A. Describe your advisory firm, including how long you have been in business. Identify
your principal owner(s).
Advisory Business
Coherence Finance Inc. (“Coherence” or the “Firm”) was formed in February of 2022 as a Delaware
corporation.
Principal Owners/Ownership Structure
Coherence Finance Inc.is principally owned by Andrew Gunderman, the Firm’s Chief Compliance
Officer; Sage Farrenholz; and, Kevin Xiang, each of whom own 33.3% of Coherence.
B. Describe the types of advisory services you offer. If you hold yourself out as
specializing in a particular type of advisory service, such as financial planning, quantitative
analysis, or market timing, explain the nature of that service in greater detail. If you provide
investment advice only with respect to limited types of investments, explain the type
of investment advice you offer, and disclose that your advice is limited to those types of
investments.
Coherence provides portfolio management services via an interactive web platform and mobile
application (“the Platform”). This entails the use of algorithm-based portfolio management advice,
rather than in-person investment advice. These automated investment solutions are based on
individual characteristics, such as age, risk tolerance, income, and current assets, among others.
Among other things, Coherence offers various model portfolios of cryptocurrency-related
investments to individuals (each a “Client,” and collectively, “Clients”) through the Platform. Each
model portfolio (each, a “Basket” or “Collection”) has its own investment program including,
without limitation, a description of its investment objectives, guidelines, and restrictions applicable
to each Basket (each, an “Investment Program”). The Platform contains detailed descriptions of the
Investment Program for each Collection which can be found at
www.coherence.finance, or on the
Coherence mobile app.
Clients access the Platform and provide information to Coherence about their total investable assets,
risk tolerance for their investment, and their investment preferences. Clients may choose one or more
Collections based on their investment preferences and adjust the allocations of the Collections.
Coherence will recommend specific Baskets by providing Clients with information about the Baskets
to inform their decision-making. Clients can also impose reasonable restrictions on the management
of the account by indicating any assets that should not be traded in their accounts. Each Basket is
comprised of a set of digital assets that are chosen and weighted to particular investment goals of a
Basket as a whole. Once Clients select their Basket allocations, Clients may reallocate their accounts,
at will, through the Platform’s account portal. Clients invest directly in the assets that make up each
Basket and some assets may be included in multiple Baskets.
Coherence Clients are empowered to invest through Baskets, to which individual Clients select
preferred allocation weights within their account. These Baskets feature thematic exposure to digital
assets, as described below. Through these Baskets, Coherence provides Clients with what it believes
is a relatively low-cost, low-friction, user-friendly entry point to digital asset investing.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual
needs of clients. Explain whether clients may impose restrictions on investing in certain
securities or types of securities.
Coherence does not tailor its Baskets to each Client. Coherence creates curated model portfolios in
which Clients can choose to invest based on their own discretion. Coherence may make advisory
recommendations as to Client allocations across the Baskets based on the information provided
through the Client’s account creation questionnaire. Clients may provide Coherence with reasonable
restrictions on their investing through the platform. Coherence prompts Clients to revisit information
and restrictions provided annually. As noted above, Clients may impose reasonable restrictions on the
digital assets Coherence includes in a Client’s account through the model portfolios by indicating any
assets the Client does not want purchased for his or her account. This occurs during the onboarding
process and through the Platform’s dashboard.
Since Coherence’s services rely heavily on the information provided to the Firm by the Client in the
account creation questionnaire, if the Client provides inaccurate or incomplete information at any
point, Coherence’s advice may not be correctly tailored to that Client’s desired Basket.
D. If you participate in wrap fee programs by providing portfolio management services,
(1) describe the differences, if any, between how you manage wrap fee accounts and how you
manage other accounts, and (2) explain that you receive a portion of the wrap fee for your
services.
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, and certain other administrative fees. Coherence does not
participate in wrap fee programs.
E. If you manage client assets, disclose the amount of client assets you manage
on a discretionary basis and the amount of client assets you manage on a non-discretionary
basis. Disclose the date “as of” which you calculated the amounts.
As of the filing date, Coherence does not provide investment advice to any Clients. Therefore, as of
the time of this filing, Coherence does not have any regulatory assets under management.