01Who we are and our regulatory status
Wealthnow is operated by Tengu LLC. Tengu LLC is not currently registered as an investment adviser with the SEC or any state. Tengu LLC intends to apply for registration as an investment adviser. Neither applying nor being registered would mean that the SEC or any state has approved Tengu LLC or its services, or that Tengu LLC has any particular level of skill or training.
Tengu LLC is not a broker-dealer, a member of FINRA or SIPC, a custodian, a bank, or an insurance company. We do not hold your money or securities. They stay at the brokerage or exchange where you hold them, which opens your account, holds your assets, applies its own rules, and executes the orders you approve.
We ask only for trading access where a broker offers it. Some brokers, such as Alpaca, do not offer a trade-only key. We never use any connection to move money.
02What the personalized features do
Parts of the Service are tailored to you. Alfred, the AI assistant, reads the data from the accounts you connect and the investor profile you complete (such as your goals, time horizon, and risk tolerance). Its answers can include views on specific securities and on your portfolio, including suggestions to buy, sell, or change how much you hold. Some features can prepare a proposed order for a connected account; an order is sent to your broker only after you approve that specific order.
Until you complete and confirm your investor profile, the assistant’s answers are research only: it does not size new positions or suggest an allocation for you, and it asks you for the missing information instead of assuming it. An order that only reduces a position you already hold, such as a sale or a stop-loss, is not held back. If you change a confirmed answer, the same applies until you confirm your profile again.
When the assistant or a proposed order says “buy,” “sell,” “trim,” or something similar, it is a suggestion for you to consider. You decide whether to act on it. Other content, such as market pages, news summaries, public rankings, and articles, is general information that is not tailored to you.
03AI-generated content
Alfred is an AI and can make mistakes. Verify important info.
The assistant runs on large language models from third-party providers, which our Privacy Policy lists. AI output can be wrong, incomplete, outdated, or misleading, and it can state an error with confidence. Tickers, prices, dates, identities, and statements about your portfolio in AI output may contain errors. Verify any number or fact against primary sources (your brokerage, exchange feeds, issuer filings) before acting on it.
04Research and model limitations
Some answers, scores, and rankings in the Service rely on our quantitative research models. In our own measurements to date, these models have not shown a measurable ability to predict returns. Treat them as research, not as a forecast, and weigh any suggestion that relies on them accordingly.
05Investing involves risk
All investing carries risk, including the risk of losing some or all of the money you invest. Markets can move quickly and against your position. Concentrated positions, options, derivatives, leveraged products, and short positions can lose more than the amount initially invested. Liquidity can disappear in stressed markets. International securities involve additional risks, including currency risk and political risk.
Consider your own circumstances before acting on anything the Service shows you, including suggestions tailored to you. Our pre-trade checks (the order gate described in our Terms) are a software safeguard. They do not replace your broker’s protections, and they do not make any trade safe.
06Past performance is not a guarantee of future results
Performance numbers shown in the Service (for individual securities, strategies, portfolios, or marketplace listings) may be historical, back-tested, simulated, paper-traded, or model-generated. None of these is a reliable indicator of how the same strategy or security will perform going forward.
Hypothetical or simulated performance results have inherent limitations. They are prepared with the benefit of hindsight, do not reflect actual trading, and may not account for liquidity, slippage, financing, taxes, fees, or operational events that affect real-world execution. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown.
07Strategies and follows in the marketplace
No strategy listed in the Wealthnow marketplace delivers signals to subscribers yet. Any performance shown for a listed strategy is a hypothetical backtest. Where a strategy’s description or results come from someone other than us, we say so, and we have not verified them unless we say we have.
You can pay to follow the disclosed holdings of a tracked fund (from its 13F filings) or the disclosed stock trades of a member of Congress, for $0.99 to $9.99 a month. A follow is built from public disclosures that can be weeks or months old. The return figures shown for a follow are hypothetical: they mostly apply the holdings disclosed today to past prices, so they are not results anyone achieved, including us, and they do not predict future results. The monthly price of a follow is set from those hypothetical figures. Following never gives us authority to trade for you: every order still needs your approval of that specific order.
08Digital-asset and crypto risks
Crypto and other digital-asset trades placed through a connected exchange involve additional risks: high volatility, custody risk, exchange operational risk, regulatory uncertainty, and the practical irreversibility of on-chain transactions. Digital assets are not securities under every regime, are not protected by SIPC, and may not be insured. The legal status of specific tokens varies by jurisdiction and can change. Do not allocate to digital assets money you cannot afford to lose, and do not connect a wallet or exchange you do not personally control.
09Third-party data and connectivity
Quotes, balances, holdings, news, filings, and other content shown in the Service come from third-party data providers, from connection services such as Plaid and SnapTrade, and from the brokers and exchanges we connect to directly. That content can be delayed, incomplete, inconsistent, or wrong, and the connections themselves can be slow, degraded, or unavailable. The statement you receive from your brokerage is the official record of your account, not the view inside the Service.
10Tax disclosures
Tengu LLC is not a tax adviser. Cost basis, realized gains and losses, wash-sale flags, and any tax effect the Service estimates (including in a suggestion to sell at a loss) are estimates based on the data we have when we compute them. They may differ from your brokerage’s tax reporting and from the values on your tax forms. For any tax decision, including loss harvesting, asset location, and the timing of realized gains, consult a qualified tax professional and rely on your official brokerage 1099 (or equivalent).
11Conflicts of interest
We are paid through subscription fees and other purchases in the app. We earn more when you choose a higher plan or yearly billing. We earn more when you buy credits and, once usage is charged, when you use the assistant more. Our owner may hold and trade securities and crypto assets our software may recommend, and may trade them at or about the same time as you.
12Who the Service is for
The Service is intended for individuals who live in the United States and are at least 18 years old, or the age of majority in their state if that is higher. Some features (for example, certain strategies or digital-asset operations) may not be available to every user. Where eligibility rules (such as options-trading approval) sit with your broker, your broker decides.
13Changes to these disclosures
We update this page when the Service or our regulatory status changes, and the “Last updated” date at the top shows the latest change. When a change to this page materially affects how the Service works for you, we will tell you by email and in the app.
14Contact
Questions about these disclosures: support@wealthnow.io.