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Providers – Information and disclosures

RIGHTCAPITAL DOES NOT PROVIDE RECOMMENDATIONS FOR ANY PRODUCTS OR SECURITIES. NOTHING ON THIS PLATFORM SHOULD BE CONSTRUED AS A SOLICITATION OR OFFER, OR RECOMMENDATION, TO BUY OR SELL ANY SECURITY.

RightCapital Inc. d/b/a www.rightcapital.com (“RightCapital”, “We” or “Us”) provides this website to individuals and/or entities (“User” or “Users”) under the following terms and conditions (this “Agreement”). By using RightCapital’s website (the “Platform”) or submitting any information to RIghtCapital, whether by or through the Platform, User hereby consents and agrees to be bound by this Agreement. By using or accessing the Platform Site in any manner, including but not limited to visiting or browsing the Platform, User agrees to be bound by this Agreement and all other operating rules, policies and procedures that may be published by RightCapital from time to time. Use of the Platform is governed by the version of this Agreement in effect on the date of use.

  1. No Warranties. RightCapital makes no warranties, expressed or implied, as to accuracy, completeness, or results obtained from any information on www.rightcapital.com (the “Platform”). The Platform, simplifies assumptions derived and/or obtained from historical data that are used to create assumptions about potential investment returns. The Platform uses historical data with respect to investment returns and various other financially related products, concerns, issues, budget(s), income, assets, liabilities and potential returns on investments on a going forward basis (the “Information”). BE ADVISED THAT ACTUAL RETURNS, WHETHER ON INVESTMENTS OR WITH RESPECT TO ANY AND ALL INFORMATION DERIVED OR OBTAINED BY, THROUGH, FROM OR ON THE PLATFORM MAY VARY WIDELY. Any and all such Information, statistics, historical data, assumptions or the like, are not necessarily indicative of future returns or any particular or potential outcome, financially or otherwise. Other assumptions and data used by RightCapital, the Information, as well as input provided by a User, assumptions, information, data, statements, documents, whether financially related or otherwise, provided by or on behalf of any User may vary substantially or substantially differ than the actual return(s), investment objectives, goals or actual values, achieved, realized, obtained or the like, now or on a foregoing basis.
  2. No Reliance. RightCapital makes no claim, warranty, guaranty, or the like, express or implied, as to the accuracy, completeness, potential or actual results or returns, whatsoever. By using, accessing or viewing the Platform, the User hereby acknowledges, understands and agrees that the User or Users shall not rely, whatsoever, on the Information.
  3. RightCapital Does Not Provide Legal, Tax, Accounting, Investment or Financial Advice. No User should, will or intends to, rely on RightCapital as the primary basis for making any investment, financial, or tax planning decision(s), plans or the like.
    1. RIGHTCAPITAL DOES NOT PROVIDE LEGAL, TAX, ACCOUNTING, INVESTMENT OR FINANCIAL ADVICE.
    2. Before making any decision that does, may or may tend to relate to any legal, tax, accounting, investment or financial ramifications or implications, the User agrees, warrants and acknowledges that the User must and shall consult with a duly licensed investment advisor, attorney, certified financial planner, certified accountant, attorney, FINRA licensed broker-dealer or registered investment advisor and any other appropriate, duly licensed professional for advice and/counsel prior to making any such related decision or taking any such related action, whether directly or indirectly related to the User’s specific financial, legal, tax or personal status, in all respects.
    3. Circular 230 . Any income tax, estate tax or gift tax advice contained within the Platform was not intended or written to be used for, and cannot be used for, the purpose of avoiding penalties that may be imposed.
  4. No Financial Advice Provided; No Fiduciary Duty Created, Established Or Owed. User hereby agrees, acknowledges and warrants that User is solely responsible for all purchases, orders, investment, budgetary and any other financial, legal or tax related decisions or actions (“Decisions”). User further agrees, acknowledges and warrants that any and all Decisions are the sole and exclusive determination(s) of the User. The Platform and RightCapital may and at times, does, provide data, information or content whether directly, indirectly or as provided by other parties relating to investment strategies, returns, and/or opportunities to buy and/or sell securities, the User shall not construe any such content as tax, legal, financial, or investment advice. Users hereby represents that any Decision is based solely on User’s consideration of the risks involving each and every determination, decision, with respect to a particular security, Decision or action that the User decides to take or intentionally, knowingly, recklessly or negligently takes or fails to take at the User’s sole and exclusive risk. The User agrees, acknowledges and warrants that all investments involve a degree of risk and thus, User acknowledges and agrees that User is solely responsible for determining the suitability of an investment or strategy and accept the risks associated with such decisions that may include the risk of complete loss of User’s principal. The Platform, RightCapital and/or the Platform, do not, shall not, nor is there, any special relationship with or fiduciary duty to User. User agrees and acknowledges that User is solely responsible for conducting legal, accounting or due diligence review. User is hereby advised to consult with a licensed legal professional and investment advisor for any legal, tax, insurance, or investment advice. The Platform merely provides User with access to and the use of the Platform for User to consider potential investment and/or financial decisions.
  5. User Generated Or User Provide Content And Information. Information provided by User relating to or in regards to User’s assets, liabilities, goals, accounts, and other assumptions are key and critical information and data used by RightCapital within RightCapital’s calculators and as part of RightCapital’s analysis, processes and overall are Platform, that are used by the Platform to create certain assumptions. RightCapital does not review the Information, data, financial statements, documents or other information provided by a User or any group of Users. The information provided by the User should be reviewed periodically and updated whenever there is a change in information or circumstances. All of the information provided by the User is not a substitute for the information within official account statements provided to User by User’s account custodians.
  6. Data Obtained From Third Parties. RightCapital uses data obtained from third-parties including, but not limited to, MorningStar, Yodlee, the U.S. Department of Education, and the U.S Department of Health and Human Services. RightCapital cannot guarantee the accuracy or timeliness of that data. RightCapital do not endorse the accuracy, timeliness, or completeness of information and data from third-party sources.
  7. General Limitations; Limited Assumptions. Any information generated by RightCapital is hypothetical, does not reflect actual investment results, and does not guarantee future results. Assumptions about historical investment returns, inflation and tax rates, as well as the input and assumptions that User provide, such as current and future income and expense estimates are inherently uncertain and introduce uncertainty in the calculations. Even small changes in these inputs and assumptions may have a significant impact on the results. The hypothetical results generated by RightCapital may vary over time and with each use. As investment returns, inflation, taxes, and other economic conditions vary from the RightCapital assumptions, User provided input and User provided assumptions, User’s actual results will vary (perhaps significantly) from those presented in Platform.
  8. Asset Classes; Limitations. RightCapital considers investments in only a few asset classes including U.S. Large Growth, U.S. Large Value, U.S. Mid cap, U.S. Small Cap, International Equities, Emerging Markets, Real Estate, U.S. Government Bonds, U.S. Corporate Bond, U.S. High Yield, International Bonds, Cash and Other. These asset classes are not specific securities, funds or investment products. It is important to note that the broad asset classes used are not comprehensive and other investments, funds, strategies, vehicles or the like, that are not considered nor contemplated, may have characteristics that are similar or superior to the asset classes used in RightCapital. Also, User may have aggregated assets that RightCapital is unable to classify in RightCapital asset classes. These are included in the other asset class. Therefore, RightCapital’s cannot not provide a full, complete or accurate depiction, analysis or the like of any User’s financial situation and/or goals or provide any warranty, express or implied, or warranty as to such information.
    1. In Monte Carlo Simulation, RightCapital asset classes are consolidated into total of 6 consolidated asset classes including U.S. Equities, International Equities, Emerging Markets, U.S. Bonds, and Cash. The expected return assumption of these asset classes are 8.7%, 9.2%, 11.4%, 3.9% and 2.4%. The return assumption of these asset classes are derived based on the return of indices, not returns of actual investments. The return assumptions used in RightCapital are estimates based on historical return data for each asset class indices. Past returns of asset class indices are not an indication of future performance. Past performance is no guarantee of future performance. It is not possible to invest directly in an index. No investor has achieved the exact performance results presented.
  9. Portfolio Returns; Limitations. The portfolio returns assume that the portfolio has been, was, or is rebalanced to reflect the target allocation. No portfolio rebalancing costs are deducted from the portfolio value.
  10. Fees And Expenses; Calculations And Exclusions. Any and all hypothetical returns produced or generated by the Platform are calculated AFTER deducting fees and portfolio expenses. Fees and portfolio expenses are provided by Users or from third party vendors, if and when such information is available. Many fees and expenses are not included, and thus, are excluded, including, but not limited to, trading fees, product redemption fees, account fees, transfer money fees, product fees and etc. RightCapital cannot and does not guarantee the inclusion, completeness or accuracy of the fees, or portfolio expenses provided by User or as provided or calculated by RightCapital.
  11. Insurance, Annuities And Other Related Calculations. RightCapital may include Life insurance, annuity or other products in the calculation. The return or returns of any such life insurance product, annuity or other product, as may be included in the calculation, are hypothetical and shall not be used as proxy, replacement for nor construed as, actual performance of the product or to predict or project investment results of those products. Product fees, expenses and detailed features may not be completely included and modeled in the calculation.
  12. Taxes; Limited Accounting. RightCapital include limited accounting for taxes. Federal and state income tax laws are extremely complex and subject to continuous change. RightCapital calculate taxes based on User input, inflation and other assumption used by RightCapital as well as limited approximation of current federal and state tax laws. Future tax laws may be significantly different than current tax laws.
Please see Interactive Brokers’ website for the most up to date information.

For clients who choose to have an account with Interactive Brokers LLC (“Interactive Brokers”), which is an SEC-registered broker-dealer, FINRA member and member of SIPC that provides a global online trading platform, their securities transactions will generally be executed through Interactive Brokers. Interactive Brokers maintains custody of some of our clients’ assets and executes and clears some of our customer trades. Hibernian is independently owned and operated, and is not affiliated with or a related person of, Interactive Brokers.

Hibernian considers a number of factors before recommending a particular broker-dealer to our clients, including but not limited to, their familiarity with the securities to be sold or purchased, their execution skills, order-flow capabilities, access to markets, overall knowledge of the market, responsiveness, their commission rates or other fee schedules, their custodial services, reputation within the industry, their level of net capital (financial strength) and excess SIPC and other insurance coverage. We believe that the commissions charged by Interactive Brokers are competitive with similarly situated retail broker-dealers offering the same variety of securities to clients. Clients are advised, however, that they may be able to effect transactions in securities through other broker-dealers at lower commission rates, particularly with respect to securities listed on a national securities exchange or in the over-the-counter market. We note that Interactive Brokers has been Rated Low Cost Online Broker 15 years in a row by Barron’s. In addition, the Transaction Auditing Group, Inc. (TAG), a third-party provider of transaction analysis, has determined that Interactive Brokers’ U.S. stock and options executions have outperformed the industry as a whole for the last ten straight years – from 2007 through 2016.

Although the brokerage commissions and/or transaction fees charged by Interactive Brokers may be higher or lower than those charged by other broker-dealers, we seek best execution for our clients and strive to ensure that our clients pay brokerage commissions and/or transactions fees which we have determined, in good faith, to be reasonable in relation to the value of the brokerage and other services provided by Interactive Brokers.

RESEARCH AND OTHER SOFT DOLLAR BENEFITS.
Interactive Brokers offers products or services other than execution that assist our firm in managing and administering client accounts. These may include software and other technology that provide access to client account data (such as trade confirmations and account statements), pre-trade allocation tools that facilitate trading for multiple clients at once, facilitating payment of our fees from clients’ accounts, assisting with back office functions, recordkeeping and client reporting. These services may be used to service all or a substantial number of client accounts, including (in some cases) accounts not maintained at Interactive Brokers.

Hibernian may also receive services from Interactive Brokers or its affiliates that are intended to help our firm manage and further develop our business. These services may include website design and technology support. Interactive Brokers also has arrangements with various product vendors, which enable our firm to purchase their products at a discount. These products may include such items as: client reporting and consolidated statement software; client communication software; client relationship management software; compliance assistance; and investment research.

Hibernian does not participate in any commission-sharing arrangements with Interactive Brokers or receive soft dollar credits. As a fiduciary to our clients, we are required to disclose that there is an inherent conflict of interest when our firm recommends that clients maintain their assets at Interactive Brokers. These recommendations may be based in part on the benefits we receive from Interactive Brokers, such as the availability of the above-mentioned products and services, and not solely on our clients’ interest in receiving the most favorable execution. Nonetheless, we seek to ensure that the securities transactions effected for our clients represent the best qualitative execution, not just the lowest possible cost.

Please see TD Ameritrade’s website for the most up to date information.

Hibernian participates in TD Ameritrade’s institutional customer program and may recommend TD Ameritrade to clients for custody and brokerage services. There is no direct link between Hibernian’s participation in the program and the investment advice it gives to its clients, although Hibernian receives economic benefits through its participation in the program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving Hibernian participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to Hibernian by third party vendors. TD Ameritrade may also have paid for business consulting and professional services received by Hibernian’s related persons. Some of the products and services made available by TD Ameritrade through the program may benefit Hibernian but may not benefit its client accounts. These products or services may assist Hibernian in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help Hibernian manage and further develop its business enterprise. The benefits received by Hibernian or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, Hibernian endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Hibernian or its related persons in and of itself creates a potential conflict of interest and may indirectly influence Hibernian’s choice of TD Ameritrade for custody and brokerage services.

Please see Betterment’s website www.betterment.com for the most up to date information.

Hibernian does not maintain custody of your assets on which we advise, although we may be deemed to have custody of your assets if you give us authority to withdraw advisory fees from your account. Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use MTG, LLC dba Betterment Securities (“Betterment Securities”), a registered broker- dealer and member of the SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Betterment Securities. Betterment Securities will hold your assets in a brokerage account and buy and sell securities when we and/or you instruct them to. While we recommend that you use Betterment Securities as custodian/broker, you will decide whether to do so and will open your account with Betterment Securities by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Betterment Securities, then we cannot manage your account on Betterment for Advisors (defined below).

YOUR BROKERAGE AND CUSTODY COSTS
For our clients’ accounts that Betterment Securities maintains, Betterment Securities does not charge you separately for custody/brokerage services, but is compensated as part of the Betterment for Advisors (defined below) platform fee, which is charged for a suite of platform services, including custody, brokerage, and sub-advisory services provided by Betterment and access to the Betterment for Advisors platform. The platform fee is an asset-based fee charged as a percentage of assets in your Betterment account. Clients utilizing the Betterment for Advisors platform may pay a higher aggregate fee than if the investment management, brokerage and other platform services are purchased separately. Nonetheless, for those Clients participating in the Betterment for Advisors platform, we have determined that having Betterment Securities execute trades is consistent with our duty to seek “best execution” of your trades.

SERVICES AVAILABLE TO US VIA BETTERMENT FOR ADVISORS
Betterment Securities serves as broker-dealer to Betterment for Advisors, an investment and advice platform serving independent investment advisory firms like us (“Betterment for Advisors”). Betterment for Advisors also makes available various support services which may not be available to Betterment’s retail customers. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Betterment for Advisors’ support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Betterment for Advisors’ support services:

1. SERVICES THAT BENEFIT YOU. Betterment for Advisors includes access to a globally diversified, low-cost portfolio of ETFs, execution of securities transactions, and custody of client assets through Betterment Securities. In addition, a series of model portfolios created by third-party providers are also available on the platform. Betterment Securities’ services described in this paragraph generally benefit you and your account.

2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment for Advisors also makes available to us other products and services that benefit us, but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts, such as software and technology that may:
a. Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts.
b. Provide access to client account data (such as duplicate trade confirmations and account statements).
c. Provide pricing and other market data.

3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment for Advisors, we may be offered other services intended to help us manage and further develop our business enterprise. These services include:
a. Consulting (including through webinars) on technology and business needs.
b. Access to publications and conferences on practice management and business succession.

OUR INTEREST IN BETTERMENT SECURITIES’ SERVICES
The availability of these services from Betterment for Advisors benefits us because we do not have to produce or purchase them. In addition, we do not have to pay for Betterment Securities’ services. We may have an incentive to recommend that you maintain your account with Betterment Securities, based on our interest in receiving Betterment for Advisors and Betterment Securities’ services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Betterment Securities as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Betterment Securities’ services and not Betterment for Advisors and Betterment Securities’ services that benefit only us or that may not directly benefit you.

BETTERMENT FOR ADVISORS’ TRADING POLICY
When using the Betterment for Advisors platform, we and you are subject to the trading policies and procedures established by Betterment. These policies and procedures limit our ability to control, among other things, the timing of the execution of certain trades (including in response to withdrawals, deposits, or asset allocation changes) within your account. You should not expect that trading on Betterment is instant, and, accordingly, you should be aware that Betterment does not permit you or us to control the specific time during a day that securities are bought or sold in your account (i.e., to “time the market”). Betterment describes its trading policies in Betterment LLC’s Form ADV Part 2A. As detailed in that document, Betterment generally trades on the same business day as it receives instructions from you or us. However, transactions will be subject to processing delays in certain circumstances. In particular, orders initiated on non-business days and after markets close generally will not transact until the next business day. Betterment also maintains a general approach of not placing securities orders during approximately the first thirty minutes after the opening of any market session. Betterment also generally stops placing orders arising from allocation changes in existing portfolios approximately thirty minutes before the close of any market session. Betterment continues placing orders associated with deposit and withdrawal requests until market close. Betterment maintains a general approach of not placing orders around the time of scheduled Federal Reserve interest rate announcements. Furthermore, Betterment may delay or manage trading in response to market instability. For further information, please consult Betterment LLC’s Form ADV Part 2A.

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