Description of Firm Revolut Wealth Inc. is a registered investment adviser primarily based in New York, NY. We are organized as a corporation under the laws of the state of Delaware. We are owned by Revolut Holdings US Inc.
We are indirectly owned by Revolut Group Holdings Ltd. and Nikolay Storonsky.
As used in this brochure, the words "we," "our," and "us" refer to Revolut Wealth Inc. and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person in this brochure. Our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
We offer portfolio management services through a wrap-fee program ("Program") via mobile based application as described in this wrap fee program brochure to prospective and existing clients. We are the sponsor and investment adviser for the Program. A wrap-fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay our firm a single fee, which includes money management fees, certain transaction costs, and custodial and administrative costs. You are not charged separate fees for the respective components of the total services. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program.
Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid.
Client Investment Process We offer discretionary portfolio management services via a mobile based application. Our investment advice is tailored to meet our clients' needs and investment objectives as an internet advisor.
If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions, and over the commission rates to be paid. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms.
During the account opening process, we will gather various pieces of information from you about your risk tolerance, investment objectives, and overall financial situation. The Firm's internal algorithms will use this information to propose one of our model portfolios that is in accordance with your risk tolerance and investment objectives and is diversified among investment styles and/or asset classes. Securities within each model are reviewed at least quarterly by an internal investment committee to ensure that they meet the parameters of the style and most effectively achieve the goals of the portfolios. The Firm's internal algorithms then review Client accounts on an ongoing basis to ensure consistency between the Client's risk profile, investment strategy and performance objectives. Accounts are rebalanced on a monthly basis to ensure they stay within the model's parameters. Asset allocation, cash management, market prospects and individual issue prospects are considered. More 4 frequent reviews will occur if triggered by economic, market, or political conditions. Clients may view their account at any time in the Revolut App. The Client's custodian provides quarterly statements to Clients showing the assets held in each Client account, the market value, and each account's performance for the quarter.
To utilize the services of Revolut Wealth, you are obligated to have a card account through our affiliate, Revolut Technologies, Inc. and our partner bank, Metropolitan Commercial Bank, and you must agree to terms and conditions from our qualified Custodian and clearing broker, DriveWealth LLC. You may be able to obtain comparable services and/or lower fees through other firms. In some cases, fees will be incurred when using other services provided through the prepaid debit card account. Clients can find additional details regarding their pre-paid account fees in the "Cardholder Agreement" with our partner bank and their Custodian and Execution details in their "DriveWealth Custodial Agreement" both of which have separate agreements with their own rights and obligations directly to you.
Assets for program accounts are held at Drivewealth as custodian. Drivewealth also acts as executing broker/dealer for transactions placed in Program accounts and provides other administrative services as described throughout this Brochure. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by Drivewealth and the advisory fees charged by investment advisers.
Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you, and we are expressly authorized to rely on the information you provide in your questionnaire regarding your investment objectives, risk tolerance, and time horizon (collectively, "investment parameters"). While we will reach out to you at least annually to remind you to keep your questionnaire information current, it is your responsibility to promptly update your information if there are ever any changes in your financial situation or investment parameters for the purpose of reviewing, evaluating, and/or revising our previously recommended model.
The Program Fee We charge an annual "wrap-fee" of 0.25% (effectively 0.00068% per day) for participation in the Program depending upon the market value of your assets under our management. Our fee is calculated based on the daily value of the portfolio and collected monthly in arrears. A minimum fee of 25 cents per month will be charged in cases where the percentage-based wrap fee is less than the minimum fee.
Affiliates may charge fees for non-related products and services.
You are not charged separate fees for the different components of the

services provided by the Program. Our firm pays all trade expenses of trades placed on your behalf. Our Program fee includes the fee we pay to any portfolio manager for their management of your account and Drivewealth's transaction or execution costs. Assets in each of your account(s) are included in the fee assessment unless specifically identified in writing for exclusion. If the portfolio management agreement is executed at any time other than the first day of a calendar month, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the month for which you are a client. Our advisory fee is not negotiable.
5 As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above.
Withdrawal of Assets You may withdraw account assets on notice to our firm, and subject to the usual and customary securities settlement procedures. However, we design our portfolios as long-term investments and asset withdrawals may impair the achievement of your specific investment objectives.
Payment of Fees We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. We will send you an invoice showing the amount of the fee. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy.
We encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian, call our main office number located on the cover page of this brochure.
Termination of Advisory Relationship You may terminate the wrap fee program agreement upon written notice to our firm. You will incur a pro-rata charge for services rendered prior to the termination of the wrap fee program agreement, which means you will incur advisory fees only in proportion to the number of days in the month for which you are a client.
Upon termination of accounts held at Drivewealth, they will deliver securities and funds held in the account per your instructions unless you request that the account be liquidated. After the wrap fee program agreement has been terminated, transactions are processed at the prevailing brokerage rates/fees. You become responsible for monitoring your own assets and our firm has no further obligation to act upon or to provide advice with respect to those assets.
Wrap Fee Program Disclosures
•The benefits under a wrap fee program depend, in part, upon the size of the Account, the management fee charged, and the number of transactions likely to be generated in the Account. For example, a wrap fee program may not be suitable for Accounts with little trading activity. In order to evaluate whether a wrap fee program is suitable for you, you should compare the Program Fee and any other costs of the Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and other execution costs, and custodial services comparable to those provided under the Program.

•In considering the investment programs described in this brochure, you should be aware that participating in a wrap fee program may cost more or less than the cost of purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers.
•Similar advisory services may be available from other registered investment advisers for lower fees. 6 Additional Fees And Expenses The Program Fee includes the costs of brokerage commissions for transactions executed through the Qualified Custodian (or a broker-dealer designated by the Qualified Custodian), and charges relating to the settlement, clearance, or custody of securities in the Account. The Program Fee does not include mark-ups and mark-downs, dealer spreads or other costs associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities exchange fees, charges for transactions not executed through the Qualified Custodian, costs associated with exchanging currencies, wire transfer fees, or other fees required by law or imposed by third parties. The Account will be responsible for these additional fees and expenses.
The wrap program fees that you pay to our firm for portfolio management services are separate and distinct from the fees and expenses charged by exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. To fully understand the total cost you will incur, you should review all the fees charged by exchange traded funds, our firm, and others.
Brokerage Practices If you participate in the Program, you will be required to establish an account with Drivewealth, member FINRA/SIPC, an unaffiliated SEC-registered broker-dealer. If you do not direct our firm to execute transactions through Drivewealth, we reserve the right to not accept your account. Not all advisers require their clients to direct brokerage. Since you are required to use Drivewealth, we may be unable to achieve the most favorable execution of your transactions. We believe that Drivewealth provides quality execution services based on several factors, including, but not limited to, the ability to provide professional services, reputation, experience and financial stability. Our selection of custodian is based on many factors, including the level of services provided, the custodian's financial stability, and the cost of services provided by the custodian to our clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees or expenses.
Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements.
Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research.