Investment Disclosures

Updated: January 20, 2022

This website is operated by Treasure Investment Management, LLC (“Treasure” or the “Company” or “we” or “us”), a wholly-owned subsidiary of Treasure Technologies, Inc., and an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). Registration with the SEC does not imply a certain level of skill or training. Brokerage services are provided to clients of Treasure by Apex Clearing Corporation (“Apex”), an SEC-registered broker-dealer and member FINRA. Apex is also a member of SIPC and therefore, securities in your account are protected up to $500,000. For details, please see

Treasure is a federally-registered investment adviser and is appropriately registered as an investment adviser in all jurisdictions in which it is required to be registered. The Treasure website, and related investment advisory services, are only offered to corporate entities domiciled in the United States. Investment services are not available to corporate entities where provision of such products or services is unauthorized.  Any information provided on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use is contrary to local law or regulation.


The information contained herein is information about Treasure’s investment advisory services, and should not be construed as an offer to sell or the solicitation of an offer to buy any security in any jurisdiction where such an offer or solicitation would be illegal. Communications by Treasure through this website are for educational and informational purposes only. Communications shared via this website or email are not intended to be testimonials or endorsements of Treasure.

General Disclosures

Any performance displayed represents past performance, which is no guarantee of future results.

Treasure does not guarantee the accuracy or completeness of the information contained herein which is stated to have been obtained from or is based upon trade and statistical services or other third party sources. All opinions and estimates are given as of the date hereof and are subject to change without notice. The value of any investment may fluctuate as a result of market changes.  The information contained herein is not intended to predict actual results and no assurances are given with respect thereto.

Risk of Loss

Treasure does not guarantee any level of performance or that any client will avoid losses in their account(s). The investment decisions clients make based on Treasure’s services will not always be profitable. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risk factors.

All investments carry some level of risk. Clients may lose some or all of the money they invest, including their entire principal, because the value of their investments may fluctuate. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change.

Before a client invests, they should be sure to read shareholder reports to learn about any potential risks. Investments with higher targeted rates of return may take risks that are beyond an individual client’s comfort level and are inconsistent with each client’s financial goals.

While past performance does not necessarily predict future returns, it may indicate how volatile (or stable) an investment has been over a period of time. Generally, the more volatile a security, the higher the investment risk. If a client needs money to meet a financial goal in the near-term, that client probably can’t afford the risk of an investment with a volatile history because that client may not have enough time to ride out any declines in the stock market.

Investing in securities involves risk of loss that each client should be prepared to bear. The value of a client’s investment may be affected by one or more of the following risks, any of which could cause a client’s portfolio return, the price of the portfolio’s shares or the portfolio’s yield to fluctuate:

Market Risk

The value of portfolio assets will fluctuate as the stock market fluctuates. The value of investments may decline, sometimes rapidly and unpredictably, simply because of economic changes or other events that affect large portions of the market including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, or social events.

Investment Risk

There is no guarantee that Treasure’s judgment about particular securities or asset classes will necessarily produce the intended results.  Treasure’s judgment may prove to be incorrect, and a client might not achieve its investment objectives. Treasure may also make future changes to the algorithms and services that it provides. In addition, it is possible that clients or Treasure itself may experience computer or other hardware equipment failure, loss of internet access, viruses, or other events that may impair access to Treasure’s software based financial services.

Volatility and Correlation Risk

Clients should be aware that Treasure’s investment selection process is based in part on a careful evaluation of past price performance and volatility in order to evaluate future probabilities. However, it is possible that different or unrelated asset classes may exhibit similar price changes in similar directions which may adversely affect a client, and may become more acute in times of market upheaval or high volatility. Past performance is no guarantee of future results, and any historical returns, expected returns, or probability projections may not reflect actual future performance.

Quantitative Tools Risk

Some of Treasure’s techniques may incorporate, or rely upon, quantitative models. There is no guarantee that these models will generate accurate forecasts, reduce risks or otherwise produce the intended results.  

Allocation Risk

The allocation of investments among different asset classes may have a significant effect on portfolio value when one of these asset classes is performing more poorly than the others. In addition, there is a risk that certain asset allocation decisions may not achieve the desired results and, as a result, a client’s portfolio may incur significant losses.

Liquidity and Valuation Risk

High volatility and/or the lack of deep and active liquid markets for a security may prevent a client from selling her securities at all, or at an advantageous time or price because Apex may have difficulty finding a buyer and may be forced to sell at a significant discount to market value. Some securities (including ETFs) that hold or trade financial instruments may be adversely affected by liquidity issues as they manage their portfolios. Values of client’s Apex accounts are based on reasonably available exchange-traded security data. Inaccurate data could adversely affect valuations or transaction size for purchases or sales.

Credit Risk

Treasure cannot control and clients are exposed to the risk that financial intermediaries or security issuers may experience adverse economic consequences that may include impaired credit ratings, default, bankruptcy or insolvency, any of which may affect portfolio values or management. This risk applies to accounts with Apex, notwithstanding asset segregation and insurance requirements that are beneficial to clients generally. In addition, exchange trading venues or trade settlement and clearing intermediaries could experience adverse events that may temporarily or permanently limit trading or adversely affect the value of securities held by clients. Finally, any issuer of securities may experience a credit event that could impair or erase the value of the issuer’s securities held by a client. Treasure may seek to limit credit risk through ETFs, which are subject to regulatory limits on asset segregation and leverage such that fund shareholders are given liquidation priority versus the fund issuer; however, certain funds and products may involve higher issuer credit risk because they are not structured as a registered fund.

Foreign (Non-U.S.) Risk

An investment in securities of non-U.S. issuers may involve more risk than those of U.S. issuers. Their securities may fluctuate more widely in price and may be less liquid due to adverse market, economic, political, regulatory or other factors.

Emerging and Frontier Markets Risk

Securities of companies in emerging markets may be more volatile than those of companies in developed markets. By definition, markets, economies and government institutions are generally less developed in emerging market countries. Investment in securities of companies in emerging markets may entail special risks relating to the potential for social instability and the risks of expropriation, nationalization or confiscation. Clients may also face the imposition of restrictions on foreign investment or the repatriation of capital and a lack of hedging instruments. The risks associated with investing in foreign or emerging markets generally are magnified in frontier markets, also known as “next emerging” markets.  Some frontier markets may operate in politically unstable regions of the world and may be subject to additional geopolitical/disruption-of-markets risks.

Currency Risk

Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns.

Capitalization Risk

Investments in small- and mid-capitalization companies may be more volatile than investments in large-capitalization companies. Investments in small-capitalization companies may have additional risks because these companies have limited product lines, markets or financial resources.

Liquidity and Valuation Risk

High volatility and liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing the client from selling out of such illiquid securities at an advantageous price. Securities involving substantial market and credit risk also tend to involve greater liquidity risk.

Issuer Specific Risk

The value of an equity security may decline in response to developments affecting the specific issuer of the security, even if the overall industry or economy is unaffected. These developments may comprise a variety of factors, including, but not limited to, management issues or other corporate disruption, political factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or an adverse effect on the issuer’s competitive position.  

Concentrated Portfolios Risk

Concentrated portfolios are an aggressive and highly volatile approach to trading and investing. Concentrated portfolios hold fewer different stocks than a diversified portfolio and are much more likely to experience sudden dramatic prices swings. In addition, the rise or drop in price of any given holding is likely to have a larger impact on portfolio performance than a more broadly diversified portfolio.

Legal, Tax or Legislative Risk

Legislative changes or court rulings may impact the value of investments or the securities’ claim on the issuer’s assets and finances, including, but not limited to, changes in investment adviser or securities trading regulation, change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities and changes in the tax code that could affect interest income, income characterization, and/or tax reporting obligations (particularly for ETFs dealing in natural resources).

Inflation, Currency, and Interest Rate Risks

Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. The liquidity and trading value of foreign currencies could be affected by global economic factors, such as inflation, interest rate levels, and trade balances among countries, as well as the actions of sovereign governments and central banks.  In addition, the relative value of the U.S. dollar- denominated assets primarily managed by Treasure may be affected by the risk that currency devaluations affect client purchasing power.  

Cybersecurity Risks

Treasure is subject to risks associated with a breach in cybersecurity.  Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate, but unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose Treasure to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While we have established business continuity plans, incident responses plans and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks also are present for issuers of securities in which we invest, which could result in material adverse consequences for such issuers, and may cause a client’s investment in such securities to lose value.

Equity-Related Risks

The prices of equity securities will rise and fall.  These price movements may result from factors affecting individual companies, industries, or the securities market as a whole.  Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments.  The prices of securities issued by such companies may suffer a decline in response.  In addition, the equity market tends to move in cycles, which may cause stock prices to fall over short or extended periods of time.

Real Estate Risks

Real estate–related investments may be adversely affected by factors affecting the real estate industry, which may include changes in interest rates and social and economic trends.  Real estate investment trusts (REITs) may also be subject to the risk of fluctuations in income from underlying real estate assets, poor performance by the REITs’ managers, prepayments and defaults by borrowers, adverse changes in tax laws, and, for U.S. REITs, their failure to qualify for the special tax treatment granted to REITs.

Venture Capital Risks

Venture capital–related investments have a very high degree of risk and often require a long-term commitment.  Typically, venture capital-backed companies have limited or no operating history, unproven technology, untested management and unknown future capital requirements.  These companies may face intense competition, often from established companies.  These companies often require several rounds of financing before they reach maturity, which may have a significant negative impact on a fund which is unable to participate in subsequent rounds of financing.

Infrastructure Risks

Infrastructure-related investments are subject to a number of unique risks.  These investments may be concentrated into a small number of projects, resulting in a high degree of risk with respect to each project.  Further, these investments are often subject to foreign and emerging market risks.

Socially Responsible Investing

Investments may focus on “low carbon” or other areas of socially responsible investing.  This investment category represents a relatively new area of investment with a relatively limited performance track record.  Due to the consideration of non-monetary factors in investment decisions, these investments may experience a lower rate of return.  There may be a relatively limited number of investments to consider in this investment category, and available investments may be subject to increased competition.

Large Investment Risks

Clients may collectively account for a large portion of the assets in certain investments.  A decision by many investors to buy or sell some or all of a particular investment where clients hold a significant portion of that investment may negatively impact the value of that the investment.

Limitations of Disclosure

The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in investing in investments.  As investment strategies develop and change over time, clients may be subject to additional and different risk factors.  No assurance can be made that profits will be achieved or that substantial losses will not be incurred.

Risk Associated with Individual Stocks

The major risks associated with investing in common stocks relate to the issuer’s capitalization, quality of the issuer’s management, quality and cost of the issuer’s services, the issuer’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk and the issuer’s ability to create shareholder value (i.e., increase the value of the company’s stock price).

Note that there may be other circumstances not described here that could adversely affect a client’s investment and prevent their portfolio from reaching its objective.

Treasure Technologies Inc.
447 Sutter St
STE 405 PMB 25
San Francisco, CA 94108
Website is operated by Treasure Investment Management, LLC ("Treasure"), a wholly-owned subsidiary of Treasure Technologies, Inc., and an investment adviser registered with the U.S. Securities and Exchange Commission ("SEC"). Brokerage services are provided to clients of Treasure by Apex Clearing Corporation ("Apex"), an SEC-registered broker-dealer and member FINRA.

Investing involves risk, including loss of principal. The contents of this website are provided for information purposes only and do not constitute an offer to sell or a solicitation to buy securities. Past performance is no guarantee of future returns.