Updated: July 2019

Counterpoint Capital Advisers, LLC (“Counterpoint,” “we,” or “us”) is an investment advisor registered with the State of Washington under the Investment Advisers Act of 1940, as amended. Counterpoint may only transact business in states where we are appropriately registered or exempt from registration. Individualized responses that involve either the effecting transactions in securities or the rendering of personalized investment advice for compensation will not be made without registration or exemption. Nothing on this Site should be construed as a solicitation, offer, or recommendation to buy or sell any security. Investment advisory services are only provided to investors who become Counterpoint Clients (“Clients”) pursuant to a written Client Agreement, which investors are urged to read and carefully consider in determining whether such agreement is suitable for their facts and circumstances. 

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY LOSE MONEY. ASSET ALLOCATION CANNOT ASSURE A PROFIT NOR PROTECT AGAINST A LOSS. There can be no assurance that an investment mix or any projected or actual performance shown on this Site will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future comparable to those shown or that any or all of Counterpoint’s Clients experienced such returns.

Counterpoint’s investment strategies, including portfolio rebalancing, can lead to high levels of trading. High levels of trading could result in (a) bid-ask spread expense; (b) trade executions that may occur at prices beyond the bid-ask spread (if quantity demanded exceeds quantity available at the bid or ask); (c) trading that may adversely move prices, such that subsequent transactions occur at worse prices; (d) trading that may disqualify some dividends from qualified dividend treatment; (e) unfulfilled orders or portfolio drift, if markets are disorderly or trading halts altogether; and (f) unforeseen trading errors.

As part of transferring your account to Counterpoint, we will sell the investments in your account and invest the proceeds into one or more of our portfolios. Liquidating your transferred account may cause, among other things, realized capital gains or losses in specific securities, surrender fees, and redirection of declared dividends or distributions. Also, be aware selling securities before transfer could subject you to the same risks.

All product names, logos, and brands are the property of their respective owners. Using these names, logos, and brands is for identification purposes only and does not imply endorsement or affiliation.

ETF Selection Disclosures

The securities employed in Counterpoint Client accounts are exchange-traded funds or other publicly registered funds (“ETFs”), generally registered investment companies under the Investment Company Act of 1940. Although Counterpoint believes its selection process identifies ETFs with high liquidity, low expenses, and low tracking error, Counterpoint’s selection process does not guarantee the quality of a particular ETF or that it will 1) be profitable, 2) properly track any comparable index, 3) trade in a liquid fashion, or 4) trade at or above its publicly-posted net asset value.

Counterpoint reserves the right to change the selection of ETFs that it recommends at any time if, in Counterpoint’s sole discretion, any ETF does not meet the requirements for continued listing on the platform. Clients should be aware that changes in the selection of ETFs employed by Counterpoint’s investment management service may result in the sale of their existing holdings and may subject them to additional tax liability.

ETFs are only one type of securities product. Counterpoint generally does not make other types of securities products that an investor may wish to consider as part of their overall investment plan available to clients. Other ETFs or investment products may provide different performance.

ETF Fee and Performance Disclosure

An ETF typically includes embedded expenses that may reduce its net asset value and, therefore, directly affect its performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. These expenses may include management, custodian, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking errors and expenses may vary.

Furthermore, ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF incurs expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF.

Certain ETF strategies may include fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses could be higher than otherwise charged for exchange-traded equity securities and for which market quotations or valuation may be limited or inaccurate.

Clients should be aware that, in some limited instances, it may be difficult or impossible to trade the Clients’ securities. This liquidity risk may be caused by numerous factors, including but not limited to 1) extreme market volatility, 2) a decision by exchange participants to withhold some or all of their quoted market bids, 3) exchange technical issues or exchange closure, 4) delisted or halted securities, and/or 5) a position across Client accounts that is large relative to the average daily trading volume of the security.

Performance Disclosures

Unless marked otherwise, performance information is presented as gross of all management fees, expenses, commissions, and dividends. 

Any comparison to traditional financial advisors is based on an evaluation of average fees and returns. Actual results may differ for each investor, and there can be no guarantee of enhanced returns due to additional diversification, ETF selection, or the use of Counterpoint’s investment management service.

Projected and/or hypothetical performance is intended to show only an expected range of possible investment outcomes based on historical average returns and standard deviation of each investment type contained in the investment mix recommended by Counterpoint but does not take into consideration the effect of taxes, changing risk profiles, or future investment decisions. Projected and/or hypothetical performance does not represent actual Client accounts or actual trades and may not reflect the effect of material economic and market factors. The actual transaction costs in Client accounts may be different.

Actual investors with Counterpoint may experience different results from any hypothetical results shown. There is a potential for loss and gain that is not reflected in the hypothetical information portrayed. The hypothetical performance results shown do not represent the results of actual trading using client assets but were achieved using the retroactive application of a model designed with the benefit of hindsight. Investors should carefully review the additional information Counterpoint presents as part of any hypothetical comparison.

ANY COMPARISONS TO INDICES ARE PROVIDED FOR ILLUSTRATIVE PURPOSES ONLY. AN INDEX IS A BROADLY DIVERSIFIED, UNMANAGED GROUP OF SECURITIES, WHICH MAY INCLUDE ONLY LARGE CAPITALIZATION COMPANIES OR COMPANIES OF A CERTAIN SIZE. BROADLY BASED INDICES MAY BE SHOWN ONLY AS AN INDICATION OF THE GENERAL PERFORMANCE OF THE FINANCIAL MARKETS DURING THE PERIODS INDICATED. BECAUSE OF THE DIFFERENCES BETWEEN THE CLIENT ALLOCATIONS AND ANY INDICES SHOWN, COUNTERPOINT CAUTIONS INVESTORS THAT NO INDEX IS DIRECTLY COMPARABLE TO THE PERFORMANCE SHOWN SINCE EACH INDEX HAS ITS UNIQUE RESULTS AND VOLATILITY, AND SUCH INDICES IF SHOWN, SHOULD NOT BE RELIED UPON AS AN ACCURATE COMPARISON.

The return, composite, and performance information shown on this Site uses or includes information compiled from third-party sources, including independent market quotations and index information. Counterpoint believes the third-party information comes from reliable sources, but Counterpoint does not guarantee the accuracy of the Site information and may receive incorrect information from third-party providers. Unless otherwise indicated, the information on the Site has been prepared by Counterpoint and has not been reviewed, compiled, or audited by any independent third-party or public accountant.

Fee and Account Disclosures

Recommendations and fees may vary for each Client. Advisory fees are calculated based on the amount of managed assets (as detailed further in Counterpoint’s Form ADV Part 2).

Counterpoint does not make any representations regarding the execution quality of orders placed with our brokerage partner. However, Counterpoint monitors the execution quality of transactions to ensure that Clients receive the best overall trade execution pursuant to regulatory requirements.

Description of “Free.” Certain ETF products offered through Counterpoint may be free of commissions and advisory fees; however, management and/or other fees may be charged for investment products managed by outside companies, which are unaffiliated entities of Counterpoint.