STRATxAI Technologies Ltd (“STRATxAI” or “Advisor”) was formed in March 2023 and is a registered investment advisor with the SEC since August 2023..
STRATxAI is owned by Life Unlocked Ltd, which is principally owned by Paul Clifford, CEO and Conor Naylor, CFO.
Advisory Services STRATxAI’s principal service is providing fee-based limited discretionary investment advisory services to clients through an interactive website and API which can be found at www.stratxai.com. The Advisor’s advice is powered by the insights it makes when clients input various data points that help tailor both “off the shelf” model portfolios provided on the STRATxAI website, or more bespoke data-driven strategies based on different performance metrics and asset attributes.
Such data points, which are largely driven by the client, allow the Advisor to provide investment advice tailored to each specific client’s concerns (which may include investment horizon, investment risk preference, fundamental and technical indicators, and sector weighting, for example).
Currently, the Advisor’s website is powered by its own quantitative strategies together with inputs from each client to help tailor model portfolios (as defined below) and other bespoke strategies at the client’s direction. A myriad of components, including company fundamental and technical analysis, as well as traditional news, alternative data, macro events, human behavior, sentiment, social attitudes and data technology goes into the Advisor’s investment decision making. STRATxAI has developed a suite of software tools that effectively corroborate and calibrate the plethora of publicly available data that impacts companies, brands, and sectors across the globe.
The Advisor selects equity, commodity, inflation and fixed-income exchange traded funds (“ETFs”) as well as equity securities of publicly-traded companies to build model portfolios, which on the STRATxAI website are called Strategies. The Strategies act as model portfolios.
Clients may choose to manually modify the model portfolio in a very slight way – such as changing the rebalance frequency or portfolio weightings other than the one recommended or currently in effect. While STRATxAI recommends a model portfolio, it also gives the client the freedom to manually choose a slightly different model portfolio and disregard the pre-set advice of STRATxAI. Based on a client’s inputs, STRATxAI can recommend a volatility threshold for the client’s portfolio. Clients are also given the ability to stray slightly from the advice of the STRATxAI algorithm and manually

increase or decrease the volatility of their portfolio, this can be done by using the STRATxAI no-code platform. Clients are able to back-test their model portfolios in order to compare them to a benchmark or another model portfolio, and to see how a particular model portfolio hypothetically performs under real-world conditions. The client is able to change and edit these model portfolios at any time.
The Advisor’s algorithm is designed to keep the holdings within each client’s account in exact alignment with the Strategy holdings outputted from the algorithm, even when the market STRATxAIPage 4 prices of the securities in the client’s account fluctuates. Clients authorize the Advisor to automatically rebalance their Investment Account holdings as per the Strategy rebalance period, maintain a minimum cash balance and re-invest dividends. If a client chooses, they are also given the ability to manually select the frequency of rebalancing manually, in which case they are given the option to rebalance either monthly, quarterly, semi-annually or annually. When a client adds money to their account, the Advisor can purchase a combination of ETFs and other securities, as appropriate, to align the client’s account along with the target Strategy allocation for the selected model portfolios. Clients may liquidate securities in their account through the website and initiate cash withdrawals through the custodian. The rebalancing strategy is based on an agreed upon rebalancing period that the client agrees to for the model portfolio. This rebalancing period may initiate liquidations of certain securities and purchases of other securities to keep the clients portfolio in exact alignment with the model portfolio of their chosen Strategy.
The number of times rebalancing is performed is not limited and is driven by the Advisor’s decisions on the composition and holdings in the client’s selected model portfolio. This is transparent and outlined in the model portfolio documentation, which the client agrees to and is aware of. As a result, there is a possibility that the Advisor may sell or buy securities without taking into account individual tax consequences or market circumstances. The Advisor will not engage in tax loss harvesting trades in order to optimize the tax consequences of holding, or disposing of, certain holdings.
The Advisor only provides investment advice through the website and only with respect to these types of investments.
STRATxAI does not provide portfolio management services to wrap fee programs.
As of the approval date of the firm, STRATxAI had no clients and therefore no client assets under management.