Legal

Agreement Overview

These Terms of Service (the "Terms," "Agreement," or "TOS") constitute a legally binding agreement between you ("Client," "you," or "your") and Lendori ("Company," "we," "us," or "our") regarding your use of our investment management services.

By opening an account, accessing our platform, or using any of our services, you acknowledge that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, and all applicable laws and regulations. If you do not agree to these Terms, you may not use our services.

IMPORTANT: This Agreement contains provisions that limit our liability and require arbitration of disputes. Please read these Terms carefully before opening an account.

Acceptance and Modifications

Acceptance of Terms

You accept these Terms by:

• Completing the account registration process
• Electronically signing the Investment Management Agreement
• Funding your account
• Using any Lendori services or features

Right to Modify

Lendori reserves the right to modify these Terms at any time. We will notify you of material changes by:

• Sending notice to your registered email address at least 30 days before changes take effect
• Posting notice on our website and in your account dashboard
• Requiring your acknowledgment for significant changes that materially affect your rights

Your continued use of our services after the effective date of modified Terms constitutes your acceptance of the changes. If you do not agree to the modified Terms, you may close your account in accordance with the termination provisions below.

Eligibility Requirements

To open an account with Lendori, you must meet all of the following requirements:

Age and Legal Capacity

• You must be at least 18 years of age (or the age of majority in your jurisdiction)
• You must have the legal capacity to enter into binding contracts
• You must not be subject to any legal disability that would prevent you from managing your financial affairs

Residency and Jurisdiction

• You must be a U.S. citizen or legal permanent resident with a valid Social Security Number or Tax ID
• You must have a physical U.S. address (P.O. boxes not accepted for primary address)
• You must not be a resident of a jurisdiction where our services are prohibited

Financial Requirements

• You must meet the minimum initial investment of $2,000
• You must have a valid U.S. bank account for deposits and withdrawals
• You must provide accurate financial information for suitability determination

Prohibited Persons

You may not open an account if you:

• Are located in, or a resident of, a country subject to U.S. economic sanctions
• Appear on any U.S. government list of prohibited or restricted parties (OFAC, SDN list)
• Have been convicted of securities fraud or financial crimes
• Have been barred or suspended from securities industry by any regulatory authority
• Have previously had a Lendori account terminated for cause

Account Opening and Registration

Application Process

To open an account, you must:

1. Complete Application: Provide all required personal, financial, and employment information accurately and completely
2. Identity Verification: Submit government-issued photo ID and pass identity verification checks
3. Risk Assessment: Complete our investment questionnaire to determine your risk profile (Conservative, Moderate, or Growth)
4. Review Disclosures: Review and acknowledge all required disclosures, including Form ADV Part 2
5. Sign Agreement: Electronically sign the Investment Management Agreement
6. Fund Account: Make an initial deposit of at least $2,000 via bank transfer

Account Approval

Lendori reserves the right to:

• Approve or reject any account application in our sole discretion
• Request additional information or documentation before approving an account
• Delay account opening pending completion of verification procedures
• Refuse service to any person for any reason not prohibited by law

Account approval typically takes 24-48 hours after we receive all required information and documentation.

Account Types

We offer the following account types:

• Individual Accounts: Accounts owned by one person
• Joint Accounts: Accounts with two or more owners (joint tenants with rights of survivorship or tenants in common)
• Retirement Accounts: Traditional IRA, Roth IRA, SEP IRA, SIMPLE IRA (subject to additional requirements)
• Trust Accounts: Accounts held by trustees (requires trust documentation)
• Entity Accounts: Accounts for corporations, LLCs, partnerships (requires formation documents and authorization)

Account Responsibilities

As an account holder, you are responsible for:

• Accuracy of Information: Providing true, accurate, complete, and current information
• Updates: Promptly updating your information when it changes (address, employment, financial situation, investment objectives)
• Security: Maintaining the confidentiality of your login credentials
• Monitoring: Regularly reviewing your account statements and confirming accuracy
• Unauthorized Access: Immediately notifying us of any unauthorized account access or suspicious activity
• Account Activity: All activity that occurs under your account, whether authorized or unauthorized

Security Best Practices:

• Use a strong, unique password and enable two-factor authentication
• Never share your login credentials with anyone
• Log out after each session, especially on shared devices
• Keep your email account secure as it is used for password resets
• Be wary of phishing attempts requesting your account information

Investment Management Services

Discretionary Authority

By opening an account with Lendori, you grant us full discretionary authority to manage your investment portfolio. This means we have the authority to:

• Make all investment decisions without prior consultation with you
• Buy, sell, and hold securities in your account across four asset categories: stocks, options, dividend ETFs, and forex
• Determine the timing, size, and allocation of investments
• Rebalance your portfolio monthly and make tactical adjustments as needed
• Select specific securities, options strategies, ETFs, and currency pairs
• Execute all transactions on your behalf

Important: Our discretionary authority means you cannot direct specific investments, request specific trades, or override our investment decisions. This is a fully managed service, not a self-directed platform.

Investment Strategy

Lendori employs systematic, diversified investment strategies across four asset categories:

• Stocks (Equities): Individual stock positions selected through fundamental and technical analysis for growth and value opportunities
• Options: Derivative strategies including covered calls, protective puts, and spreads for income generation and risk management
• Dividend ETFs: Exchange-traded funds focused on dividend-paying stocks for income and diversification
• Forex (Foreign Exchange): Major G10 currency pairs for diversification and returns from currency movements

Your specific allocation across these categories is determined by your risk profile:

• Conservative: 20-30% stocks, 5-10% options, 30-40% ETFs, 5-10% forex, remainder in cash/equivalents
• Moderate: 30-40% stocks, 10-15% options, 25-30% ETFs, 5-15% forex, remainder in cash/equivalents
• Growth: 40-60% stocks, 15-25% options, 15-25% ETFs, 10-20% forex, remainder in cash/equivalents

Actual allocations may vary based on market conditions and available opportunities. We reserve the right to hold positions in cash or cash equivalents when we determine it is in your best interest.

Portfolio Rebalancing

Your portfolio is systematically rebalanced monthly to maintain optimal allocation. Rebalancing involves:

• Selling positions that have grown beyond target allocation
• Buying positions that have fallen below target allocation
• Adjusting for deposits and withdrawals
• Capturing gains from strong performers
• Adding to quality positions that have declined in value

In addition to monthly rebalancing, we actively monitor all positions daily and may make tactical adjustments based on market conditions, risk management, or strategic opportunities.

Suitability and Best Interest

Lendori acts as a fiduciary and is obligated to:

• Act in your best interest at all times
• Provide investment advice that is suitable for your financial situation, investment objectives, and risk tolerance
• Disclose material conflicts of interest
• Seek best execution for all transactions
• Charge reasonable fees for our services

We determine suitability based on information you provide in your account application and investment questionnaire. You are responsible for ensuring this information is accurate and updated when your circumstances change.

Fees and Expenses

Management Fees

Lendori charges an annual management fee for our investment services. Fee schedules are tiered based on account size:

• $2,000 - $25,000: 2.5% annually
• $25,001 - $100,000: 2.0% annually
• $100,001 - $500,000: 1.75% annually
• $500,001 and above: 1.5% annually (with potential for negotiated rates)

Fee Calculation and Billing

• Calculation Method: Fees are calculated monthly based on your average daily account value for the month
• Deduction: Fees are automatically deducted from your account at the end of each month
• Pro-Rata: Fees for partial months are pro-rated based on the number of days your account was open
• Blended Rates: If your account balance increases to a higher tier, you will be charged the blended rate on the total account value

Example: For an account with an average monthly value of $50,000 in the $25,001-$100,000 tier, the monthly fee would be approximately $83.33 ($50,000 × 2.0% ÷ 12 months).

Performance Fees

In addition to management fees, Lendori may charge performance fees on returns exceeding certain benchmarks:

• High-Water Mark: Performance fees are only charged on net new profits above the previous highest account value
• Hurdle Rate: Performance fees apply only to returns exceeding 10% annually
• Performance Fee Rate: 20% of profits above the hurdle rate
• Calculation: Performance fees are calculated and charged quarterly

Example: If your account grows 15% in a year (5% above the 10% hurdle), the performance fee would be 20% of the 5% excess return.

Other Fees and Expenses

• Underlying Fund Expenses: ETFs held in your portfolio have internal expense ratios (typically 0.08% to 0.40% annually). These fees are not charged by Lendori but are embedded in the ETF's net asset value.
• Transaction Costs: While we do not charge commissions, there may be small regulatory fees or exchange fees on certain transactions (typically $0.01 to $0.05 per transaction)
• Wire Transfer Fees: Outgoing domestic wire transfers: $25; International wires: $45
• Account Closure Fee: None - accounts can be closed at any time without penalty
• Inactivity Fee: None

Fee Transparency

All fees charged to your account are clearly disclosed in your monthly statements. You can view a detailed breakdown of fees in your account dashboard at any time.

Fee Changes

Lendori reserves the right to change fee schedules with 30 days' advance notice. Fee increases will require your consent. If you do not agree to increased fees, you may close your account without penalty.

Deposits and Withdrawals

Deposits

Accepted Methods:

• ACH Bank Transfer: Free, typically processed in 3-5 business days
• Wire Transfer: Same or next business day, may incur bank fees
• Check Deposits: 5-10 business days for clearance

Deposit Requirements:

• Deposits must come from a U.S. bank account in your name
• Initial deposit must meet the $2,000 minimum
• Subsequent deposits have no minimum amount
• All deposits are subject to verification and anti-money laundering screening

Investment Timeline: Once a deposit clears, funds are typically allocated to your portfolio within 24-48 hours according to your risk profile.

Withdrawals

Withdrawal Process:

• Log in to your account and navigate to "Withdrawals"
• Enter the withdrawal amount and confirm your bank details
• Submit your withdrawal request
• Funds are typically transferred within 3-5 business days

Withdrawal Restrictions:

• Minimum Balance: You must maintain at least $2,000 in your account. Withdrawals bringing your balance below $2,000 will result in account closure.
• Settlement Period: Withdrawals may be delayed if you have unsettled trades (typically T+2 for stocks, T+1 for options)
• Verification: Large withdrawal requests may require additional verification
• Frequency: No limit on number of withdrawals, but frequent large withdrawals may impact portfolio performance

Full Account Closure: To close your account and withdraw all funds, contact our info team. We will liquidate all positions, allow trades to settle, deduct any outstanding fees, and transfer the remaining balance to your bank account within 5-7 business days.

Failed Transactions

If a deposit fails (e.g., insufficient funds), you are responsible for any fees charged by your bank. If a withdrawal fails (e.g., incorrect bank information), please contact info to update your information and resubmit the request.

Risks and Disclaimers

Investment Risks

ALL INVESTMENTS INVOLVE RISK. YOU MAY LOSE SOME OR ALL OF YOUR INVESTED CAPITAL.

Specific risks associated with your Lendori portfolio include:

• Market Risk: Securities prices fluctuate based on economic conditions, company performance, and market sentiment. Your portfolio value will rise and fall.
• Equity Risk: Stock investments may decline in value, and companies may reduce or eliminate dividends.
• Options Risk: Options are complex derivatives that can result in total loss of premium paid. Selling options exposes you to potentially unlimited losses if markets move against your position.
• ETF Risk: ETFs are subject to the risks of their underlying holdings and may trade at premiums or discounts to net asset value.
• Currency Risk: Forex positions involve leverage and can result in rapid losses. Currency prices are influenced by economic data, geopolitical events, and interest rate changes.
• Leverage Risk: Options and forex positions involve leverage, which magnifies both gains and losses.
• Liquidity Risk: Some investments may be difficult to sell quickly without significantly impacting price.
• Concentration Risk: Over-concentration in any sector, security, or strategy increases risk.
• Regulatory Risk: Changes in laws or regulations may adversely affect investments.

No Guarantees

Lendori makes no guarantees regarding investment performance. Specifically:

• Past performance does not guarantee future results
• Target returns are goals, not promises
• No specific level of performance or return is guaranteed
• Your actual results may be higher or lower than any stated targets
• Different time periods will yield different returns
• Individual results will vary based on timing of deposits, withdrawals, and market conditions

Not FDIC Insured

YOUR ACCOUNT IS NOT A BANK ACCOUNT AND IS NOT FDIC INSURED. Securities held in your account are protected by SIPC up to $500,000 (including up to $250,000 for cash), but SIPC does not protect against investment losses due to market declines.

Tax Implications

Investment transactions may have tax consequences. You are responsible for:

• Consulting with your tax advisor regarding the tax treatment of your investments
• Paying all applicable taxes on investment income and gains
• Providing accurate tax information (W-9 form)
• Reporting investment income on your tax returns

Lendori will provide Form 1099 reporting your annual investment income and gains, but we do not provide tax advice. Portfolio rebalancing and trading may generate taxable events throughout the year.

Prohibited Activities

You agree not to:

• Market Manipulation: Engage in or attempt to manipulate markets, prices, or trading activity
• Fraud: Provide false information, impersonate others, or engage in fraudulent activity
• Money Laundering: Use Lendori services for money laundering or terrorist financing
• Illegal Activities: Use your account for any illegal purpose or in violation of any laws
• Unauthorized Access: Access or attempt to access accounts that do not belong to you
• System Interference: Interfere with or disrupt our systems, servers, or networks
• Reverse Engineering: Reverse engineer, decompile, or attempt to derive source code from our platform
• Data Mining: Use automated tools to access, scrape, or collect data from our platform
• Multiple Accounts: Open multiple accounts to circumvent limits or requirements

Violation of these prohibitions may result in immediate account termination, forfeiture of funds, and referral to law enforcement.

Account Termination and Suspension

Termination by You

You may close your account at any time by:

• Contacting our info team to request account closure
• Providing written notice via email to info@lendori.finance

Upon termination request, we will liquidate all positions, allow trades to settle, deduct outstanding fees, and transfer the remaining balance to your bank account within 5-7 business days.

Termination by Lendori

We reserve the right to terminate or suspend your account immediately, with or without notice, if:

• You violate these Terms or any applicable law
• You provide false or misleading information
• Your account is involved in fraudulent or suspicious activity
• You fail to maintain the minimum balance of $2,000
• Your account poses a risk to Lendori or other clients
• We are required to do so by law or regulation
• We determine, in our sole discretion, that continuing the relationship is not in our best interest

Effect of Termination

Upon termination:

• Your access to the platform will be revoked
• All outstanding fees and expenses will be deducted
• Remaining funds will be returned to you (subject to any legal holds)
• You remain responsible for any obligations incurred before termination
• Provisions of these Terms that by their nature should survive termination will continue to apply

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

• Lendori'S TOTAL LIABILITY TO YOU FOR ANY CLAIMS RELATED TO OUR SERVICES SHALL NOT EXCEED THE AMOUNT OF MANAGEMENT FEES YOU PAID IN THE 12 MONTHS PRECEDING THE CLAIM
• WE ARE NOT LIABLE FOR ANY INVESTMENT LOSSES, INCLUDING LOSSES DUE TO MARKET DECLINES, VOLATILITY, OR POOR INVESTMENT PERFORMANCE
• WE ARE NOT LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES
• WE ARE NOT LIABLE FOR DAMAGES ARISING FROM YOUR BREACH OF THESE TERMS
• WE ARE NOT LIABLE FOR TECHNICAL ISSUES, SYSTEM DOWNTIME, OR SERVICE INTERRUPTIONS BEYOND OUR REASONABLE CONTROL

This limitation applies to all claims, whether based on contract, tort, negligence, strict liability, or any other legal theory.

Indemnification

You agree to indemnify, defend, and hold harmless Lendori, its affiliates, officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including attorneys' fees) arising from:

• Your violation of these Terms
• Your violation of any law or regulation
• Your violation of any third-party rights
• Your account activity or investment decisions
• Unauthorized use of your account
• Any misrepresentation made by you

Dispute Resolution and Arbitration

Mandatory Arbitration

PLEASE READ THIS CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

You and Lendori agree that any dispute, claim, or controversy arising out of or relating to these Terms or your use of our services will be resolved through binding arbitration rather than in court, except that:

• Either party may bring claims in small claims court if they qualify
• Either party may seek injunctive or equitable relief in court to protect intellectual property rights

Arbitration Procedures

• Administrator: Arbitration shall be administered by FINRA Dispute Resolution or the American Arbitration Association (AAA)
• Rules: Arbitration shall be conducted under the applicable arbitration rules
• Location: Arbitration shall take place in [City, State] or a mutually agreed location
• Costs: Each party shall bear its own costs and attorneys' fees unless the arbitrator awards them to the prevailing party
• Award: The arbitrator's decision is final and binding and may be entered as a judgment in any court of competent jurisdiction

Class Action Waiver

YOU AND Lendori AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE ACTION. Unless both parties agree otherwise, the arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding.

Right to Opt-Out

You may opt out of this arbitration agreement by sending written notice to Lendori within 30 days of opening your account. If you opt out, you and Lendori will not be bound by this arbitration provision, but all other Terms will continue to apply.

Governing Law and Jurisdiction

These Terms are governed by the laws of the State of [State], without regard to conflict of law provisions. For any disputes not subject to arbitration, you consent to the exclusive jurisdiction of the state and federal courts located in [City, State].

Miscellaneous Provisions

Entire Agreement

These Terms, together with our Privacy Policy and any other agreements referenced herein, constitute the entire agreement between you and Lendori regarding our services and supersede all prior agreements and understandings.

Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will continue in full force and effect.

No Waiver

Our failure to enforce any provision of these Terms does not constitute a waiver of that provision or any other provision.

Assignment

You may not assign or transfer these Terms or your account without our prior written consent. Lendori may assign these Terms to any affiliate or in connection with a merger, acquisition, or sale of assets.

Force Majeure

Lendori is not liable for any failure or delay in performance due to circumstances beyond our reasonable control, including natural disasters, war, terrorism, labor disputes, or technical failures.

Electronic Communications

You consent to receive communications from us electronically. We will communicate with you by email or by posting notices on our website or in your account. You agree that all agreements, notices, disclosures, and other communications provided electronically satisfy any legal requirement that such communications be in writing.

What Are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, tablet) when you visit a website. Cookies allow the website to recognize your device and remember information about your visit, such as your preferred language, login status, and other settings.

Similar technologies include web beacons, pixels, tags, and local storage. For simplicity, this policy refers to all these technologies collectively as "cookies" unless otherwise specified.

Why We Use Cookies

Lendori uses cookies for several important purposes:

• Essential Functionality: Enable core features like secure login, account access, and transaction processing
• Security: Protect your account from fraud and unauthorized access
• Preferences: Remember your settings and preferences across sessions
• Performance: Analyze how our website performs and identify areas for improvement
• Analytics: Understand how visitors use our site to improve user experience
• Marketing: Deliver relevant advertising and measure campaign effectiveness (with your consent)

Types of Cookies We Use

1. Strictly Necessary Cookies

These cookies are essential for the website to function properly. They enable basic functions like page navigation, secure login, and access to protected areas. The website cannot function properly without these cookies.

Examples:

• Session Cookies: Maintain your login session and remember your authentication state
• Security Cookies: Detect fraud and protect against attacks
• Load Balancing Cookies: Distribute traffic across our servers for optimal performance

Legal Basis: These cookies are necessary for providing our service and do not require consent.

2. Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings.

Examples:

• Preference Cookies: Remember your language, region, or timezone preferences
• Accessibility Cookies: Remember accessibility settings like font size or contrast
• UI Customization: Remember your dashboard layout and display preferences

Retention: Typically 1-2 years

3. Performance and Analytics Cookies

These cookies help us understand how visitors interact with our website by collecting anonymous information about pages visited, time spent, and any errors encountered.

Examples:

• Google Analytics: Tracks website usage, traffic sources, and user behavior
• Error Tracking: Identifies technical issues and system errors
• Performance Monitoring: Measures page load times and system performance
• A/B Testing: Tests different versions of pages to improve user experience

Retention: Typically 1-2 years

Legal Basis: Your consent or legitimate interest in improving our services

4. Advertising and Marketing Cookies

These cookies are used to deliver advertisements that are relevant to you and your interests. They also limit the number of times you see an ad and help measure the effectiveness of advertising campaigns.

Examples:

• Remarketing Cookies: Show you relevant ads on other websites based on your visit to lendori.finance
• Social Media Pixels: Track interactions with social media content and ads
• Conversion Tracking: Measure the effectiveness of marketing campaigns
• Third-Party Ad Networks: Deliver targeted advertising across the internet

Retention: Typically 90 days to 2 years

Legal Basis: Your explicit consent

Third-Party Cookies

Some cookies on our site are set by third-party service providers we work with. We do not control these third-party cookies, and you should check the privacy policies of these third parties for information about their cookies.

Third-Party Services We Use

• Google Analytics: Website analytics and traffic analysis (Privacy Policy)
• Google Tag Manager: Tag and code management (Privacy Policy)
• Facebook Pixel: Social media analytics and advertising (Privacy Policy)
• LinkedIn Insight Tag: Professional network analytics (Privacy Policy)
• Hotjar: User behavior analytics and heatmaps (Privacy Policy)
• Intercom: Customer info and messaging (Privacy Policy)

Managing Your Cookie Preferences

Browser Settings

Most web browsers allow you to control cookies through their settings. You can set your browser to:

• Block all cookies
• Block only third-party cookies
• Delete cookies when you close your browser
• Alert you before accepting cookies

How to Manage Cookies by Browser:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Cookies and website data
• Edge: Settings → Cookies and site permissions → Cookies and site data

Important Note: Blocking all cookies may affect the functionality of Lendori and prevent you from accessing certain features. Strictly necessary cookies cannot be disabled if you want to use our service.

Cookie Consent Manager

When you first visit our website, you'll see a cookie consent banner allowing you to accept or reject non-essential cookies. You can change your cookie preferences at any time by:

• Clicking the "Cookie Settings" link in the footer of our website
• Accessing your cookie preferences in your account settings
• Contacting us at privacy@lendori.finance

Opt-Out Tools

You can opt out of certain third-party cookies using these tools:

• Google Analytics: Google Analytics Opt-out Browser Add-on
• Ad Personalization: Digital Advertising Alliance Opt-Out
• Do Not Track: Enable "Do Not Track" in your browser settings (though not all websites honor this)

Mobile Application Tracking

Our mobile application may use similar tracking technologies, including:

• Device Identifiers: Advertising ID (IDFA on iOS, AAID on Android)
• SDKs: Third-party software development kits for analytics and functionality
• Push Notifications: Device tokens for sending account alerts and updates

You can control mobile tracking through your device settings:

• iOS: Settings → Privacy → Tracking → Allow Apps to Request to Track
• Android: Settings → Privacy → Ads → Opt out of Ads Personalization

Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. When we make changes, we will update the "Last Updated" date at the top of this policy.

We encourage you to review this Cookie Policy periodically to stay informed about how we use cookies.

General Risk Disclosure

INVESTING IN SECURITIES INVOLVES SIGNIFICANT RISK OF LOSS.

Before investing with Lendori, you should carefully consider whether our services are suitable for your financial situation and risk tolerance. All investments carry risk, and you may lose some or all of your principal investment. Past performance is not indicative of future results, and no representation is being made that any account will or is likely to achieve profits or losses similar to those shown.

Specific Investment Risks

Stock Market Risk

Stocks and equity securities are subject to market risk, meaning their value can fluctuate significantly based on:

• Overall stock market conditions and investor sentiment
• Company-specific performance and earnings results
• Economic conditions, interest rates, and inflation
• Political events and regulatory changes
• Industry trends and competitive dynamics

Individual stocks may decline significantly or become worthless if a company files for bankruptcy or experiences severe financial difficulties. Stock values can be volatile in the short term, and temporary declines of 20% or more are not uncommon during market downturns.

Options Trading Risk

OPTIONS TRADING IS COMPLEX AND INVOLVES SUBSTANTIAL RISK OF LOSS.

Options are derivative instruments whose value is derived from underlying securities. Key risks include:

• Total Loss of Premium: Options can expire worthless, resulting in 100% loss of the premium paid
• Leverage Risk: Options involve leverage, which magnifies both potential gains and losses
• Time Decay: Options lose value as they approach expiration, even if the underlying security remains unchanged
• Complexity: Options strategies require understanding of Greeks (delta, gamma, theta, vega) and complex risk dynamics
• Limited Liquidity: Some options contracts may be illiquid, making them difficult to exit
• Volatility Risk: Changes in implied volatility significantly impact options values
• Assignment Risk: Short options positions may be assigned at any time, requiring you to fulfill obligations
• Naked Options Risk: Selling uncovered (naked) options exposes you to potentially unlimited losses

Lendori primarily uses defined-risk options strategies such as covered calls, cash-secured puts, and spreads. However, losses on these strategies can still be substantial.

ETF Risks

Exchange-traded funds (ETFs) offer diversification but come with their own risks:

• Market Risk: ETFs decline when their underlying holdings decline
• Tracking Error: ETF returns may deviate from the index or assets they're designed to track
• Premium/Discount Risk: ETFs may trade at prices above (premium) or below (discount) their net asset value
• Liquidity Risk: Some ETFs have low trading volume, resulting in wider bid-ask spreads
• Concentration Risk: Sector or thematic ETFs may be heavily concentrated in specific areas
• Dividend Risk: Dividend-paying companies may reduce or eliminate dividends
• Expense Ratios: ETF fees reduce returns over time

Foreign Exchange (Forex) Risk

FOREX TRADING IS SPECULATIVE AND INVOLVES SUBSTANTIAL RISK OF LOSS.

Currency trading involves significant risks including:

• Leverage Risk: Forex positions involve high leverage (often 50:1 or higher), which can result in rapid and substantial losses exceeding your invested capital
• Volatility: Currency prices can change rapidly due to economic data releases, geopolitical events, or central bank actions
• 24-Hour Market: Forex markets operate around the clock, and significant price movements can occur when U.S. markets are closed
• Liquidity Gaps: Even major currency pairs can experience reduced liquidity during certain times
• Counterparty Risk: Risk that the forex broker or liquidity provider fails to honor obligations
• Interest Rate Risk: Currency values are significantly impacted by interest rate changes
• Political Risk: Currency devaluations, capital controls, or political instability can cause sudden losses

FOREX TRADING IS NOT SUITABLE FOR ALL INVESTORS. Only invest funds you can afford to lose entirely.

Concentration Risk

Your portfolio may be concentrated in certain securities, sectors, or strategies at various times. Concentration increases risk because poor performance in a single area can significantly impact overall portfolio value.

Liquidity Risk

Some investments may be difficult to sell quickly without accepting a significantly lower price. During periods of market stress, liquidity can decline sharply, making it difficult to exit positions at reasonable prices.

Regulatory and Legal Risk

Changes in laws, regulations, or tax treatment can adversely affect investments. New regulations may limit investment strategies, increase costs, or require positions to be closed.

Performance and Return Disclosures

Past Performance

PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS.

Historical returns, whether actual or hypothetical, do not predict future performance. Future returns may be higher or lower than past returns, and you may lose money. Performance data reflects a specific time period and may not be representative of returns over other time periods.

Net vs. Gross Returns

Unless otherwise stated, performance data is shown:

• Net of Fees: After deduction of management fees and other expenses
• Gross of Taxes: Before consideration of taxes, which can significantly reduce returns

Your actual returns will be reduced by management fees, performance fees (if applicable), and taxes. Even small differences in fees can have a significant impact on returns over time.

Benchmark Comparisons

When we compare our performance to benchmarks or indices:

• Benchmarks are unmanaged and do not include fees or expenses
• You cannot invest directly in an index
• Benchmark composition and risk characteristics may differ significantly from your portfolio
• Benchmarks may not be appropriate measures of our strategy's performance

Model or Hypothetical Performance

If we present model or hypothetical performance results, they are subject to inherent limitations:

• Model results do not represent actual trading
• Hypothetical results may not reflect the impact of material economic and market factors
• Model results may assume perfect execution and liquidity that may not be achievable in practice
• Results may be based on strategies that were not historically available
• Models can be designed with the benefit of hindsight

HYPOTHETICAL PERFORMANCE RESULTS HAVE MANY INHERENT LIMITATIONS. NO REPRESENTATION IS BEING MADE THAT ANY ACCOUNT WILL OR IS LIKELY TO ACHIEVE PROFITS OR LOSSES SIMILAR TO THOSE SHOWN.

Individual Results Will Vary

Your actual investment results will depend on many factors including:

• Timing of deposits and withdrawals
• Market conditions during your investment period
• Your specific risk profile and asset allocation
• Fees and expenses charged to your account
• Tax treatment of investment income and gains

Fiduciary Status and Conflicts of Interest

Fiduciary Duty

Lendori is registered as an investment adviser with the Securities and Exchange Commission. As your investment adviser, we have a fiduciary duty to act in your best interest. This means we must:

• Place your interests ahead of our own
• Provide advice that is suitable for your circumstances
• Avoid misleading statements or omissions
• Disclose material conflicts of interest
• Seek best execution for transactions

Conflicts of Interest

Despite our fiduciary duty, certain conflicts of interest exist:

• Asset-Based Fees: Our fee structure (percentage of assets under management) creates an incentive for us to encourage you to maintain or increase your account balance. We mitigate this by providing objective advice based on your circumstances.
• Performance Fees: We may earn higher fees when your account performs well. This could incentivize excessive risk-taking. We mitigate this through our disciplined risk management approach and adherence to your stated risk profile.
• Trade Allocation: When we manage multiple client accounts, we must allocate investment opportunities fairly. We have procedures to ensure equitable treatment.
• Soft Dollars: Our custodians may provide us with software, research, or other services that benefit our business. These arrangements are disclosed in our Form ADV.

For complete disclosure of conflicts of interest, please review our Form ADV Part 2 (Brochure), which is available upon request or at adviserinfo.sec.gov.

Regulatory Information

SEC Registration

Lendori is registered with the U.S. Securities and Exchange Commission as an investment adviser under the Investment Advisers Act of 1940. SEC registration does not imply a certain level of skill or training and does not constitute an endorsement of our firm by the SEC.

CRD Number: [Insert CRD Number]

SEC File Number: [Insert SEC File Number]

Form ADV

Our Form ADV Part 2 (the "Brochure") provides detailed information about:

• Our business practices and services
• Fee schedules and compensation arrangements
• Types of clients we serve
• Investment strategies and risks
• Conflicts of interest
• Disciplinary history
• Key personnel qualifications

You received a copy of our Form ADV Part 2 when you opened your account. You can request an updated copy at any time or access it online at https://adviserinfo.sec.gov by searching for our firm name.

SIPC Protection

Securities in your account are held by our custodian and are protected by the Securities Investor Protection Corporation (SIPC) up to $500,000 (including $250,000 for cash claims).

Important: SIPC protection does not protect against investment losses due to market declines. It only protects against loss of securities and cash if the custodian firm fails. For more information about SIPC, visit www.sipc.org.

Additional Insurance

Our custodian may carry additional insurance coverage beyond SIPC limits. This excess coverage protects against custodian insolvency but does not protect against investment losses. Details of this coverage are available upon request.

Tax Considerations

Lendori DOES NOT PROVIDE TAX ADVICE. The tax information provided here is general in nature and may not apply to your specific situation. You should consult with a qualified tax advisor regarding:

• Tax treatment of investment income and capital gains
• Tax-loss harvesting strategies
• Required minimum distributions from retirement accounts
• Estate and gift tax planning
• State and local tax implications

Tax Reporting

Lendori will provide the following tax documents:

• Form 1099-DIV: Reports dividends and capital gain distributions (if applicable)
• Form 1099-B: Reports proceeds from securities sales
• Form 1099-INT: Reports interest income (if applicable)
• Form 1099-MISC: Reports miscellaneous income (if applicable)

These forms will be available in your account by January 31 for the previous tax year (or February 15 for corrected forms).

Tax Implications of Portfolio Management

Our portfolio management activities may generate taxable events including:

• Capital gains or losses from securities sales
• Dividend and interest income
• Options premium income
• Currency gains or losses from forex trading

Rebalancing and tactical adjustments may trigger capital gains taxes. Short-term capital gains (positions held less than one year) are taxed at ordinary income rates, which may be significantly higher than long-term capital gains rates.

We do not guarantee tax-efficient management, and our primary focus is on maximizing risk-adjusted returns rather than minimizing taxes. However, we are mindful of tax implications where practical.

Forward-Looking Statements

Materials on our website, in account communications, and in marketing materials may contain forward-looking statements about:

• Expected market conditions
• Economic forecasts
• Investment opportunities
• Portfolio strategy
• Expected returns or performance

Forward-looking statements are based on current beliefs, assumptions, expectations, and projections about future events. They are subject to significant risks and uncertainties, and actual results may differ materially from those expressed or implied. Factors that could cause actual results to differ include:

• Changes in market conditions
• Economic developments
• Political or regulatory changes
• Unexpected events or crises
• Changes in investor sentiment

We undertake no obligation to update forward-looking statements to reflect events or circumstances after the date they were made.

Educational Content Disclaimer

Educational content, market commentary, and research provided by Lendori is for informational purposes only and should not be considered:

• Personalized investment advice for your specific situation
• A recommendation to buy or sell any specific security
• A guarantee of future results
• Tax, legal, or accounting advice

Always consult with qualified professionals before making investment decisions.

Account Statements and Confirmations

You will receive:

• Monthly Statements: Detailed account statements showing positions, transactions, and performance
• Trade Confirmations: Confirmations for each trade executed in your account
• Quarterly Reports: Comprehensive performance reports with portfolio analytics

Your Responsibility: You must carefully review all statements and confirmations for accuracy. You must notify us in writing of any errors or discrepancies within 30 days of receiving a statement. Failure to report errors within 30 days may limit your ability to dispute transactions.

Overview

Lendori is committed to operating with the highest standards of regulatory compliance and ethical conduct. We are subject to comprehensive regulation and oversight designed to protect investors and maintain the integrity of financial markets.

This page provides information about our regulatory status, oversight agencies, compliance programs, and investor protections.

SEC Registration and Oversight

Investment Adviser Registration

Lendori is registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser under the Investment Advisers Act of 1940. This federal registration subjects us to comprehensive regulatory requirements including:

• Fiduciary duty to act in clients' best interests
• Disclosure of material conflicts of interest
• Maintenance of accurate books and records
• Annual compliance reviews and audits
• Custody and safeguarding of client assets
• Advertising and marketing regulations
• Privacy and data security requirements

Registration Details

• Firm Name: Lendori
• SEC File Number: [Insert SEC File Number]
• CRD Number: [Insert CRD Number]
• Registration Date: [Insert Date]
• Primary Business: Investment advisory services
• Assets Under Management: [Updated Quarterly]

Verification of Registration

You can verify our SEC registration and review our regulatory filings at:

• SEC Investment Adviser Public Disclosure: https://adviserinfo.sec.gov
• Search for "Lendori" or use our CRD number
• Review our Form ADV Parts 1, 2A, and 2B
• Check our disciplinary history and regulatory actions

Important Note About SEC Registration

SEC registration does not imply a certain level of skill or training, nor does it constitute an endorsement of our services by the SEC. The SEC does not review or approve the qualifications of investment advisers or the adequacy of their disclosures.

FINRA Membership

About FINRA

Lendori is a member of the Financial Industry Regulatory Authority (FINRA), a self-regulatory organization that oversees broker-dealers and enforces rules designed to protect investors and ensure market integrity.

FINRA Membership Information

• Member Firm: Lendori
• Firm CRD Number: [Insert CRD Number]
• Member Since: [Insert Date]

Verification Through BrokerCheck

You can check our background and view any regulatory actions through FINRA's BrokerCheck:

• Website: https://brokercheck.finra.org
• Search for our firm or individual registered representatives
• View employment history and qualifications
• Check for customer complaints and disciplinary actions

FINRA Rules We Follow

As a FINRA member, we comply with rules governing:

• Suitability and best interest obligations
• Supervision and compliance
• Communications with the public
• Trade reporting and market transparency
• Customer account protection
• Arbitration and dispute resolution

SIPC Protection

What is SIPC?

The Securities Investor Protection Corporation (SIPC) is a nonprofit corporation created by Congress to protect customers of brokerage firms that fail financially. Securities in your Lendori account are held by our custodian, which is a SIPC member.

SIPC Coverage

SIPC protects securities and cash in customer accounts up to:

• $500,000 per customer (including up to $250,000 for cash claims)
• Coverage applies if our custodian broker-dealer fails, not if we fail as an investment adviser
• Protection covers the loss of securities and cash, not investment losses from market declines

What SIPC Does NOT Cover

Important Limitations:

• Investment losses due to market declines or poor performance
• Losses from fraud by registered representatives (different coverage may apply)
• Investment contracts that are not securities (e.g., certain forex or commodity positions)
• Claims against investment advisers (only custodian failures)

Additional Insurance Coverage

Our custodian carries excess SIPC insurance through [Insurance Company Name] providing additional protection of up to $[Amount] per customer. This excess coverage applies only after SIPC limits are exhausted and covers the same types of losses as SIPC.

More Information

For detailed information about SIPC protection:

• Website: https://www.sipc.org
• SIPC Brochure: Available on our website or upon request

State Registration

In addition to our federal SEC registration, Lendori is registered or has filed notice in the following states where we conduct business:

Registered States

State securities regulators provide additional oversight and may investigate complaints. Contact information for state securities regulators is available at www.nasaa.org.

Compliance Program

Overview

Lendori maintains a comprehensive compliance program designed to prevent, detect, and correct violations of securities laws and regulations. Our program is overseen by our Chief Compliance Officer (CCO) and includes:

Key Compliance Elements

• Written Policies and Procedures: Comprehensive policies covering all aspects of our business operations
• Annual Compliance Review: Thorough annual review of our compliance program's effectiveness
• Ongoing Monitoring: Continuous monitoring of advisory activities for regulatory compliance
• Employee Training: Regular training for all employees on compliance topics
• Code of Ethics: Ethical standards for all employees and access persons
• Personal Trading Rules: Restrictions on employee personal securities transactions
• Advertising Review: Pre-approval of all advertising and marketing materials
• Custody Controls: Safeguarding of client assets and custody compliance

Chief Compliance Officer

Our Chief Compliance Officer is responsible for:

• Administering the compliance program
• Ensuring firm adherence to regulatory requirements
• Conducting annual compliance reviews
• Investigating and resolving compliance issues
• Reporting to senior management and board of directors
• Serving as liaison with regulators

Contact our CCO: compliance@lendori.finance

Independent Testing

We engage independent third-party consultants to conduct annual testing of our compliance program, including:

• Review of policies and procedures
• Testing of key controls
• Evaluation of regulatory compliance
• Assessment of cybersecurity measures
• Recommendations for improvements

Anti-Money Laundering (AML) Program

AML Compliance

Lendori has implemented a comprehensive Anti-Money Laundering (AML) program in compliance with the Bank Secrecy Act and USA PATRIOT Act. Our AML program includes:

Customer Identification Program (CIP)

• Identity Verification: Verification of customer identity using government-issued identification
• Required Information: Collection of name, date of birth, address, and identification number (SSN or TIN)
• Verification Methods: Documentary verification (ID documents) and non-documentary verification (database checks)
• Recordkeeping: Maintenance of verification records for five years after account closure

Customer Due Diligence (CDD)

• Understanding the nature and purpose of customer relationships
• Identifying and verifying beneficial owners of legal entity customers
• Ongoing monitoring of transactions for suspicious activity
• Updating customer information on a risk-based schedule

Ongoing Monitoring

We continuously monitor account activity for potentially suspicious transactions including:

• Unusual patterns of deposits or withdrawals
• Transactions inconsistent with customer profile
• Structuring transactions to avoid reporting requirements
• Rapid movement of funds
• Transactions involving high-risk jurisdictions

Suspicious Activity Reporting (SAR)

If we detect suspicious activity, we are required to file a Suspicious Activity Report (SAR) with FinCEN. We cannot disclose to you that a SAR has been filed regarding your account.

OFAC Compliance

We screen all customers against the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list and other sanctions lists. We cannot open accounts for individuals or entities on these lists.

AML Training

All employees receive annual AML training covering:

• Money laundering typologies and red flags
• Customer identification procedures
• Suspicious activity detection and reporting
• Sanctions compliance
• Recordkeeping requirements

Privacy and Data Security

Regulation S-P Compliance

We comply with SEC Regulation S-P, which governs the privacy of consumer financial information. Our obligations include:

• Providing privacy notices to customers
• Allowing customers to opt out of certain information sharing
• Protecting the security and confidentiality of customer information
• Properly disposing of consumer information

Cybersecurity Measures

We maintain comprehensive cybersecurity safeguards including:

• Encryption: TLS 1.3 for data in transit, AES-256 for data at rest
• Access Controls: Multi-factor authentication and role-based access
• Network Security: Firewalls, intrusion detection, and DDoS protection
• Monitoring: 24/7 security monitoring and incident response
• Testing: Regular penetration testing and vulnerability assessments
• Vendor Management: Due diligence on third-party service providers
• Employee Training: Security awareness training for all staff
• Incident Response: Documented procedures for responding to breaches

Data Breach Notification

In the event of a data breach affecting your personal information, we will notify you promptly in accordance with applicable laws. Notification will include:

• Description of what happened
• Types of information affected
• Steps we are taking to investigate and respond
• Steps you can take to protect yourself
• Contact information for questions

Best Execution

Lendori has a duty to seek best execution for all client transactions. This means seeking the most favorable terms reasonably available under the circumstances, considering:

• Price and commissions
• Speed of execution
• Likelihood of execution and settlement
• Size and type of transaction
• Market conditions
• Availability of market data

We regularly review execution quality and evaluate our executing brokers to ensure we continue to obtain best execution for clients.

Business Continuity Planning

Lendori maintains a Business Continuity Plan (BCP) to ensure we can continue providing services in the event of a significant disruption. Our plan addresses:

• Data Backup: Daily backups stored at geographically diverse locations
• Disaster Recovery: Procedures to restore systems and data
• Alternative Work Locations: Backup facilities for critical operations
• Communication: Methods to communicate with clients during disruptions
• Critical Functions: Prioritization of essential business functions
• Testing: Annual testing and updating of the BCP

A summary of our Business Continuity Plan is available upon request.

Complaints and Grievances

How to File a Complaint

If you have a concern or complaint about our services, please contact us:

• Email: complaints@lendori.finance
• Mail: Lendori Compliance Department, [Address]

Complaint Handling Process

1. Receipt: We acknowledge receipt of your complaint within 2 business days
2. Investigation: We thoroughly investigate the matter
3. Response: We provide a written response within 15 business days
4. Resolution: We work with you to resolve the issue fairly

Escalation Options

If you are not satisfied with our response, you may escalate your complaint to:

• SEC Office of Investor Education and Advocacy:
  Website: www.sec.gov/oiea
• FINRA Dispute Resolution:
  Website: www.finra.org/arbitration-mediation
• State Securities Regulator:
  Contact information at www.nasaa.org

Regulatory Examinations

Lendori is subject to periodic examinations by the SEC and other regulators. During examinations, regulators review:

• Compliance with securities laws and regulations
• Adequacy of policies and procedures
• Accuracy of disclosures to clients
• Custody and safeguarding of client assets
• Best execution practices
• Privacy and cybersecurity controls
• Books and records

We cooperate fully with all regulatory examinations and implement recommendations to enhance our compliance program.