Questions to ask before you sign

What will I pay, all in?

Two kinds of cost. The first is our advisory fee: an asset-based fee (0.25% to 2.00% of assets under management a year, billed monthly in arrears), a fixed fee (a monthly retainer or a project fee agreed in advance), or a combination of the two. A monthly retainer is set by what you are looking for from us, the complexity of your situation and how involved you want us to be. We check it against what an asset-based fee would be for the same relationship, so that we arrive at an amount both of us agree to. We look at every pricing model, asset-based, retainer, project fee or a combination, for what makes the most sense for each client. Your fee is set out in writing in your Client Advisory Agreement before the relationship begins.

The second is costs charged by third parties: brokerage commissions and transaction charges; digital-asset trading costs, including exchange fees, spreads and blockchain network (gas) fees; the internal expenses of funds and ETFs; and custodial fees, including wire and transfer fees. Where a sub-adviser manages part of your assets, it charges its own fee in addition to our asset-based fee. Apart from the private fund noted below, we receive no part of these.

We receive no revenue sharing and no compensation from any custodian or vendor. The exception is the private fund we sub-advise: we receive no management fee from it, but if you invest in it, we may receive carried interest, a share of its profits, which is a conflict that Form ADV Part 2A describes. Two of our partners are also registered representatives of Finalis Securities LLC and may receive transaction-based compensation, such as success fees on capital raising, in that separate capacity. Protocol Wealth receives no part of it, and Form ADV Part 2A describes the conflict and how we address it.

Source: Form ADV Part 2A, Items 5.A, 5.C, 5.F, 6, 12 and 14; Pricing

Who controls my money?

Client assets are held at qualified custodians in accounts in the client's name: Charles Schwab, Altruist and Interactive Brokers for traditional securities, and Anchorage Digital Bank, a federally chartered digital asset bank, for digital assets held in custody. We are authorized to trade in these accounts. We are not authorized to move assets out of them to third parties. Where you authorize it, the custodian deducts our fee, and it sends you statements directly at least quarterly. That fee authority is why we are deemed to have custody.

For digital assets held onchain, we use Fordefi multi-party computation (MPC) wallets. Signing authority is divided into cryptographic shards: Fordefi holds one shard and Protocol Wealth holds one shard. You hold the ultimate backup, and Protocol Wealth cannot recover the wallet on its own. You approve the strategies and destination addresses, and assets can be sent only to addresses you have approved. Fordefi is not a qualified custodian. We do not believe this arrangement gives us custody under Rule 206(4)-2; regulators have not issued guidance on it, and a regulator could reach a different conclusion.

When assets are moved into DeFi protocols, staking or a sub-adviser's smart-contract vault, they are not held by a qualified custodian, are not protected by the SEC's Custody Rule or by SIPC, and can be lost entirely. Some clients also hold assets in a self-custody wallet in the client portal, which we offer to clients we enable for it: you are the only signer, and we hold no credential that can move those assets. With an MPC wallet, you hold the recovery backup, through Coincover or a recovery phrase you keep, and safeguarding your credentials and recovery materials is your responsibility; if they are lost, we cannot recover the assets.

Source: Form ADV Part 2A, Items 15 and 16; General Terms, Section 10 (Custody of Assets); General Terms, Section C (Digital-asset management); Custody and Control

What happens if I lose money?

Investing involves risk of loss. We cannot guarantee the future performance of your account or promise that investment decisions will be successful.

We act as a fiduciary, and that duty cannot be signed away. Nothing in the agreement limits our liability for our own negligence or breach of fiduciary duty, or waives any right you have under the Investment Advisers Act of 1940. Under Section 215 of the Act, a provision that tried to waive compliance with the Act would be void.

The terms do say we are not liable for the independent acts of a custodian that are beyond our reasonable control, subject to our duty to select and monitor the custodian with reasonable care, and they exclude certain losses caused by third-party providers and network outages. Those limits sit beneath the fiduciary and non-waiver provisions above, not in place of them.

You also take on two responsibilities. We are not liable for losses caused solely by your failure to follow the cybersecurity practices in Section 22, such as a compromise of your email account or sharing your login credentials. And you agree to cover our direct losses arising from information you give us that you know, or are materially reckless about, being false, or that you know is materially wrong and do not correct (Section 8); an honest mistake is not covered.

Source: General Terms, Precedence and non-waiver; Sections 1, 8, 10, 22, 24 and 33; Section C

How do you use AI, and what happens to my information?

An adviser is responsible for every recommendation and every communication we send you, and reviews AI-assisted work before it is used in advice to you. Two things can reach you without an adviser reviewing each item first: answers from the client portal AI assistant, a limited beta that is off unless you or your adviser turn it on, and that gives no investment advice; and values read from statements and K-1s for outside investments, which are labeled "Unverified" until an adviser confirms or corrects them. AI tools do not make investment decisions, trade or move money.

Anthropic's Claude models, used in the portal assistant, document reading, advisers' internal chat and email sorting, run under zero data retention terms; Anthropic may keep content where the law requires it or its safety systems flag a conversation. Advisers can also use xAI's Grok in our internal advisory chat under zero data retention terms. To make documents advisers add to that chat searchable, passages are sent to Google's Gemini service, whose terms bar training on the data but are not zero data retention. In most of our AI features, before text is sent to a model, our software replaces identifiers it recognizes by pattern, such as Social Security numbers, email addresses, US phone numbers and some account-number formats. This does not cover every feature or PDF and image attachments, detection is not complete, and names are not replaced.

Source: AI & Technology Use Disclosure; List of Subprocessors; Form ADV Part 2A, Items 4.D and 8; General Terms, Section 20

What returns can I expect?

We do not publish performance results or projections on this website, and we cannot promise any result. Past performance does not guarantee future results.

Where a client's agreement provides for performance reporting, it comes at the frequency recorded in that agreement, and it is supplemental: the custodian's statements are the official record. If you want to know how we would report on your accounts, ask in a consultation.

Source: General Terms, Section 24 and Section B (Performance Reporting); Form ADV Part 2A, Item 15.A