Overview
Introduction
Ocho Investment Advisors, LLC is a digital financial services company offering advisory services limited to
Solo 401(k), IRA and individual taxable account clients. The Firm is a Delaware limited liability company
formed in September 2022, wholly owned by The Vibes Company Inc. (Vibes).
Services
The Firm offers non-discretionary and discretionary limited advisory services to Solo 401(k), IRA and
individual customers through our web or mobile platform.
Ocho Advisory
The Firm offers non-discretionary investment advisory services (Flexible Accounts) through our
web or mobile platform by assessing your risk tolerance, recommending certain ETFs based on
that assessment. Because we have no discretionary authority over your account(s), you make
the ultimate decision regarding the purchase or sale of investments and we will not monitor
your account.
The accuracy of your investor profile will affect the results of our recommendations. When your
profile requires updates or corrections, you may make changes by accessing your settings page
in the app. Other than providing these recommendations, we do not tailor our services to your
individual financial circumstances.
The Firm also offers discretionary investment advisory services (Automated Accounts). We will
construct a diversified portfolio comprised of ETFs based on your risk profile. Automated
Accounts are rebalanced automatically and daily for cash balance, allocation drift and changes to
the portfolio holdings. Portfolio holdings are reviewed by our investment committee at least
quarterly.
The securities available are a limited universe of Exchange Traded Funds (“ETFs”) and equities
which are subject to change, as determined by the clearing firm DriveWealth. All users have
access to the same universe of securities.
Our advisory platform is available through our parent company, Vibes. Any information provided
by Vibes is for informational and general educational purposes only and is not investment
advice. Any graphs, charts and other visual aids that are provided are for informational purposes
only, not to be used to make investment decisions. Certain hypothetical scenarios that are
described in The Vibes Company, Inc. app or marketing materials are for illustrative purposes
only and the securities described are not actual securities held by client accounts. Inclusion of
such scenarios is not intended as a recommendation to purchase or sell any security and
performance of these scenarios does not indicate actual results.
Broker Dealer Election
For the
Ocho Advisory program, we have established a relationship with an independent custodian,
DriveWealth, LLC, an SEC registered broker-dealer and FINRA member (the “Broker” or “Custodian”). You
must open a brokerage account with the Broker who maintains custody of your assets. The Broker also
provides execution, clearing, and settlement services for your account. All account opening
functionalities, including identity verification and approval, are handled digitally by Broker. You will be
required to complete all applicable Broker forms and agreements, including a limited power of attorney,
if required, which authorizes the Broker to deduct our fees from your accounts pursuant to your
agreements with us. The Broker reserves the right to reject any account application for any reason
whatsoever.
The Broker provides all brokerage services to you, including executing securities purchase and sell orders
you enter through our web or mobile platform or pursuant to your request. The Broker may add or
remove any security from the Approved Securities List. If a security is removed from the Approved
Securities List, the Broker will limit transactions in that particular security to the liquidation of positions
only.
You pay all brokerage and transaction costs for the securities you purchase with the Broker.
Program Limitations
We do not provide comprehensive financial planning services and the investment advisory services
provided through Ocho Investment Advisors are not a complete investment program. We are not aware
of your aggregate investable and invested assets. We encourage you to consider additional asset classes,
strategies and investments to supplement your overall investment plan. You should not use Ocho
Investment Advisors as the sole component of your investment program.
Automated accounts are not tax sensitive; that is, when partial holdings of securities are sold, they are
sold on a first-in-first-out (FIFO) basis, not by highest cost, which could result in capital gains.
Ocho is an internet-based advisor; that is, we provide its investment advice exclusively through an online
algorithmic-based program that clients interact with directly.
The Ocho Advisory program only offers exchange traded fund (ETF) and equity securities. You may sell
your securities or transfer your securities to another account at any time. Please note, however, that
fractional shares are not transferable. Fractional shares must be liquidated prior to transferring your
account. You may also withdraw available cash out of your brokerage account at any time.