A. Advisory Business
GET MOVING Inc. (referred to herein as “Finvest,” “Firm,” “we,” and “our”) is an independent
investment advisory firm registered as an internet-only investment adviser with the U.S.
Securities and Exchange Commission (“SEC”). An internet-only investment adviser provides
investment advice to almost all of its clients exclusively through an interactive website. The
company was formed in 2022 as a Delaware Corporation. It is owned by Shivam Bharuka and
operated by Shivam Bharuka and Arnav Sahu.
Finvest operates through a mobile app through which users can buy/sell Treasury Bills through
an easy-to-use interface. Finvest allows individuals and businesses to be users on its app.
Through the app, Finvest makes recommendations to users on which securities to invest in,
based on a suitability and personalization questionnaire it offers in the onboarding process.
Finvest also primarily focuses on recommendations in Certificates of Deposit and/or Municipal
Bonds, as well as some other securities.
Clients will not be able to directly contact Finvest’s portfolio managers for investment advice.
Clients may contact Finvest for technical and customer service issues via email at
[email protected] but not for investment advice.
B. Services
Portfolio management services are provided on a non-discretionary basis. This means that, while
Finvest makes recommendations to the client, securities are purchased or sold at the sole
discretion of the Client.
Upon opening an account for clients, Finvest will ask a series of questions about their financial
situation and allow clients to impose restrictions on risk tolerance. Clients will be able to update
these on Finvest’s app. These questions include investment objectives, investment horizon,
downturn tolerance, and overall risk tolerance. Based on client suitability parameters, Finvest
will restrict certain assets from being bought or sold in Client accounts.
Finvest does not capture any additional information not covered in the questionnaire in making
its restrictions and providing its investment advice. The type of restriction a Client may impose
includes the degree of risk level.
Once invested in the portfolio, clients are able to change their investments at any time, provided
these investments fit within
the restrictions. Finvest does not provide brokerage services directly.
Finvest offers its services through the software of its sub‐adviser, Atomic Invest LLC (“Atomic”).
Finvest uses the software provided by Atomic to connect with the brokerage firm Pershing LLC
(“Pershing”) to direct and execute trades on behalf of clients. When creating an investment
account with Finvest, clients will also be making an account with the brokerage firm.
Clients will be able to select specific securities or restrict the purchase of specific securities.
The Firm’s mobile app allows Clients to create an investment transaction instantly through
Pershing. Pershing will provide execution, clearance, settlement, and custody services for Finvest.
Cash transfers and custody are also provided by Pershing. The investments in each Client’s
account are held in a separate account in the name of the Client at Pershing, and not with Finvest.
Certain transactional costs will still be paid by the Client, including transaction fees for the
purchase or sale of securities, expenses related to the use of margin, the fees (including expense
ratios) charged to shareholders of mutual funds or ETFs, short-term redemption fees, mark-ups
and mark-downs, spreads, odd-lot differentials, paper statement fees, fees charged by regulatory
agencies, exchange fees, American Depositary Receipt fees, transfer taxes, fees required by law.
These fees may be charged by Client’s brokerage account provider, but not charged by Finvest.
Finvest may charge wire transfer fees.
A client’s portfolio may be comprised of Treasury Bills, Treasury Notes, Treasury Bonds, Fixed
income money market funds and ETFs, Certificates of Deposits, Corporate Bonds, and Municipal
Bonds only.
Our application also monitors the client’s accounts to ensure that they fall within the client’s
suitability restrictions. If any changes are needed to the client’s investments, we will recommend
the changes to the client through the application. These recommendations may involve selling a
security or group of investments and buying others. The client will also receive statements at
least quarterly from the client’s account custodian. Our Investment Advisory Agreement outlines
the responsibilities of both the client and Finvest.