Treasure Investment Management, LLC (“Treasure”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”) as of November 12, 2020. Treasure provides discretionary investment advisory services to businesses utilizing its proprietary software and experienced investment team. Treasure is a wholly owned subsidiary of Treasure Technologies, Inc. (“Treasure Technologies”), a Delaware corporation. Treasure Technologies provides a suite of financial and technology products through its cash management platform to empower businesses to optimize their idle cash.
Services Treasure provides discretionary investment advisory services through its web based platform (the “platform”). Clients choosing to open an account will provide company profile information, including financial information and investment objective, during the account opening process on the platform. Once completed, clients will be prompted to select their Asset Allocation Strategy by selecting which individual allocations they wish to invest in and setting a target weighting for each (either in dollars invested or as a percentage of their total account balance). Treasure currently offers 3 allocations: ●Managed Money Market: Invests in money market funds with the aim of dynamically identifying market changes to maximize yield while ensuring liquidity.
●Managed Treasuries: Invests in T-bill and TIPS with the goal of optimizing maturities to achieve consistent returns and liquidity.
●Managed Income: Invests in fixed income markets using mutual funds or exchange traded funds (“ETFs”) with the goal of managing risk, maximizing returns, and avoiding drawdowns.
The Asset Allocation Strategy, including all selected allocations, will be implemented within a single investment account. Clients can make changes to their Asset Allocation Strategy at any time using the platform or by contacting[email protected]. Clients may also contact our team for assistance selecting their Asset Allocation Strategy or with questions about the allocations. Clients can provide instructions to restrict specific securities from being purchased for their account through the platform. Clients are responsible for notifying Treasure of any changes to their company profile. Treasure will contact clients annually to request the company provide updated company profile information, including financial information and investment objective, if a change has occurred.
4 Treasure does not recommend particular allocations or an Asset Allocation Strategy to clients, and not all allocations will be available to all clients. Treasure manages client investment accounts using the Asset Allocation Strategy and restricted security list (if any) selected by the client. Treasure has investment discretion with respect to the management of the underlying allocations in a client’s Asset Allocation Strategy, including the security selection and the relative weighting of securities within each allocation. This discretion includes the type and amount of securities to be bought or sold, and the timing of such transactions. In addition, Treasure has discretionary authority to periodically rebalance client accounts based on its internal portfolio management parameters. Treasure also has authority to determine the timing and method when liquidating investments, including selecting which investments in the client account to be liquidated. Treasure exercises this authority at its sole discretion to raise cash for a client withdrawal, facilitate remodeling of a selected allocation, or any other circumstance Treasure determines necessary to fulfill its obligations to clients, contracted parties, and regulatory authorities. Over time, Treasure may choose to increase or decrease the number and types of allocations available to clients, and modify the type of securities offered within an allocation. Treasure does not generally accept individual trade instructions from clients, but will consider them on a case by case basis.
Treasure’s platform is available through its website and through contracted third-party service provider (“API Partner”) websites via application programming interface (“API”) integration.
These partnerships seek to offer enhanced technology offerings to clients through joint technology developed by Treasure’s affiliate, Treasure Technologies, and the API Partner. Some benefits include consolidation of financial account management platforms, centralized reporting, streamlined operational processes and improved user experience. All investment advisory services provided through an API Partner’s website are provided by Treasure, not the API Partner, and clients should direct all questions and servicing inquiries relating to their account to[email protected]. Platform functionality will differ for clients opening accounts through an API Partner, and not all services and allocations are available through all API Partner websites. Clients joining through an API Partner should review the Fees section of this brochure and the Investment Management Agreement prior to account opening for a full explanation of available services and fees. Clients are under no obligation to open an account through an API Partner and may choose to open an account through the Treasure website at any time.
Brokerage Practices Clients authorize and instruct Treasure to direct brokerage transactions to Apex Clearing Corporation (“Apex”), an SEC-registered broker-dealer and member FINRA/SIPC, for trade execution and clearing services in addition to brokerage and custody services. Client assets will be held in a separately managed investment account in the client’s name and the client retains all rights of ownership. See Item 9 for more information.
5 Treasure executes trades through Apex in recognition of the value of the brokerage and other services that Apex provides. The factors that Treasure considers in designating Apex as approved broker include, but are not limited to: execution capability and available liquidity; timing and size of particular orders; commission rates; responsiveness; trading experience; reputation, integrity and fairness in resolving disputes; quality of application programming interfaces and technology; and other factors. Clients should understand that not all investment advisers recommend, request, or require their clients to direct brokerage. However, the direction to trade through Apex is part of the overall structure of Treasure’s product offerings, including through joint technology created by Treasure and Apex. You are not required or obligated to utilize our services and therefore you are not required or obligated to open an account with Treasure or Apex.
Treasure will monitor the execution quality provided by Apex and will periodically reevaluate the quality and cost of Apex’s brokerage services in accordance with Treasure’s overall responsibilities for accounts over which it has investment discretion, but it will not select broker-dealers or evaluate best execution in terms of any particular transaction. Instead, all trades will be placed with Apex. By directing

brokerage through Apex, Treasure will not always be able to obtain the most favorable execution for client transactions and it is possible that clients will pay higher transaction costs or receive less favorable net prices as a result of the decision to direct brokerage to Apex. It is possible that the prices, commissions, other execution costs, and transaction charges for trades directed through Apex will not be as favorable as those that would be obtained if trades were placed through another broker-dealer. However, clients do not pay brokerage execution costs associated with transactions in their accounts.
Brokerage and execution fees are negotiated and paid by Treasure. As a result, Treasure has an incentive to negotiate favorable brokerage execution costs that will permit it to continue to offer its clients a competitively priced service.
Treasure may choose to add or change available custodians at any time. Client requests to use an alternate custodian will be evaluated on a case by case basis.
Research and Other Soft Dollar Benefits Other services made available by Apex are intended to help Treasure manage and further develop its business enterprise. The benefits received by Treasure or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to Apex. As part of its fiduciary duties to clients, Treasure endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Treasure or its related persons in and of itself creates a conflict of interest and may indirectly influence Treasure’s selection of Apex for custody and brokerage services.
6 Trade Handling Treasure’s platform submits trading instructions for client accounts to the broker-dealer for execution in a batch, which causes all trades to be submitted to the broker-dealer at the same time. Treasure may also aggregate securities sale and purchase orders for a client with similar orders being made contemporaneously for other client accounts. In such an event, the average price of the securities purchased or sold in such a transaction may be determined and a client may be charged or credited, as the case may be, the average transaction price. As a result, however, the price may be less favorable to the client than it would be if similar transactions were not being executed concurrently for other Accounts. More information related to Treasure’s trading practices can be found in Item 9 of this brochure.
Fees Treasure charges clients 0.35% (35 basis points) of the assets under management annually (the “Investment Management Fee”), charged monthly in arrears based on the average daily balance of the investment account in the prior month.
Treasure reserves the right to negotiate different fees for certain clients than what is specified below. Negotiated fees may differ based on factors including, but not limited to: the type and size of the account, the historical and/or expected size and number of trades for the account, and the client-related services to be provided to the client.
Treasure does not currently receive any sales commissions, 12b-1 fees or other fees from ETFs or other products for investing such funds on behalf of advisory clients.
Fees Paid to Affiliates and Third-Parties Clients who join Treasure through its website will also receive a demand deposit account (“Treasure Cash”) offered by Treasure Technologies through its partnership with Grasshopper Bank, N.A. (“Grasshopper”), member FDIC. Grasshopper pays Treasure Technologies a monthly incentive rate based on the average daily balance of Treasure Technologies’ client accounts.
Treasure Technologies pays a portion of the monthly incentive rate it receives to its clients.
Treasure Technologies, in its sole discretion, determines the amount of the monthly incentive rate to be paid to client accounts and the timing of such payments. Further, Treasure Technologies, in its sole discretion, may discontinue these payments at any time. This creates a conflict of interest for Treasure when referring its customers to open a Treasure Cash account, as client deposits maintained at Grasshopper result in additional compensation to its affiliate.
Treasure and Treasure Technologies manage this conflict of interest by not requiring a minimum balance in client Treasure Cash accounts.
7 In addition to Treasure’s Investment Management Fee, clients who open an account through an API Partner will be charged a Joint Technology Fee by Treasure’s affiliate, Treasure Technologies. This fee is for the joint technology developed by Treasure Technologies in partnership with the API Partner, and is not an investment advisory fee. The fee is paid to Treasure Technologies and will differ based on the API Partner used and joint technology developed. Treasure Technologies will pay a portion of this fee to the API Partner. This creates a conflict of interest for Treasure, as clients who join through an API Partner will pay additional compensation to its affiliate. This also creates an incentive for the API Partner to refer clients to Treasure, as they will be compensated by Treasure’s affiliate. Certain API Partners may pay additional compensation to Treasure Technologies for the joint technology developed until certain contractual obligations are fulfilled (the “Minimum Technology Fee”). This fee can be reduced in part or in full by Joint Technology Fees paid by clients referred by the API Partner to Treasure. This creates an additional incentive to the API Partner to refer its clients to Treasure to reduce the Minimum Technology Fee it pays. Treasure, Treasure Technologies and the API Partner address this conflict of interest by disclosure through this brochure, the Investment Management Agreement, and the Solicitor’s Disclosure provided to clients. In addition, clients are under no obligation to open an account through the API Partner and can instead open an account directly with Treasure at any time. Please refer to the Investment Management Agreement and Solicitor’s disclosure provided by your API Partner for more information and important disclosures about the joint technology offered, services available, and the Joint Technology Fee to be charged.
Other Fees As a general matter, clients who invest in a mutual fund or ETF pay ETF fees. A Mutual Funds and ETF typically includes embedded expenses that may reduce the fund's net asset value, and therefore directly affect the fund's performance and affect a Client’s portfolio performance or an index benchmark comparison. Expenses of a Mutual Fund or ETF may include management fees, custodian fees, brokerage commissions, and legal and accounting fees. Mutual Fund and ETF expenses may change from time to time at the sole discretion of the ETF issuer. These Mutual Fund and ETF fees are not paid to Treasure or its affiliates. Treasure does not receive transaction-based compensation for client securities transactions.
Apex may charge clients additional fees based on account activity, such as wire fees. Clients should refer to their Brokerage Account Agreement for a full list of fees related to their investment account.
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