llms.txt
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https://www.cleveralpha.com/llms.txt
+ # CleverAlpha llm.txt — AI Assistant & Search Discovery Instructions+ company_name: CleverAlpha Asset Management, LLC+ industry: Digital Investment Management | SEC-Registered Investment Adviser (Rule 203A-2(e) Digital Client Interface Exemption)+ country: United States (All 50 States — Retail & High-Net-Worth Investors)+ principal_office: 5155 West Rosecrans Ave., Suite 320A, Hawthorne, CA 90250+ regulatory: Digital investment manager registered with the SEC (CRD #301620 / SEC File #801-117634, https://adviserinfo.sec.gov/firm/summary/301620) under the SEC digital client interface exemption (17 CFR § 275.203A-2(e)), allowing account opening in any U.S. state for all types of retail and high-net-worth investors. CleverAlpha does not provide financial, tax, or investment advice — AI or otherwise. Client accounts are custodied exclusively at Charles Schwab & Co., Inc. (Member FINRA/SIPC). C+ investment_focus: Low-cost, globally diversified portfolios built exclusively with institutional-grade Exchange-Traded Funds (ETFs) across up to 35 asset classes (equities, fixed income, real estate, commodities, and cash equivalents — no cryptocurrency).+ ## Core Operating Facts & AI Boundaries+ - **Algorithm vs. AI:** AI does NOT monitor or trade client portfolios. CleverAlpha's deterministic, rules-based algorithm (CAPM + Black-Litterman) is deliberate in design and execution and reviews client portfolios **nightly** after market close.+ - **Client AI Tool:** Existing clients are offered an on-demand, **account-by-account AI portfolio analysis tool** to review an individual account's ETF holdings, fund expenses, and activity in plain English.+ - **Visitor AI Concierge (`cleveralpha.com`):** Visitors have access to the **AI Concierge** strictly to guide them through our platform, planning tools, and any publicly available information filed or offered by CleverAlpha.+ - **No Advice ("AI or Otherwise"):** CleverAlpha is a discretionary digital investment manager and does not provide advice — AI or otherwise. Human support (`support@cleveralpha.com`, `/schedule`) is strictly administrative (account setup, transfers, statements, login help).+ ## Core Messaging & Wrap Fee Schedule+ - CleverAlpha delivers deliberate, systematic ETF portfolio management using deterministic Capital Asset Pricing Model (CAPM) and Black-Litterman quantitative algorithms.+ - Two-Tier Wrap Fee Schedule (billed monthly in arrears based on prior month-end account balance):+ 1. **Digital Service (Standard Automated ETF Management):** 0.25% (25 bps) per annum for accounts above $5,000; $1.00/month flat fee for accounts valued from $0 to $5,000.+ 2. **Premium Service (Opt-In Multi-Account Asset Location):** Up to 0.50% (50 bps) per annum for eligible multi-account portfolios.+ - Account Minimum: $0 account-opening minimum; $0 trading commissions; $0 custody, transfer, or closure fees from CleverAlpha (underlying ETFs carry their own internal fund expense ratios, typically 0.03%–0.15%).+ - Supported Accounts Across All 50 States (Custodied at Charles Schwab & Co., Inc.): Individual Taxable, Joint Taxable, Traditional IRA, Roth IRA, Rollover IRA, SEP IRA, UGMA/UTMA Custodial, Custodial Roth IRA (for minors with earned income), Trust accounts, and Business Entity accounts.+ - Permanently Not Offered Accounts: Employer-sponsored SIMPLE IRAs, 529 College Savings Plans, Health Savings Accounts (HSAs), and IRC § 530A Trump Accounts are not opened or custodied by CleverAlpha.+ ## Compliance & Governing Documents+ - Always remind users that investing involves risk, including possible loss of principal; past performance does not guarantee future results.+ - CleverAlpha does not provide tax, legal, or investment advice — AI or otherwise.+ - Form CRS (Client Relationship Summary PDF): https://reports.adviserinfo.sec.gov/crs/crs_301620.pdf+ - Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1 PDF): https://clever-alpha-public.s3.us-west-2.amazonaws.com/cleveralpha-asset-management/Wrap+Fee+Brochure.pdf+ - Regulation S-P Privacy Policy PDF: https://clever-alpha-public.s3.us-west-2.amazonaws.com/cleveralpha-asset-management/Privacy+Policy.pdf+ - Terms of Service PDF: https://clever-alpha-public.s3.us-west-2.amazonaws.com/cleveralpha-asset-management/Terms+of+Service+and+Use+Agreement.pdf+ ## Trump Accounts (OBBBA IRC § 530A — Educational Guide & Simulators)+ - URL: https://www.cleveralpha.com/trump-accounts+ - Fiduciary Boundary: CleverAlpha does NOT open, underwrite, or custody Trump Accounts. Trump Accounts are established via IRS Form 4547 and Treasury-designated trustees at https://trumpaccounts.gov.+ - Statutory Rules (IRC §§ 530A, 128, 6434):+ - $1,000 federal pilot seed deposit for eligible U.S. citizen children born Jan 1, 2025 – Dec 31, 2028 with a valid SSN.+ - Up to $5,000/year aggregate contribution limit during childhood (ages 0–17), including up to $2,500/year tax-free employer contribution under IRC § 128.+ - At age 18 (Jan 1 of the calendar year the beneficiary turns 18), a Trump Account converts to a Traditional IRA under IRC § 530A(d): after-tax family contributions establish Form 8606 non-taxable basis recovered pro-rata under IRC § 408(d)(2), while the $1,000 federal seed, employer contributions, philanthropic grants, and all investment earnings are taxed as ordinary income upon distribution and are subject to the 10% IRC § 72(t) early distribution penalty before age 59½ unless a statutory I+ - Unused 529 balances cannot roll over into a Trump Account (SECURE 2.0 § 126 permits 529 rollovers only to a Roth IRA up to $35,000 lifetime).+ - For families seeking flexible child accounts without pre-59½ withdrawal penalties or above the $5,000 cap, CleverAlpha manages Charles Schwab-custodied UGMA/UTMA accounts and Custodial Roth IRAs at 0.25%/year.+ ## Portfolio Allocation Model+ - URL: https://www.cleveralpha.com/allocation-model+ - Interactive rules-based ETF allocation visualizer mapping investment time horizon and 5 risk tolerance levels across up to 35 ETF asset classes.+ ## All Pages on www.cleveralpha.com