Item 1. Cover Page

Buenwealth LLC
1900 N.E. Miami Ct.
Miami, FL 33132

(786) 702- 0078

www.buenwealth.com

December 2, 2024

This Brochure provides detailed information about the qualifications, services, and business practices of Buenwealth LLC (“Buenwealth,” “we,” “our,” or “the Firm”). Registration with the SEC as an investment adviser does not imply any specific level of skill or training. This document is meant to assist you in understanding our services and policies, along with any potential conflicts of interest.

If you have questions regarding the contents of this Brochure, please contact our Chief Compliance Officer at (786) 702-0078. Additional information about Buenwealth LLC is available on the SEC’s website at Investor.gov, where you can find further details about the firm’s registration and background.

Item 2. Material Changes

In this section, Buenwealth LLC outlines any material changes made to this Brochure since its last update.

As of November 25, 2024, Buenwealth applied for registration as an investment adviser with the SEC under Rule 203A-2(e), which provides an exemption for internet-only investment advisers.
Catalina Rey has been designated as the Chief Compliance Officer of Buenwealth LLC
Buenwealth has updated its primary U.S. address to 1900 N.E. Miami Ct., Miami, FL 33132.

Going forward, Buenwealth will notify clients of any material changes within 120 days of the fiscal year-end, which is December 31. A new Brochure will also be provided as necessary based on changes, with no charge to clients. For a copy of this or future updates, please contact us at +1 (305) 394-6486 or email [email protected].

Item 3. Table of Contents

Item 4. Advisory Business

A. Firm Description

Buenwealth LLC is a limited liability company formed in Florida on March 14, 2023. We are wholly owned by Fiat Flow Solutions Ltd., a UK-based entity, and are registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser. Our primary focus is providing automated investment advisory services tailored to the needs of individuals, high-net-worth individuals, corporations, and other institutional clients through a digital platform.

B. Types of Advisory Services

Our services are primarily delivered through a proprietary, automated digital advisory platform. The Firm’s platform allows clients to complete a comprehensive online questionnaire that assesses their financial situation, investment experience, goals, and risk tolerance. Based on the data provided, our system generates a personalized investment recommendation.

Buenwealth specializes in offering non-discretionary advisory services. Clients retain control over their investments, choosing whether to accept the recommended asset allocation or adjust their allocations within the available options. Our platform focuses on asset management utilizing equities and a diversified selection of exchange-traded funds (ETFs) across asset classes, including U.S. equities, international developed equities, international emerging markets, U.S. Treasury securities, and corporate bonds.

C. Investment Process

Clients can open an account through our secure online system by completing a detailed registration process, which includes submitting personal financial data, such as age, investment goals, and risk tolerance. Based on this data, our proprietary algorithm generates an investment recommendation aligned with the client’s financial objectives.

The algorithm evaluates each client's risk profile, time horizon, and investment goals to ensure that the asset allocation meets the client's unique needs. It is essential for clients to understand that our automated recommendations are based on the questionnaire responses, and generally no additional market conditions or individual circumstances are taken into account.

D. Client Tailored Services and Client Imposed Restrictions

Our platform provides individualized investment advice through an investment recommendation based on the client responses to the questionnaire. Clients may impose reasonable restrictions on certain securities or types of investments within the platform's offerings. However, the platform is limited to recommending equities and ETFs, meaning specific requests outside of these categories cannot be accommodated at this time.

E. Wrap Fee Program

Buenwealth does not participate in wrap fee programs. Unlike a wrap fee program, where one stated fee covers all investment-related services, Buenwealth’s fees are exclusive of third-party costs and expenses, as detailed in the following sections.

F. Assets Under Management

Buenwealth is a de novo adviser and currently does not manage any assets. Future updates will reflect the Firm’s growth and assets under management (AUM) as required by SEC regulations.

Item 5. Fees and Compensation

A. Fee Structure

Buenwealth’s services are available to clients for an annual advisory fee ranging from 0.50% to 1.50% of assets under management. This fee is calculated based on the client’s total assets under management with the Firm and is charged monthly in arrears.

Fees for Buenwealth’s automated advisory services are competitive within the industry but may vary based on account size or client profile. Additional costs related to brokerage and transaction fees may apply depending on the custodian selected by the client and specific investment products chosen. Buenwealth reserves the right to offer discounted fees for particular client segments or existing account holders.

B. Payment of Fees

The advisory fees for each billing cycle are calculated using the account’s daily balance and deducted directly from client accounts. Fees are prorated for clients who open or close their accounts during the billing period, ensuring fair and accurate fee assessments. Any additional fee arrangements negotiated individually with clients will be documented as part of their advisory contract.

C. Third-Party Fees

Clients may incur additional charges imposed by custodians, brokers, or other third-party service providers. These fees may include, but are not limited to, custodial fees, wire transfer fees, and costs associated with ETF management. Buenwealth discloses these fees on its website and encourages clients to review these additional costs.

Buenwealth may, at its discretion, cover or reimburse certain fees charged by third-party providers if deemed necessary. However, clients should understand that Buenwealth does not receive any portion of the fees charged by ETFs or other external financial products.

D. Prepayment of Fees

Buenwealth does not require or solicit the prepayment of fees. All fees are billed in arrears, ensuring that clients are charged only for services rendered.

E. Additional Compensation for Securities Sales

Neither Buenwealth nor its supervised persons accept compensation for the sale of securities or investment products. Our sole source of compensation is the advisory fee disclosed above, promoting transparency and alignment with client interests.

F. Additional Compensation for Securities Sales

Item 6. Performance-Based Fees and Side-By-Side Management

Buenwealth does not charge performance-based fees. All client fees are calculated based on assets under management rather than performance. This structure ensures that Buenwealth’s compensation aligns with client investment objectives without any added risk incentives for the Firm.

Item 7. Types of Clients

Buenwealth LLC offers automated investment advisory services to a range of clients, including individuals, high-net-worth individuals, small businesses, corporations, and other institutions seeking a technology-driven, non-discretionary advisory service. Our platform is particularly suited to clients looking for accessible, efficient investment recommendations tailored to their risk profile and financial goals.

Minimum Account Size

To receive advisory services from Buenwealth, clients are required to meet a minimum account size of $500. This threshold enables a diverse range of investors to benefit from our services while ensuring the operational efficiency of our automated platform.

Buenwealth reserves the right to waive or adjust minimum account requirements for certain clients or promotional purposes. We encourage prospective clients to evaluate the suitability of our platform based on their financial needs and to contact us for more information regarding account requirements.

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

A. Methods of Analysis

Buenwealth utilizes a proprietary algorithm that incorporates elements of quantitative analysis and asset allocation principles to provide tailored investment recommendations. Based on client responses to our digital questionnaire, our algorithm assesses factors such as risk tolerance, investment experience, and time horizon to generate an allocation recommendation. Key aspects of our analysis include:

Asset Allocation: The platform emphasizes diversification across asset classes to minimize risk. Based on the client’s responses, our algorithm determines an optimal balance between equities and ETFs across a variety of asset classes.
Risk Tolerance Assessment: The questionnaire evaluates the client’s capacity to handle different levels of risk, ensuring the investment recommendations align with their comfort level.
Historical Data: Our approach leverages historical performance data for various asset classes to guide asset allocation. However, clients should understand that historical performance is not a guarantee of future returns.

B. Investment Strategies

Buenwealth’s primary strategy focuses on achieving long-term growth through diversified asset allocation, cost efficiency, and risk mitigation. Our platform offers a selection of core strategies, including:

Diversified Asset Allocation: Investment recommendations are designed to include a mix of asset classes, such as U.S. equities, international equities, corporate bonds, and U.S. Treasury securities, reducing concentration risk.
Rebalancing: Periodically adjusts the allocation to stay aligned with the client’s risk tolerance and investment objectives.
Cost-Efficient Investment Vehicles: We use low-cost ETFs to provide clients with diversified exposure while reducing expenses associated with individual securities.

C. Risk of Loss

Investing in securities involves inherent risks, including the potential loss of principal. Buenwealth strives to mitigate these risks through strategic asset allocation; however, clients must be aware of and prepared to bear the following risks:

Market Risk: Changes in market conditions can impact the value of investments. Economic, political, and regulatory events may create volatility that affects overall investment performance.
ETF-Specific Risks: ETFs may experience tracking errors, liquidity issues, and potential cost variations that impact performance.
Interest Rate Risk: Fluctuations in interest rates can affect the value of certain securities, especially bonds.
Foreign Investment Risk: Exposure to foreign securities, particularly in emerging markets, may involve additional risks such as currency fluctuations, political instability, and foreign regulations.
Reliance on Algorithms: Buenwealth’s recommendations are derived from client responses and historical data. The algorithm’s assumptions may not account for sudden or unforeseen market shifts, and while based on established strategies, they do not eliminate all risks.

We provide clients with transparent risk disclosures and encourage them to review the appropriateness of their investment strategy regularly.

Item 9. Disciplinary Information

Buenwealth is dedicated to maintaining a high ethical standard. Neither Buenwealth nor any of its management or supervised persons have been subject to disciplinary actions, regulatory violations, or legal proceedings that would be material to a client’s assessment of our integrity.

The Firm conducts ongoing compliance reviews and maintains rigorous internal protocols to ensure adherence to all relevant regulations and standards.

Item 10. Other Financial Industry Activities and Affiliations

A. Financial Industry Activities

Buenwealth’s operations are focused solely on investment advisory services delivered via a digital, automated platform. We are not engaged in any additional financial industry activities that might conflict with our role as an independent adviser.

B. Affiliations

Buenwealth is affiliated with Buenbit SAC, a digital money exchange registered with Peru’s Banking and Insurance Superintendence, and BKR Argentina SA, a payment provider registered with Argentina’s Central Bank. While these affiliations provide us with additional insights into global finance, Buenwealth operates independently in delivering its advisory services, and these affiliations do not impact the investment recommendations offered through our platform.

Buenwealth does not receive referral fees or compensation from these affiliates. Should any material financial relationships arise, Buenwealth will disclose them transparently in compliance with regulatory standards.

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

A. Code of Ethics

Buenwealth has adopted a Code of Ethics to establish high standards of conduct for its employees and uphold our fiduciary duty to clients. The Code includes provisions to:

Prioritize Client Interests: All employees are expected to act in the client’s best interests and avoid any actions that could lead to conflicts of interest.
Confidentiality: Buenwealth safeguards client information and prevents unauthorized disclosure.
Prohibit Insider Trading: Employees are strictly prohibited from using material non-public information for personal gain.

B. Personal Trading Policy

Buenwealth permits employees to invest in securities but requires compliance oversight to prevent conflicts of interest. Personal trading is regularly reviewed, and employees must adhere to strict guidelines to ensure their activities do not compromise the impartiality of Buenwealth’s recommendations.

We monitor employee trading activities and enforce measures to ensure that personal investments do not interfere with the best interest of our clients.

Item 12. Brokerage Practices

A. Custodian Selection and Best Execution

Buenwealth has a contractual agreement with Drivewealth LLC, a broker-dealer and member of FINRA and SIPC, to execute client transactions and provide custodial services. Drivewealth offers competitive commission rates, efficient execution, and a high standard of client asset protection.

Buenwealth periodically reviews Drivewealth’s execution services to ensure clients receive favorable pricing and efficient transaction handling. Our evaluation includes considerations for trade execution speed, cost-effectiveness, and reliability.

B. Aggregation of Orders

When beneficial for clients, Buenwealth may aggregate orders across multiple accounts to enhance trade execution efficiency. Such aggregated trades are executed at the same average price, and costs are distributed on a pro-rata basis to ensure fairness across client accounts.

C. Margin Accounts

Buenwealth allows clients to open margin accounts through Drivewealth LLC, though the decision to use margin is left to the client’s discretion. Margin accounts provide clients with liquidity for new investments by leveraging existing assets. Buenwealth does not directly facilitate margin lending, and all margin-related agreements are administered by Drivewealth, which supplies the necessary disclosures and terms.

Item 13. Review of Accounts

A. Review Process

Buenwealth’s platform periodically reviews client accounts to ensure their allocation aligns with the selected investment strategy. Adjustments may be made based on significant market changes or updates to the client’s financial situation, as indicated through their responses.

B. Client Access to Account Information

Clients can access their account details, including current balances and positions, through Buenwealth’s secure online portal. Drivewealth provides quarterly custodial statements, and Buenwealth sends quarterly reminders to clients to review any relevant account changes.

C. Annual Review

Buenwealth conducts an annual review, prompting clients to confirm or update their financial information, goals, and any restrictions they wish to apply to their account. This review allows us to ensure that the investment recommendations remain suitable and aligned with the client’s evolving financial circumstances.

Item 14. Client Referrals and Other Compensation

Buenwealth does not currently engage in a referral program. However, in the event a referral program is introduced, Buenwealth may compensate affiliates, partners, or third-party solicitors for referring clients. If implemented, such compensation could include flat fees or performance-based payments, with clients incurring no additional charges as a result of these arrangements. Buenwealth maintains transparency in all client referral relationships and will fully disclose any relevant information if a program is implemented in the future.

Item 15. Custody

Buenwealth does not hold custody of client assets. All client assets are held by Drivewealth LLC, a qualified custodian, which provides clients with monthly statements reflecting account balances and transactions. Clients are encouraged to review these statements to confirm that Buenwealth’s reports align with Drivewealth’s custodial records.

Item 16. Investment Discretion

Buenwealth receives limited discretionary authority to execute transactions based on the investment recommendations provided through the platform. Each client grants Buenwealth a non-discretionary authority when accepting the investment advisory agreement. All recommendations and transactions are carried out in line with the allocation selected by the client.

Item 17. Voting Client Securities

Buenwealth does not vote on proxies or other client-held securities. Clients are responsible for voting their proxies, and Buenwealth can offer guidance on request. Shareholder communications are sent directly to clients by their custodian, allowing clients to participate in governance decisions if they choose.

Item 18. Financial Information

Buenwealth does not solicit or require prepayments of fees exceeding $1,200 per client and is financially stable with no conditions that would impair our ability to meet contractual obligations.