Certain features available on the Public app and website (collectively, the “Public Platform”) may be sponsored by unaffiliated third parties (a “Sponsor”) in exchange for a fee paid to Public Holdings, Inc. (“Public Holdings”) or Open to the Public Investing, Inc. (“Public Investing”) (collectively, “Sponsored Content”). Public may earn a fee for reasons such as brand promotion on the Platform, marketing support, data analytics, administrative services, and to reimburse expenses, among others. The amount and form of fees paid by a Sponsor can vary depending on many factors, including the services provided by Public and the Sponsor’s investment products. Any Sponsored Content that appears on the Public Platform is labeled with “Presented by” tags, followed by the Sponsor’s logo.
As a Platform member, it is important to understand that the receipt of fees related to Sponsored Content creates a conflict of interest, which means that there is an incentive for us to display certain investment products. Importantly, Sponsored Content should not be considered an investment recommendation by Public Holdings, Public Investing, a Sponsor, and/or each of their respective affiliates for a particular security, issuer or sponsor, as applicable. You should consider your own investment objectives to make the choices best suited for your investment needs. All investments involve risk and past performance of a security or financial product does not guarantee future results or returns. Additional information regarding this conflict of interest can be found in the Public Investing Form CRS.
Pulse
Pulse connects companies with important and timely information about retail investors. A selection of Public Town Halls and Public Lives available on the Public Platform are sponsored by Pulse partners. Pulse partners may pay Public Holdings a fee in exchange for sponsoring these events. Sponsors make these marketing support payments to incentivize Public Holdings to promote their products, and a conflict of interest exists as a result of these payments. Sponsorship of these events by a Pulse partner should not be considered an investment recommendation by Public Holdings and/or its affiliates of a particular security or the Sponsor itself.
Learn & Earn
Learn & Earn provides members with interactive educational lessons to grow financial literacy. Members of the Public Platform have opportunities to earn stock, ETF or cryptoasset rewards through the Learn & Earn program. These programs may be sponsored by unaffiliated third parties, and the Sponsor may pay Public Holdings a fee in exchange for the sponsorship. The receipt of a particular stock, ETF or cryptoasset reward or the identification of a particular security in communications related to these programs does not constitute an offer, solicitation of an offer, or advice to buy or sell particular securities by Public Holdings and/or its affiliates.
Investment Plans
Investment Plans allow members to set up self-directed purchases of individually-selected securities or cryptoassets on a recurring basis. Certain Investment Plans may be sponsored by unaffiliated third parties. If an Investment Plan is sponsored, then Public Investing may receive compensation from the Sponsor. Sponsored Investment Plans should not be considered a recommendation of an Investment Plan overall or a recommendation of its individual holdings or default allocations; members can edit these Investment Plans as they see fit to meet their unique investment needs.
Sponsored Investment Plans are made up of stocks and ETFs. Before investing in an ETF, investors should consider the investment objectives, risks and charges, and expenses of the ETF. Although ETFs are designed to provide investment results that generally correspond to the performance of their respective underlying indices, they may not be able to exactly replicate the performance of the indices because of expenses and other factors. A prospectus contains this and other information about the ETF and should be read carefully before investing. Members should obtain and review prospectuses from issuers and/or their third-party agents who distribute and make prospectuses available for review.
Sponsored Content may be paid by a particular investment fund, or its investment advisor or distributor, or an affiliate, but generally represents an expense embedded within a fund’s expense ratio. Product-related expenses typically come in the form of sales charges, deferred sales charges, distribution and services fees, redemption fees, and other fees and expenses disclosed in a product’s offering documents. Fees generated in connection with a security or securities transaction are paid to Public Investing, a FINRA-registered broker dealer.
Additionally, Public Investing receives higher fees from fund and fund family Sponsors where Platform members have the largest holdings, and some Sponsor contracts pay increased asset-based fees when certain thresholds are met. Public Investing does not accept these fees for assets held in retirement accounts and does not share these payments with employees. The asset based fee paid to Public Investing for certain ETFs may be higher based on the fund’s expense ratio and therefore Public Investing has a conflict of interest in negotiating with fund and fund family Sponsors. Higher expense ratios will cause an investor to earn less on an investment than a comparable fund with a lower expense ratio.
Other Conflicts of Interest
Public Holdings sometimes receives reimbursements from Sponsors for technology development-related costs associated with the maintenance of the Platform, or the launch of a tool or service. In that Public benefits from Sponsors’ reimbursements of technology development-related costs, its financial interests are conflicted.
Non-Cash Compensation is compensation paid by Sponsors that is not in connection with any particular member, group of members, or assets and may be received by Public Holdings and/or its employees. This includes items such as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with events, workshops, or marketing or advertising initiatives.