labs may look at a potential Creator’s assets under management and performance history, among other data points, and may screen for negative news regarding the potential Creator in an effort to ensure that the Creators who are permitted to craft and publish SAVVY Blueprints and Creator Content on the Platform are appropriate and sound. Only potential Creators who have been reviewed and approved by Savvy Labs will be allowed to publish to the Platform, and unsatisfactory potential Creators will not be granted access. Onboarded Creators are also continuously monitored to ensure that they continue to stay appropriate for the Platform.
● Due Diligence of SAVVY Blueprints and Creator Content: Upon receiving a proposed SAVVY Blueprint or Creator Content from an approved Creator, Savvy Labs will review and vet the SAVVY Blueprint and Creator Content using Savvy Labs’ due diligence and approval process. During this process, Savvy Labs will review a range of information, with considerations including but not limited to whether the proposed security allocations of the Blueprints are reflective and consistent to the Blueprint strategy and Creator Content, whether there are securities proposed which Savvy Labs has restricted for trading for regulatory purposes, etc.
Savvy Labs will endeavor to make certain that each proposed SAVVY Blueprint is “fit for purpose” and reasonable in structure for recommendation to Platform Users.
Savvy Labs will submit each SAVVY Blueprint to the Savvy Labs Investment Committee for final approval.
● Individualized Recommendations to Users: Based on information received from a User, including through the use of investment objective-related filters and from conversations between Users and Savvy Labs’ investment professionals, Savvy Labs’ proprietary technology will provide individualized recommendations to Users.
These recommendations will be comprised of a curated list of SAVVY Blueprints that may fit the User’s investment goals and objectives. Savvy Labs investment professionals will also be available to provide recommendations with respect to SAVVY Blueprints that suit a User’s investment objectives and goals. A User will then be able to have further conversations with Savvy Labs directly to discuss strategies, recommendations, or customization of a SAVVY Blueprint. Once a SAVVY Blueprint has been selected and customized, if necessary, Savvy Labs will implement the SAVVY Blueprint by directing a broker-dealer to purchase securities in line with the User’s selected or customized SAVVY Blueprint. In order to ensure the recommendations continue to remain suitable, Users will be asked to update investment objectives information regularly or to confirm that there have been no changes in these regards.
● Ongoing portfolio management services: Savvy Labs’ proprietary technology allows for the continuous and efficient management and monitoring of each portfolio. When Savvy Labs identifies that a SAVVY has departed from allocation parameters established by a SAVVY Blueprint, Savvy Labs will effect purchases and sales of securities and assets as necessary for the implementation of a SAVVY Blueprint through the placement of buy or sell orders with approved third-party broker-dealers.
Additional Services Savvy Labs is in the process of formation and the information provided herein describes the advisory services that Savvy Labs expects to provide. Savvy Labs is in the process of developing potential additional business lines and will amend this Brochure with a description of such additional services as appropriate. Any material changes to the information contained herein will be provided in an updated Brochure, which will be filed within 120 days of Savvy Labs’ registration with the SEC.
Savvy Labs does not provide financial planning services or tax advice to Users.