Form ADV Part 2-A: Brochure - Affluo, LLCaffluo.com/wp-content/uploads/2018/04/Form-ADV-Part-II-v1.3b.pdf · Hemang S. Bhojani (CRD # 6286159) is the Founder, President and Portfolio

Form ADV Part 2-A: Brochure This brochure provides information about the qualification and business practices of Affluo, LLC. If you have any questions about the contents of this brochure, please contact us at (718)-473-9837 or [email protected]. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Affluo, LLC also is available on the SEC’s website

www.adviserinfo.sec.gov. The CRD number of Affluo, LLC is 170149. Affluo, LLC is a Registered Investment Adviser. Our use of term “Registered” does not imply a certain level of skill or training. Affluo, LLC

Hemang S. Bhojani March 31, 2017 Version 1.3

2401 Deer Pass, Austin, TX 78746 Tel: 718 473 9837 Fax: 801 881 7967 Email: [email protected]

mailto:[email protected]?subject=Brochure:

http://www.adviserinfo.sec.gov/

mailto:[email protected]?subject=Brochure:

Affluo, LLC

2401 Deer Pass, Austin, TX 78746 718-473-9837 [email protected] Page 1

2. Material Changes No material changes have been made to this brochure since our last update on January 1, 2015.

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3. Table of Contents

2. Material Changes ...................................................................................................................................... 1

3. Table of Contents ...................................................................................................................................... 2

4. Advisory Business ...................................................................................................................................... 3

5. Fees and Compensation ............................................................................................................................ 5

7. Types of Clients and Account Sizes ......................................................................................................... 12

9. Disciplinary Information .......................................................................................................................... 15

10. Other Financial Industry Activities and Affiliations ............................................................................... 15

11. Code of Ethics, Participation of Interest in Client Transactions and Personal Trading ......................... 16

12. Brokerage Practices .............................................................................................................................. 17

13. Review of Accounts ............................................................................................................................... 17

14. Client Referrals and Other Compensation ............................................................................................ 17

15. Custody ................................................................................................................................................. 18

16. Investment Discretion ........................................................................................................................... 18

17. Voting Client Securities ......................................................................................................................... 18

18. Financial Information ............................................................................................................................ 18

19. Requirements for State-Registered Advisers ........................................................................................ 18

Affluo, LLC


4. Advisory Business Affluo, LLC is a Registered Investment Adviser based in Austin, Texas. It is also referred to as

“Adviser” in this document.

Hemang S. Bhojani (CRD # 6286159) is the Founder, President and Portfolio Manager at Affluo,

LLC. He has been actively investing, studying investment strategies and testing investment

hypotheses, sometimes using algorithms. Prior to that, he worked as a management consultant

at McKinsey & Company where he advised Clients, primarily in the Financial Services sector, on

a broad range of strategic and operational issues. Prior to McKinsey & Company, he worked in

enterprise software at Trilogy Software, serving Clients in the Life Insurance and Annuities

sector. During this time, his roles spanned development, technical design, project management

and Client management.

Hemang received an M.B.A. with Honors from the University of Chicago’s Booth School of

Business, an M.S. in Information Networking from Carnegie Mellon University and a B.E. in

Computer Engineering from the University of Mumbai where he graduated at the top of his

class.

Hemang made his first investment at the age of thirteen and has held a personal portfolio since

then.

He started Affluo, LLC to offer Clients an alternative method to the traditional buy-and-hold

method of investment. His methods have a greater focus on always tracking and managing risk

exposure.

Types of Advisory Services

Affluo, LLC offers portfolio management services to Clients who are looking for alternatives to

the traditional buy-and-hold, long-only method of investment. Affluo, LLC managed accounts

are actively traded and may include trading options and shorting. The financial instruments

traded in these accounts may include stocks, short equities, ETFs, inverse ETFs, leveraged ETFs,

puts, calls, option combinations like spreads and currency pairs. On select occasions, Futures

may be traded, only when the relevant ETF does not serve the Client interests by tracking the

underlying commodity well. Note that Affluo, LLC is not a CTA (Commodity Trading Advisor) and

trading Futures is only done on an exception basis and after getting Client approval. Our focus is

on actively managing the risk exposure, both for an account and for each position / trade.

Clients should note that this kind of trading activity carries risk and could potentially lose

money even when the general market is up or roughly level i.e. range-bound. Additionally,

while actively traded accounts may, in a downward trending market or deteriorating

individual position, benefit from the agility of closing positions and thereby limit losses or

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lock in gains, the cost of this is, usually, more money spent on transaction costs, higher taxes

in the case of short term gains and lower gains in a secular up-trending market.

This service is offered as simple managed accounts (SMA) whereby the Firm manages a

collection of individual accounts as part of a larger “master” portfolio. Conceptually, there is a

master trading account where the trades are issued. Each trade (buy or sell) that is made in the

master portfolio is made to all managed accounts (for a specified account type) simultaneously

and proportionally based on each account’s value (either cash value or total value), relative to

the total corresponding value of all the managed accounts.

As an example, let’s consider that $1 million are under management with 3 accounts A, B and C

with $500K, $300K and $200K respectively. If an order to purchase 1000 IBM shares is

submitted in the master account then the order will be automatically split in proportion to the

account values such that 500 shares will be purchased in account A, 300 in account B and 200 in

account C. On occasion, trades may be selectively allocated to a subset of managed accounts or

an individual account, depending on varying Client requirements and preferences. Also, trades

may be allocated individually to a newly opened or funded account to bring its overall

investment in line with other accounts.

IRA accounts will be managed in a slightly different way compared to non-IRA accounts. Since

IRA accounts do not allow shorting, IRA accounts will be excluded from shorting. In those

accounts, if there is a need to establish a hedge or take an outright bearish position, it will be

accomplished by taking a position in inverse ETFs.

Affluo, LLC will help Clients in establishing margined or non-margined accounts with our

selected brokerage service, Interactive Brokers, LLC. We have no affiliation with Interactive

Brokers, LLC and it has mainly been chosen as it is a well-established, award-winning brokerage

service. They give us the ability to trade a wide variety of financial instruments with good

execution at a very reasonable cost. We do not receive any compensation from Interactive

Brokers, LLC. Further information on Interactive Brokers, LLC can be found at

www.interactivebrokers.com.

As of end of day March 24, 2017, Affluo, LLC managed $577,911 on a discretionary basis and no

funds on a non-discretionary basis.

Master Trading

Account ($ 1 million)

Client A Account

($500K)

Client B Account

($300K)

Client C Account

($200K)

http://www.interactivebrokers.com/

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5. Fees and Compensation The Adviser charges an annual advisory fee of 2% of assets under Adviser management. There

are two options under the flat fee structure. Adviser’s fees are exclusive of brokerage

commissions, transaction fees, and other related costs and expenses which may be incurred by

the Client.

1. Quarterly Flat Fee Option

Fees will be charged to the Client at the end of each calendar quarter. The quarterly fees

charged will be 0.5% of the account value (defined as “Net Liquidation Value”) after Market

hours (including extended hours) on the last day of the calendar quarter.

Example of Fees charged under Quarterly Flat Fee Option:

Date Net Account Value Adviser Fees

March 31st $100,000 $100,000 * 0.005 = $500

June 30th $105,000 $105,000 * 0.005 = $525

September 30th $110,000 $110,000 * 0.005 = $550

December 31st $115,000 $115,000 * 0.005 = $575

Fees when withdrawing or adding funds

If a Client wants to withdraw money, at the time of withdrawal, fees will be charged at a pro-

rated rate from the beginning of the quarter till the day the Client withdraws money using 91

days as the length of a quarter. The pro-rated fees will be charged only on the portion of the

funds being withdrawn; fees for the rest of the funds will be charged at the end of the quarter.

The same formula would apply for a full withdrawal. Termination of Advisory relationship

would be treated like a full withdrawal.

Example of fees for Client withdrawing funds in the middle of the quarter:

Timing of withdrawal

Amount withdrawn

Adviser Fees on withdrawn amount to be paid at withdrawal

May 30th end of day $50,000 $50,000 * (60/91) * 0.005 = $164.84

June 15th end of day $50,000 $50,000 * (76/91) * 0.005 = $208.79

If a Client adds money, his end of quarter fees for the portion of funds added will be charged at

a pro-rated rate from the day funds were added till the end of the quarter using 91 days as the

length of the quarter.

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Example of fees for Client adding funds in the middle of the quarter:

Timing of addition Amount added Additional Adviser Fees to be paid at the end of the quarter

May 30th start of day $50,000 $50,000 * (32/91) * 0.005 = $87.91

June 15th start of day $50,000 $50,000 * (16/91) * 0.005 = $43.96

2. Daily Flat Fee Option

Interactive Brokers, LLC will automatically deduct Advisory fees at the end of each trading day

at an annualized rate of 2%. Trading days exclude all weekends and stock exchange holidays.

Interactive Brokers, LLC uses a base of 252 trading days in a year and will withdraw 0.007937%

(2% divided by 252) of account value (defined as “Net Liquidation Value”) at the end of every

trading day.

Since Advisory fees are withdrawn on a daily basis, no pro-rated fee calculation is required

when adding or withdrawing funds under this option.

Example of Fees charged under Daily Flat Fee Option:

Date Net Account Value Adviser Fees

Jan 5th $100,000 $100,000 * (2%/252) = $7.94

Jan 6th $101,000 $101,000 * (2%/252) = $8.02

Jan 7th $102,000 $102,000 * (2%/252) = $8.10

The quarterly and daily flat fee may be negotiable per the discretion of the Adviser.

6. Performance Based Fees

Clients who are under the flat fee structure described earlier do not pay any performance fees.

Pursuant to “Investment Advisers Act of 1940”, this fee structure can be offered only to a

“Qualified Client” – defined as a Client with

a) At least $1 million under the management of Affluo, LLC or

b) At least than $2 million net worth, excluding the value of the primary residence, at the

time of signing this agreement.

A “Qualified Client” could enter a 0/20% performance fee structure which means no flat

management fee as percentage of Client assets under management and a 20% performance

fee.

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The performance fee is charged quarterly, based on gains from quarter to quarter, and is

deducted from the client account, unless the Client has elected to be billed separately. The

gains are calculated based on the increase in the account value inclusive of all brokerage fees,

commissions, capital gains, dividends and interest.

For example, assume an account started with $100,000. It gained $5,000 in the form of capital

gains. It earned $2,000 from dividends and interest. It paid $500 in various brokerage fees and

commissions. The ending account value used in the calculation will be $100,000 + $5000 (gains)

+ $2000 (dividends and interest) - $500 (fees and commissions) = $106,500.

Assuming no withdrawals by the Client, if there are any losses incurred in the quarter, these

losses are carried forward indefinitely until sufficient profits are generated to cover the

previously generated losses. During a loss period, no fees are collected.

The way these losses are carried forward is by tracking a High Water Mark for the Client

Account. The High Water Mark is the highest value of an account on any valuation date, where

the valuation dates are account inception, the end of each calendar quarter or any date on

which the Client deposits or withdraws funds.

Example of 0/20% performance fee structure for a Client Account opened on Jan 1st with

$100,000; therefore, High Water Mark at account opening is $100,000:

Date Net Account Value (NAV)

Client Account NAV High Water Mark

Account Profit Performance = NAV – Previous High Water Mark

Adviser Fees

March 31st $100,000 $100,000 $100,000 - $100,000 = $0 $0

June 30th $110,000 $110,000 $110,000 - $100,000 = $10,000 $10,000 * 20% = $2,000

September 30th

$105,000 $110,000 $105,000 - $110,000 = -$5,000 $0

December 31st

$115,000 $115,000 $115,000 - $110,000 = $5,000 $5,000 * 20% = $1,000

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Example of fees and how the high water mark is adjusted based on additions:

If Clients want to add funds before the quarter ends, they are charged the performance fee

based on gains till the day of addition relative to the previous High Water Mark. The High Water

Mark is increased by the amount of the addition. At the end of the quarter, the performance

fee calculation will take place based on this new High Water Mark.

Example 1: An addition of $10,000 to an account with gains in the middle of the quarter:

Account opened on Jan 1st with $100,000; therefore high water mark at inception is

$100,000

$10,000 added on July 31st. Pre-addition, Account Value on July 31st was $120,000

o Pre-addition, High Water Mark set at $120,000

o $10,000 added.

o Post-addition, High Water Mark reset at $120,000 + $10,000 = $130,000




Adviser Fees

March 31st $100,000 $100,000 $100,000 - $100,000 = $0 $0

June 30th $110,000 $110,000 $110,000 - $100,000 = $10,000

$10,000 * 20% = $2,000

July 31st pre-addition

$120,000 $120,000 $120,000 - $110,000 = $10,000

$10,000 * 20% = $2,000

July 31st post-addition

$130,000 $130,000 n/a n/a

September 30th

$135,000 $135,000 $135,000 - $130,000 = $5,000 $5,000 * 20% = $1,000

December 31st

$135,000 $135,000 $135,000 - $135,000 = $0 $0

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Example 2: An addition of $10,000 to an account with losses in the middle of the quarter:


$100,000

$10,000 added on July 31st. Pre-addition, account value on July 31st was $90,000.

o Pre-addition, assume High Water Mark set at $110,000

o $10,000 added.

o Post-addition, High Water Mark reset at $110,000 + $10,000 = $120,000




Adviser Fees

March 31st $100,000 $100,000 $100,000 - $100,000 = $0 $0

June 30th $110,000 $110,000 $110,000 - $100,000 = $10,000

$10,000 * 20% = $2,000


$90,000 $110,000 $90,000 - $110,000 = -$20,000

$0


$100,000 $120,000 n/a n/a

September 30th

$110,000 $120,000 $110,000 - $120,000 = -$10,000

$0

December 31st

$125,000 $125,000 $125,000 - $120,000 = $5,000 $5,000 * 20% = $1,000

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Example of fees and how the high water mark is adjusted based on withdrawals:

If Clients want to withdraw money before the quarter ends, they are charged the performance

fee based on gains till the day of withdrawal relative to the previous High Water Mark. The High

Water Mark is decreased proportionately to the amount of the withdrawal. At the end of the

quarter, the performance fee calculation will take place based on this new High Water Mark.

Example 1: A withdrawal of 50% of an account with gains in the middle of the quarter:


$100,000

50 % of Account withdrawn on July 31st. Pre-withdrawal, assume Account Value on July

31st was $120,000.

o Pre-withdrawal, assume High Water Mark set at $120,000

o 50% of the account withdrawn i.e. 50% * $120,000 = $60,000 withdrawn.

o Post-withdrawal, High Water Mark reset at 50% * 120,000 = $60,000




Adviser Fees

March 31st $100,000 $100,000 $100,000 - $100,000 = $0 $0

June 30th $110,000 $110,000 $110,000 - $100,000 = $10,000

$10,000 * 20% = $2,000

July 31st pre-withdrawal

$120,000 $120,000 $120,000 - $110,000 = $10,000

$10,000 * 20% = $2,000

July 31st post-withdrawal

$60,000 $60,000 n/a n/a

September 30th

$65,000 $65,000 $65,000 - $60,000 = $5,000 $5,000 * 20% = $1,000

December 31st

$65,000 $65,000 $65,000 - $65,000 = $0 $0

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Example 2: A withdrawal of 50% of an account with losses in the middle of the quarter:

Account opened on Jan 1st with $100,000; therefore, high water mark at inception is

$100,000

50 % of Account withdrawn on July 31st. Pre-withdrawal, assume Account Value on July

31st was $90,000

o Pre-withdrawal, assume High Water Mark set at $110,000

o 50% of the account withdrawn i.e. 50% * $90,000 = $45,000 withdrawn.

o Post-withdrawal, High Water Mark reset at 50% * 110,000 = $55,000




Adviser Fees

March 31st $100,000 $100,000 $100,000 - $100,000 = $0 $0

June 30th $110,000 $110,000 $110,000 - $100,000 = $10,000

$10,000 * 20% = $2,000


$90,000 $110,000 $90,000 - $110,000 = -$20,000

$0


$45,000 $55,000 n/a n/a

September 30th

$60,000 $60,000 $65,000 - $55,000 = $5,000 $5,000 * 20% = $1,000

December 31st

$65,000 $65,000 $65,000 - $60,000 = $5,000 $5,000 * 20% = $1,000

The performance fee may be negotiable per the discretion of the Adviser.

Side-By-Side Management

Both the asset based and performance based fee accounts will be treated in exactly the same

way as Simple Managed accounts under a single Master trading account. The same trades will

be executed in both types of accounts. The trade allocation will be done proportionally based

on account value. The only distinction in trades will be in IRA and non-IRA accounts due to the

restriction of short selling in IRA accounts. From a trading perspective, there will be no

distinction between asset based and performance fee based accounts.

For both, asset based fee and performance based fee accounts, our incentives are aligned to

grow account value in absolute terms with managed risk exposure.

Affluo, LLC


7. Types of Clients and Account Sizes

Affluo, LLC accepts individuals, including high net worth individuals, corporations and business

entities as Clients.

We also accept Clients who are capable of opening, funding and maintaining a margin account

with Interactive brokers, LLC. Although we do not plan to buy positions on margin, Interactive

Brokers, LLC requires margin accounts to enable shorting.

The recommended minimum account size is $30,000 but is not mandated.

8. Methods of Analysis, Investment Strategies and Risk of Loss

A. Methods of Analysis

At Affluo, LLC, we use three methods to inform our strategy.

1. Fundamental Analysis, both at a macro level and individual equity level.

2. Technical Analysis

3. Momentum Analysis

We use both individual discretion and systematic, algorithmic filtering and analysis. Individual

discretion is used in 1 and partially 2 above. Systematic, algorithmic analysis is used in part of 2

and 3 above.

At the macro level, we analyze economic data releases, and market indicators like yields,

currencies and commodities.

For individual equities, we look at company filings and current analyst expectations.

We use publicly available information resources like the Wall Street Journal, The Economist,

Financial Times, Yahoo Finance, MorningStar etc.

For algorithm development, we use a combination of Amibroker, which is a back-testing

platform and Microsoft Excel.

B. Investment Strategies

Our first and dominant goal is risk management.

The way we do this is two-fold:

1. Managing the loss exposure

We use stop losses for most positions. We will usually unwind the position if the loss on

the position exceeds 2% of account value. The typical limit placed on position specific

risk will be lower. An exception to the 2% rule is for positions in broad market index

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ETFs, such as the SPDR S&P 500 ETF (SPY). The Client should note that markets don’t

always move in smooth, linear ways. For instance, we could target a maximum 2% of

account value loss on a certain position and put in a stop loss order accordingly.

However, in the case of a “gap-down”, a severe market reaction to strongly negative

news either macro or individual, the loss may be greater than 2% as we may not get an

opportunity to exit at the preferred price.

2. Managing the position size of every position

We will use the following position sizing guidelines:

Type of Position Example Maximum Position Size (% of Account Value)

Typical Position Size Range (% of Account Value)

Individual Equity Apple (AAPL) 10% 0.05-7%

Commodity ETF SPDR Gold Shares ETF (GLD) 20% 0.05-7%

Industry Specific ETF

SPDR S&P Pharmaceuticals ETF (XPH) 25% 10-20%

Broad Market Index ETF

SPDR S&P 500 ETF (SPY) 50% 10-20%

Option on Individual Equity

Oct 18, 2014 Call on AAPL with a strike price of $700

2% 0.5-1.5%

Option on Index ETF

Oct 18, 2014 Call on SPY with a strike price of $184

3% 1-2%

Should we, in certain cases, decide to exceed these guidelines, we will do so only after checking

with the Client. Client accounts may remain in cash for long periods of time if we do not detect

good opportunities. If we feel stocks are overvalued or that economic conditions are

deteriorating, we may initiate short positions or buy put options or inverse ETFs to generate

returns in a bearish market. We may also use option strategies to hedge or limit our downside

risk.

We employ both macro and individual equity strategies.

For macro, we will take positions in index ETFs or index options. The choice of ETFs or options

will depend on risk management.

Affluo, LLC


For individual equities, we will take positions in the underlying stock or equity options. The

choice of options or stock will depend on risk management, availability and liquidity of options

in the underlying stock.

C. Risk of Loss

Investing in securities always involves risk and the possibility of losing money, which our

Clients should be ready to bear. If losing part of capital invested is not a viable option, then

the Client should reduce the capital set aside to invest or consider not investing at all. We go

through this evaluation and discussion in our Client Qualification Exercise.

Although we will try to limit our losses on individual positions, we could suffer successive

losses on multiple positions which could increase the total loss in the portfolio. In securities

and asset management, past performance is no guarantee of future performance. There is a

possibility that the strategies we employ might lose money even if the general market is up

or roughly level i.e. range-bound.

There are two broad types of risks:

1. Those inherent in any form of trading or investing in the securities markets. An example

of this is the risk of any disaster or broad emergency.

2. Those that are due to the specific investment strategies, sources and tools that we use.

An example of this is when we believe a stock will appreciate in value but the stock does

the opposite.

Risk from Information and Data Resources

For some of our strategies we make quick decisions based on new information released, one of

the main risks involved is that we might interpret the information incorrectly or in some rare

circumstances, the news source may release incorrect information. Such calculations may be

wrong in circumstances where the information released is incorrect. We may not be able to

recoup losses once this data is corrected.

Also, our algorithmic filtering uses historical price data that is adjusted for splits and dividends.

However, if the data from the data provider is erroneous or the period for which the data is

used is not representative of current conditions, it could lead to a sub-optimal algorithm.

Risk from shorting stocks

Shorting a stock is a strategy which generates a profit when a stock falls below the price at

which the short position is initiated (ignoring transaction costs). The risk with shorting is that

you lose money when a stock rises in value. Since a stock can have an increase of more than

Affluo, LLC


100%, you can lose more than your initial investment in that position. If the risk in these

positions is not constantly monitored and managed, one can possibly lose many multiples of

the initial investment in that position.

Risks of trading options

When purchasing an option, the option could expire worthless and cause a complete loss of the

investment. Unlike stocks, options have an expiration date. When purchasing an option, one

has to not only get the direction of the security price movement correct, but also the time

frame in which such a move should occur. Options in certain securities are not very liquid i.e.

the trading volumes could be very low. Therefore initiating and unwinding the position at a

favorable price may not be easy. Also volatility of option prices is usually higher than the

underlying, making it a risker investment

Risk of trading inverse ETFs

Inverse ETFs are similar to shorting. They rise in value when the underlying index falls in value.

One difference between shorting and buying an inverse ETF is that in an inverse ETF you can

only lose the amount that has been invested. Inverse ETFs track only the daily inverse

performance of an index and are rebalanced daily. That means over a longer period of time,

they will have a tracking error to the index. For example, if the S&P 500 falls 20% over a 1 year

period, the corresponding inverse ETF may not rise by 20% over the year; it may only rise by

18%.

Risk of trading leveraged ETFs

Leveraged ETFs aim to magnify the movement of the underlying. For example, a 2x leveraged

ETF aims to magnify by 2x the gain of the underlying. However, when the underlying loses

value, the leveraged ETF will typically lose value at 2x that rate.

Therefore, these are riskier investments than the unlevered ETFs.

9. Disciplinary Information There are no legal or disciplinary actions or outstanding judgments against Affluo, LLC or

Hemang S. Bhojani, the portfolio manager and founder of the company.

10. Other Financial Industry Activities and Affiliations Affluo, LLC has no financial industry activities or affiliations that require disclosure.

Affluo, LLC


Affluo, LLC requires an account with Interactive Brokers, LLC for most of our accounts due to

our independent determination that they have the best and most cost effective platform to

execute our strategies. We do not have any affiliation with Interactive Brokers, LLC.

11. Code of Ethics, Participation of Interest in Client Transactions and

Personal Trading

Code of Ethics

Affluo, LLC has adopted the following code of Ethics:

1. Place the interests of our Clients ahead of our own

2. Invest substantially along with our Clients using the same strategies for our own money

3. Tell the truth as we see it

4. Act with integrity, competence and respect

5. Keep our Client information confidential

6. Deliver the best of our Firm to every Client for the highest net value that we can deliver.

7. Obey all applicable laws and regulations and avoid any conduct or activity which may

cause harm to the Firm or its Clients or call either reputation into question.

Personal Trading and Conflicts of Interest

Hemang S. Bhojani will maintain a personal trading account under the Master trading account

at Interactive brokers, LLC along with client accounts. So, he will participate in buying and

selling the same securities as client accounts. His orders will be bundled along with client orders

through the Master account, so his orders will get the same execution preference as client

accounts.

He might take a greater risk in his personal account relative to client accounts.

Hemang might also have other accounts which are not part of the Master account. In those

accounts, he will not trade ahead of client trades in case he is executing a similar strategy as the

Client accounts.

There could be a conflict of interest in situations where different time frames of holding

securities are concerned or where he is testing different investing strategies on his own

separate account. For instance, it is possible that he could be holding a long position a certain

security in a personal longer term investment account but could take a short position for Clients

on the same security for a shorter term time horizon (although, in such situations, his own

personal account under the Interactive Brokers, LLC Master account would also be trading

along with client accounts). Similarly, he could be testing different investment strategies that

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are still in development due to which he may take a certain position in a certain security in his

test accounts but could hold a contrary position in the same security in the Master Account

(although here too, his personal account under the Master Account would be treated in the

same manner as other Clients).

12. Brokerage Practices Affluo, LLC has selected Interactive Brokers, LLC as the broker/dealer based on an independent

analysis that Interactive Brokers, LLC provides the best platform to execute our strategies at

very low cost commissions. Not all Investment Advisers require/recommend specific

broker/dealers.

Affluo, LLC does not receive any soft dollars from Interactive Brokers, LLC for client

transactions. Any trading or research service offered to us from Interactive Brokers, LLC is

available to all of their retail and professional Clients.

Interactive Brokers, LLC’s CRD number is 36418.

13. Review of Accounts Affluo, LLC will monitor its Master Account on a daily basis thus indirectly monitoring Client

Accounts on a daily basis. We will monitor all our positions and determine the risk of our

positions and review whether they are still worth maintaining and comply with our trading

strategies based on latest market information.

In addition, Hemang S. Bhojani, President and Portfolio Manager will look at each Client

Account individually on a monthly basis to review performance.

Clients themselves can look at their individual account at Interactive Brokers, LLC at any time.

Interactive Brokers, LLC provides our Clients the ability to generate detailed reports for their

accounts on a daily, weekly, monthly, yearly and on a custom date range basis. Annual reports

for tax accounting are also provided to Clients by Interactive Brokers, LLC. Clients should

periodically review their statements carefully and contact us if they have any issues they want

to discuss.

14. Client Referrals and Other Compensation If we refer our Clients to another adviser or recommend a financial service, it will be done

based on an objective analysis that it will serve the best interests of our Clients. We do not

receive any compensation or any material benefit for referring Clients.

Affluo, LLC


Affluo, LLC does not offer any compensation to anyone who might refer Clients to us.

15. Custody Affluo, LLC does not maintain custody of client accounts. The custody of client accounts is with

the brokerage firm or a custodian of the Client’s choice.

16. Investment Discretion When Clients sign up with Interactive Brokers, LLC and choose a financial adviser they have to

sign a limited power of attorney for the financial Adviser. The limited power of attorney gives

Affluo, LLC the following authority:

Discretionary authority to trade securities in the Client’s account

Deduct Advisory fees based on a fee arrangement that has been agreed upon and

specified by Client to Interactive Brokers

Initiate deposit and withdrawal actions from Client account for only the benefit of the

Client and only between accounts which have been specified by the Client to Interactive

Brokers, LLC. Clients can technically curb this authority by not specifying any outside

accounts to Interactive Brokers, LLC.

Clients can also specify whether they want to limit shorting in their accounts.

17. Voting Client Securities The Client is responsible for proxy voting for shares they hold in their accounts

18. Financial Information No disclosure of financial information is required because Affluo, LLC does not have custody of

Client accounts and does not require prepayment of any fees.

19. Requirements for State-Registered Advisers

Principal Executive Officers

Hemang S. Bhojani (CRD # 6286159) is the Founder, President and Portfolio Manager at Affluo,






Affluo, LLC







class.


then.

He started Affluo, LLC to offer Clients an alternative method to the traditional buy-and-hold

method of investment. His methods have a greater focus on always tracking and managing risk

exposure.

Disciplinary Information

Hemang S. Bhojani has not been involved in any legal or disciplinary event.

Further information about Hemang S. Bhojani is specified below in the Brochure supplement -

form ADV part 2B

Affluo, LLC


Hemang S. Bhojani March 31, 2017 Version 1.3

Form ADV Part 2-B Brochure Supplement This brochure supplement provides information about Hemang S. Bhojani

that supplements the Affluo, LLC brochure. You should have received a

copy of that brochure. Please contact Hemang S. Bhojani, the President of

Affluo, LLC at (718)-473-9837 or [email protected] if you did

not receive Affluo, LLC’s brochure or if you have any questions about the

contents of this supplement.

Additional information about Hemang S. Bhojani is available on the SEC’s

website at www.adviserinfo.sec.gov. The CRD number to search

information for Hemang S. Bhojani is 6286159.

Affluo, LLC 2401 Deer Pass, Austin, TX 78746 Tel: 718 473 9837 Fax: 801 881 7967 Email: [email protected]

mailto:[email protected]

http://www.adviserinfo.sec.gov/

mailto:[email protected]

Affluo, LLC


2. Educational Background and Business Experience Hemang S. Bhojani (CRD # 6286159) is the Founder, President and Portfolio Manager at Affluo,











class.


then.

He was born in 1975.

3. Disciplinary Information Hemang S. Bhojani has not been involved in:

A. Any criminal or civil action in a domestic, foreign or military court of competent

jurisdiction.

B. Any proceeding before the SEC, any other federal regulatory agency, any state

regulatory agency, or any foreign financial regulatory authority.

C. Any self-regulatory organization (SRO) proceeding.

D. Any other hearing or formal adjudication in which a professional attainment,

designation or license was revoked or suspended because of a violation of rules relating

to professional conduct. Neither did he resign or relinquish the attainment, designation

or license in anticipation of such a hearing of formal adjudication.

Affluo, LLC


4. Other Business Activities Hemang S. Bhojani is not

A. Registered or has an application pending to register, as a broker-dealer, registered

representative of a broker-dealer, futures commission merchant (“FCM”), commodity

pool operate(“CPO”), commodity trading advisor (“CTA”), or an associated person of an

FCM, CPO, or CTA.

B. Engaged in any other business activity or occupation for compensation.

5. Additional Compensation Hemang S. Bhojani receives no additional compensation from someone who is not a Client of

Affluo, LLC.

6. Supervision The sole supervisory authority for Affluo, LLC is Hemang S. Bhojani. Hemang S. Bhojani is the

President and Portfolio Manager for Affluo, LLC and can be contacted at 718-473-9837. He is

responsible for the fiduciary obligations of Affluo, LLC.

7. Requirements for State Registered Advisers A. Hemang S. Bhojani has not been involved in

1. Any award or otherwise being found liable in an arbitration claim alleging

damages in excess of $2,500.

2. Any award of otherwise being found liable in a civil, self-regulatory organization,

or administrative proceeding.

B. Hemang S. Bhojani has not been the subject of a bankruptcy petition.

Documents

Form ADV Part 2-A: Brochure - Affluo, LLCaffluo.com/wp-content/uploads/2018/04/Form-ADV-Part-II-v1.3b.pdf · Hemang S. Bhojani (CRD # 6286159) is the Founder, President and Portfolio