Item 1 - Cover Page
Version: 1.0
MONFLEX TECHNOLOGY CORP.
Form ADV Part 2A - Firm Brochure
(CRD# 344954)
Baizakov street 280
Republic of Kazakhstan, Almaty, 050000
+7 771 070 79 13
October 6th 2026
This brochure provides information about the qualifications and business practices of Monflex Technology Corp (hereinafter, “Monflex”, “the "Firm," "we," "us," or "our"). If you have any questions about this brochure, please contact us at damir.muratbekov@monflex.io.
The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser’s services.
Additional information about Monflex is available on the SEC's Investment Adviser Public Disclosure website at https://www.adviserinfo.sec.gov
Item 2 - Material Changes
This is Monflex’s initial Form ADV Part 2A firm brochure. Accordingly, there are no material changes to report. Subsequent annual updates to this brochure summarize material changes made since the most recent annual brochure update.
Item 3 - Table of Contents
Item 1 - Cover Page ................................................................................................................ 1
Item 2 - Material Changes ............................................................................................................................... 2
Item 3 - Table of Contents ............................................................................................................................... 3
Item 4 - Advisory Business ............................................................................................................................... 4
Item 5 - Fees and Compensation ..................................................................................................................... 7
Item 6 - Performance-Based Fees and Side-by-Side Management.................................................................... 9
Item 7 - Types of Clients .................................................................................................................................. 9
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss` ............................................................. 9
Item 9 - Disciplinary Information ................................................................................................................... 13
Item 10 - Other Financial Industry Activities and Affiliations .......................................................................... 13
Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ..................... 14
Item 12 - Brokerage Practices ........................................................................................................................ 14
Item 13 - Review of Accounts ........................................................................................................................ 15
Item 14 - Client Referrals and Other Compensation ....................................................................................... 16
Item 15 - Custody .......................................................................................................................................... 16
Item 16 - Investment Discretion .................................................................................................................... 17
Item 17 - Voting Client Securities ................................................................................................................... 17
Item 18 - Financial Information ..................................................................................................................... 17
Item 4 - Advisory Business
Firm Organization and SEC Registration
Monflex is a corporation organized under the laws of the State of Delaware in September 2026. The Firm is 100% owned directly by MONFLEX HOLDINGS LIMITED, and indirectly 100% owned by Manas Bissaliyev.
Monflex is applying for registration with the Securities and Exchange Commission (“SEC”) on the basis that its principal office and place of business is outside the United States. Monflex will provide investment advisory services through its mobile application and related digital platform, as described below. Registration with the SEC does not imply a particular level of skill or training.
Upon the effectiveness of its registration, Monflex will provide investment advisory services in accordance with its advisory agreements and applicable federal securities laws. Additional information regarding the Firm’s advisory services, investment process, fees, and client requirements is provided below.
Investment Advisory Services and Client Information:
Monflex provides its live-trading advisory service on a non-discretionary basis. Each client must approve a proposed trade setup before Monflex transmits the entry order. After execution, Monflex may transmit only those exit orders authorized by the client as part of the approved trade setup. A user may create an account and access general educational features before establishing an advisory relationship. Before receiving personalized bot selections, investment recommendations, or security-specific trade setups, the user must complete Monflex’s digital investment questionnaire, receive this brochure, and enter into an investment advisory agreement with Monflex. These requirements apply to personalized recommendations provided in both Demo mode and live trading mode.
The questionnaire collects information concerning the client’s financial situation, investment objectives, tolerance for loss, ability to bear loss, liquidity needs, and other circumstances relevant to the service. Monflex uses this information to determine the client’s investment profile and the supported strategies, investments, and trading parameters available to the client. Clients must promptly update information that has materially changed and are prompted at least annually to review their investment profile. Monflex does not consider financial circumstances, assets, liabilities, accounts, or tax information that the client does not provide through the platform.
Demo mode uses simulated funds and does not submit live orders or hold actual investments. Personalized recommendations displayed in Demo mode remain subject to Monflex’s advisory onboarding requirements. A client does not need an Alpaca account to use Demo mode. Before enabling live trading, the client must establish or connect an eligible Alpaca account and separately complete the applicable brokerage agreements and account-access authorizations.
Client Tailoring and Restrictions
Monflex uses questionnaire responses to assign a client to a risk group and recommend supported trading strategies. Risk tolerance and ability to bear loss inform the client’s risk group, while investment objectives and liquidity needs inform strategy selection. The platform uses the client’s profile to determine available bots and investments and to configure position sizes, stop-loss levels, and take-profit levels. For live trading, position sizing also takes available buying power into account.
Clients select among the bots and investments made available for their profile and may decline any proposed trade. A client may avoid recommendations involving a particular supported security by not selecting that security for monitoring. Monflex does not offer a separate instruction to permanently exclude a particular security or sector and does not individually modify a bot’s underlying signal-generation rules at a client’s request.
The platform separately asks about trading familiarity to determine whether explanations use beginner, intermediate, or advanced terminology. Trading familiarity changes the presentation and level of detail of an explanation; it does not independently change the underlying trade signal or establish that an investment is appropriate for the client.
Monflex’s advice is limited to the platform’s supported investments and strategies. If the program cannot accommodate a client’s needs or restrictions, Monflex may decline or terminate the advisory relationship.
Use of Artificial Intelligence
Monflex’s trading bots generate trade signals using predefined, rules-based calculations. Artificial intelligence does not generate the underlying trade signal, calculate the Setup Strength score, or determine the security, position size, or order instructions.
Monflex uses an artificial intelligence explanation layer to describe the technical conditions underlying an identified trade setup, explain its setup strength score, and summarize relevant asset news when available. The explanation uses information supplied by the platform, including strategy conditions, market data, technical indicators, and the client’s trading familiarity. The level of technical detail varies with trading familiarity. News summaries provide additional context and do not determine the underlying technical signal. These explanations accompany Monflex’s investment recommendations and do not constitute an independent investment selection process.
Monflex separately offers AI Mentor as an optional educational feature that explains general investment concepts, charts, technical indicators, and information displayed in the application. AI Mentor is designed to decline requests for individualized investment recommendations and does not select investments or bots, generate trade setups, or submit orders.
Artificial intelligence outputs may be inaccurate, incomplete, outdated, or inconsistent. Neither an AI explanation nor an AI Mentor response guarantees the accuracy of information, the suitability or profitability of a transaction, or any investment result. Monflex remains responsible for the advisory services it provides through the platform.
Limited Scope of Advice
Monflex’s live-trading advisory service is limited to supported U.S.-listed equity securities and exchange-traded funds available through the platform. Monflex also provides personalized cryptocurrency trade setups in Demo mode. These setups use simulated funds and do not result in the purchase, sale, transfer, or custody of actual cryptocurrency.
At launch, Monflex will not transmit live cryptocurrency orders or provide ongoing management of actual cryptocurrency holdings. Live trading does not include short sales, options, or margin trading. Availability of a cryptocurrency in Demo mode does not mean that Monflex supports live trading in that asset.
Monflex does not provide comprehensive financial planning, retirement planning, estate planning, or tax planning, and does not provide ongoing management of investments held outside the connected account.
Wrap Fee Programs
Monflex does not sponsor, participate in, or serve as a portfolio manager for a wrap fee program.
Assets Under Management
As of the date of this filing, Monflex is a newly formed investment adviser that reports $0 in discretionary regulatory assets under management and $0 in non-discretionary regulatory assets under management.
Item 5 - Fees and Compensation
Subscription Fees
Monflex charges a subscription fee for its digital advisory service. Clients who subscribe through the Monflex website may choose a plan costing $39.99 every four weeks or $79.99 every 12 weeks. Monflex also offers a one-week introductory subscription for $6.93 that automatically renews at $39.99 every four weeks unless cancelled. Introductory discounts may apply to the first charge. Clients who subscribe through the Apple App Store or Google Play may choose a plan costing $9.99 per week or $24.99 per month. Monflex offers 3-day free trial for weekly plan on Apple App Store and Google Play. This free trial does not apply to subscriptions bought through Monflex's website. Monflex does not offer a free tier or first-year fee waiver at launch. Subscription fees are non-negotiable.
Subscription fees are charged in advance at the beginning of each billing period to the client’s selected payment method. Monflex does not deduct subscription fees from brokerage accounts or charge an asset-based advisory fee. The prices stated above exclude any applicable VAT. Live trading requires the client to have an Alpaca brokerage account.
The subscription provides access to Demo functionality, supported platform content, and, after completion of advisory onboarding and connection of an eligible Alpaca account, the live-trading advisory service. The subscription price does not increase solely because a client enables live trading. Personalized recommendations are unavailable until the client completes the required investment profile and enters into the advisory agreement.
AI Mentor Fee
Monflex offers AI Mentor as an optional paid add-on separate from the core subscription. AI Mentor is sold as a one-time purchase with lifetime access at USD 99.99 (discounts may be applied to this offer). The add-on may be purchased, declined, or added later and is not required to access the core application, trading bots, Demo functionality, or other educational content.
Termination and Refunds
Subscriptions renew automatically at the end of each billing period at the then-current price unless cancelled. A client who subscribed through the Monflex website may cancel automatic renewal in the app by selecting Profile → Settings → Manage Subscription → Cancel Subscription. A client who subscribed through the Apple App Store or Google Play must cancel through the applicable store’s subscription settings. Cancellation
prevents future subscription charges. The advisory agreement and access to advisory services continue through the end of the current paid period unless the client requests earlier termination.
A client may terminate the advisory agreement before the end of a paid period via the application. If the agreement terminates early, Monflex will not refund the unearned portion of the prepaid advisory subscription fee, and shall provide services untill the end of the billing period. For an app-store purchase, Monflex will work with the client through the applicable store’s refund process. Monflex may grant additional refunds after reviewing a client’s request.
When the advisory agreement ends, Monflex stops providing investment recommendations and transmitting orders for the client at the end of the billing period. At the end of the period, the client positions will be liquidated, with notification to the client. The client’s ability to access, retain, transfer, or close the Alpaca account is governed by Alpaca’s account procedures.
Other Fees and Expenses
The subscription fee does not include all costs a client may incur. Clients may pay brokerage, custody, account-maintenance, transfer, wire, electronic-funds-transfer, regulatory, tax, or other charges imposed by Alpaca or another service provider. ETFs also charge internal management fees and other fund expenses, which are described in each fund's prospectus and reduce investment returns. These costs are separate from and in addition to Monflex fee.
A client could obtain some or all of the services available through Monflex separately from other providers and may pay more or less by doing so. Clients should consider the combined cost of the subscription fee, brokerage and custody charges, and underlying investment expenses.
Compensation for the Sale of Securities
Neither Monflex nor its supervised persons receive sales commissions, 12b-1 fees, or other transaction-based compensation from the securities recommended to clients. Economic benefits related to or other service providers are described in Item 14.
Item 6 - Performance-Based Fees and Side-by-Side Management
Monflex does not charge performance-based fees and does not engage in side-by-side management of accounts that pay performance-based fees and accounts that do not.
Item 7 - Types of Clients
Monflex generally provides its advisory program to individuals.
Monflex does not impose a minimum balance to establish an advisory relationship or access the digital platform. Monflex currently accepts clients only in jurisdictions in which the Firm has determined that it may lawfully provide its services.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss`
Methods of Analysis and Investment Strategies
Monflex uses predefined, rules-based technical analysis to identify potential trade setups. Supported strategies include Trend, which seeks an established price direction; Momentum, which seeks price movements gaining strength; and Reversal, which seeks a pullback followed by signs of potential recovery. Each strategy evaluates specified combinations of price movements, trading volume, trend indicators, volatility measures, and other technical conditions. A setup is generated when the applicable programmed conditions are satisfied.
The underlying signal-generation process is deterministic: the same market data applied to the same strategy parameters produces the same signal. Client information is used separately to determine strategy eligibility, the available investment universe, and applicable position-sizing and exit parameters. Artificial intelligence explains the resulting setup and may summarize relevant news, but does not create the underlying technical signal or calculate its score.
The platform assigns each identified setup a Setup Strength score from 0 to 100 using a fixed formula that combines signal margin, trend alignment, participation, and volatility fit, with each component contributing up to 25 points. Scores below 40 are classified as Weak, scores from 40 through 69 as Moderate, and scores from 70 through 100 as Strong. The platform displays only setups scoring 40 or higher. The score measures the degree of alignment with the strategy’s technical conditions. It is not a probability of profit, an expected return, or a guarantee that a setup is appropriate for a particular client.
For live trading, a proposed setup identifies the investment, entry order, position size, and applicable stop-loss and take-profit instructions. Position sizes and exit parameters reflect the client’s profile and the platform’s programmed controls, with available buying power also considered for live orders. The client must approve the proposed setup before Monflex transmits an entry order. Subsequent exit orders are limited to the instructions the client previously approved.
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Material Risks
Risk of Loss. Investing in securities involves risk of loss, including the potential loss of principal. Monflex does not guarantee investment performance, the achievement of any investment objective, or that any portfolio or transaction will be profitable.
Artificial Intelligence Explanation Risk. AI-generated explanations and news summaries may contain factual errors, omit relevant information, misinterpret technical signals, or present unsupported conclusions. An explanation may sound confident even when the underlying information is incomplete or incorrect. News may be stale, inaccurate, or inconsistent with the technical signal. An AI explanation does not change the underlying rules-based methodology or eliminate the risks of the recommended investment. Clients may give an explanation more weight than it warrants when deciding whether to accept a trade.
Setup Strength Risk. Setup Strength reflects selected technical conditions under Monflex’s scoring methodology. A high score does not establish the probability of a profitable trade, account for every material risk, or prevent a loss. Historical relationships among indicators may change, and stronger technical alignment may not produce better investment results.
Demo and Simulated Trading Risk. Demo transactions use simulated funds and do not reflect actual execution. Simulations may not fully account for bid-ask spreads, liquidity, slippage, transaction costs, order rejection, partial fills, market impact, or the effects of trading with real money. Simulated results are not actual client investment returns and should not be relied upon as a prediction of live results. A client who independently executes a Demo recommendation outside Monflex may incur actual losses; Monflex does not transmit or monitor those external transactions.
Cryptocurrency Risk. Cryptocurrency prices may be highly volatile and may decline substantially or become worthless. Relevant risks include limited liquidity, market manipulation, unreliable pricing, cyberattacks, fraud, trading-platform failures, network outages, protocol changes, and changes in legal or regulatory treatment. Markets may operate continuously, and prices may differ across venues. Technical signals and simulated execution may not reflect these conditions accurately. Monflex’s cryptocurrency functionality is limited to Demo mode at launch and does not involve actual cryptocurrency holdings, custody, or execution.
Limited Diversification and Cumulative Exposure Risk. A client may monitor or trade a limited number of investments, resulting in concentration in particular issuers, sectors, or correlated assets. Profile-based position sizing and trading controls do not ensure diversification or prevent loss. Multiple transactions and open positions may create cumulative exposure materially greater than an individual order’s size.
Market Risk. Securities markets may decline because of economic, political, regulatory, issuer-specific, public health, geopolitical, or other events. A diversified portfolio may lose value, and diversification does not ensure a profit or protect against loss.
Client Information Risk. The quality and appropriateness of Monflex’s advice depend on the completeness, accuracy, and timeliness of the information supplied by the client. Inaccurate, incomplete, or outdated information may result in an inappropriate portfolio assignment, strategy selection, or transaction. Monflex may not independently verify all information provided by a client.
Rules-Based Technical Strategy Risk. Monflex’s strategies use historical and current price, volume, trend, and volatility information to identify trade setups. Technical indicators may lag market developments or generate false or repeated signals. An identified trend may reverse, momentum may weaken, and a perceived recovery may fail to occur. Strategies may perform poorly during volatile, range-bound, rapidly changing, or illiquid markets. The underlying technical signal does not incorporate a comprehensive assessment of an issuer’s financial condition, valuation, earnings, management, or other fundamental information. AI-generated news summaries do not change the underlying signal-generation methodology.
Frequent Trading Risk. Certain bots may generate multiple trade recommendations during a trading day. Frequent trading may increase bid-ask spread costs, execution costs, market-impact costs, slippage, and short-term taxable gains, even when the broker does not charge a stated commission. These costs may materially reduce investment performance. The subscription fee may also represent a substantial percentage of the assets used for trading, particularly for clients with small account balances.
Stop-Loss and Take-Profit Risk. Stop-loss and take-profit levels do not guarantee execution at the specified price or limit a client’s loss to the stated percentage. Market gaps, trading halts, rapid price movements, insufficient liquidity, rejected orders, partial executions, or technology failures may cause an order to execute at a materially different price or not execute at all. A stop order may become a market order when triggered and may be executed below the applicable stop price.
Client Selection Risk. Clients select the securities monitored by a bot and may select a bot or strategy that is inconsistent with their investment profile. The platform uses profile-based controls to identify and restrict potentially inconsistent selections, but those controls may not identify every circumstance in which a selection is inappropriate. A client’s failure to provide complete, accurate, and current information may cause the platform to provide inappropriate advice.
Algorithm and Data Risk. The bots depend on accurate market data, correctly implemented code, and the continued availability of Monflex’s systems and third-party systems. Errors in data, calculations, programming, configuration, testing, or deployment may result in an incorrect, delayed, duplicated, or omitted recommendation or order. Monflex may suspend a bot or automated trading when it identifies an error, abnormal output, unavailable data, stressed market conditions, or another circumstance that could materially impair the operation of a strategy.
AI Mentor Risk. AI Mentor uses artificial intelligence to generate plain-language responses. Its responses may be inaccurate, incomplete, outdated, internally inconsistent, or based on an incorrect interpretation of a client’s question. AI Mentor may not consider all information relevant to a client’s financial circumstances, investment objectives, or risk tolerance. A response from AI Mentor should not be understood as a guarantee of accuracy, execution, investment performance, or any particular investment result.
Fractional Share Risk. Notional orders may result in the purchase of fractional shares. Fractional shares may be subject to different execution, liquidity, voting, transfer, and liquidation practices than whole shares and may be tradable only through the custodian that executed the transaction.
Technology and Cybersecurity Risk. Monflex’s advisory services depend on software, networks, cloud services, market-data feeds, payment processors, Alpaca, and other service providers. System outages, cyberattacks, unauthorized access, vendor failures, data corruption, or data loss may interrupt investment advice, trading, account access, or reporting and may result in financial loss or the disclosure of confidential information.
Artificial Intelligence Interface Risk. Artificial intelligence-assisted interface and data-capture features may misunderstand, incorrectly summarize, or inaccurately display information provided by a client. Clients are responsible for reviewing information submitted through or displayed by the platform. Artificial intelligence-generated interface outputs are not a substitute for the platform’s rules-based investment recommendations or for advice from a qualified tax, legal, or financial professional.
ETF and Underlying Fund Risk. ETF shares may trade above or below their net asset value, may not track their underlying index or strategy as expected, may become less liquid, or may be halted or delisted. Clients indirectly bear each ETF’s management fees and other expenses and are exposed to the risks associated with the ETF’s underlying investments.
Equity Risk. Equity securities and equity ETFs may be volatile and may lose substantial value because of general market conditions, issuer performance, sector developments, regulatory changes, or changes in investor sentiment.
Liquidity Risk. During stressed or disrupted markets, an ETF or other security may be difficult to purchase or sell at a reasonable price. Transactions may execute at prices materially different from displayed or quoted values or may not execute at all.
Tax Risk. Purchases, sales, rebalancing transactions, and distributions may create taxable income, gains, or losses. Monflex does not provide individualized tax advice and does not guarantee any particular tax treatment or outcome.
Cash Risk. Cash may lose purchasing power because of inflation and may earn less than other investments. A cash sweep or similar cash-management program may be subject to interest-rate, eligibility, insurance, liquidity, and counterparty risks.
Item 9 - Disciplinary Information
Monflex is required to disclose legal or disciplinary events that are material to a client's or prospective client's evaluation of the Firm's advisory business or the integrity of its management. Neither Monflex nor any of its management persons has a material legal or disciplinary event to disclose.
Item 10 - Other Financial Industry Activities and Affiliations
Broker-Dealer and Futures Activities
Neither Monflex nor any of its management persons is registered, or has an application pending to register, as a broker-dealer or registered representative of a broker-dealer. Neither Monflex nor any of its management persons is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading adviser, or associated person of any of those entities.
Monflex does not recommend or select other investment advisers for clients and does not receive compensation from other investment advisers.
Affiliated Technology Provider
Monflex licenses certain software, algorithms, intellectual property, and related technology from MONFLEX OPERATIONS LIMITED, an entity under common ownership with Monflex. The affiliate develops, owns, maintains, and supports the technology used to generate and deliver investment advice through the platform. Monflex pays the affiliate a technology and services fee
MONFLEX OPERATIONS LIMITED also collects certain subscription payments on behalf of Monflex. Monflex remains the contracting investment adviser and is responsible for the advisory services described in this brochure. Collection of a payment by the affiliate does not transfer the advisory relationship to that affiliate.Common ownership creates an incentive for Monflex to use the affiliate’s technology instead of evaluating unaffiliated alternatives. Monflex remains responsible for the investment advice provided to its clients and for compliance with applicable law. The Firm oversees the affiliate through contractual requirements, access controls, change-management procedures, testing, incident reporting, business-continuity arrangements, and periodic review of the technology’s operation and performance. A failure of the affiliate or termination of the licensing arrangement could impair or interrupt Monflex’s advisory services.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
Code of Ethics
Monflex has adopted and maintains a Code of Ethics designed to reflect the Firm's fiduciary obligations and require compliance with applicable federal securities laws. The Code addresses standards of conduct, protection of material nonpublic and confidential information, personal securities reporting, review of personal trading, gifts and entertainment, outside business activities, and reporting of violations. Monflex provides a copy of its Code of Ethics to any client or prospective client upon request.
Personal Trading and Participation in Client Transactions
Monflex and its related persons may buy or sell for their own accounts the same ETFs or other securities that are held in or recommended for client accounts. This creates a conflict because a related person's transaction could occur before, at the same time as, or after a client transaction and could benefit from market activity related to client trading.
The Firm addresses this conflict through its Code of Ethics, including personal holdings and transaction reporting, quarterly review of access-person brokerage activity, restricted-list or preclearance controls when appropriate, and prohibitions on misuse of client information and other fraudulent or manipulative conduct.
Monflex does not recommend to clients a security in which the Firm or a related person has a material financial interest as an issuer, underwriter, general partner, or similar capacity.
Item 12 - Brokerage Practices
Required Custodian and Broker-Dealer
Clients using Monflex’s live-trading service must establish or connect an eligible account with Alpaca Securities LLC (“Alpaca”), an unaffiliated broker-dealer and qualified custodian. Alpaca holds the client’s securities and cash and provides execution, custody, account statements, and related services. An Alpaca account is not required to receive personalized recommendations in Demo mode. Monflex does not transmit orders to other brokerage firms or provide ongoing monitoring of investments held at those firms.
Monflex requires Alpaca because the Firm's digital platform, account-opening process, model trading, and operational controls are integrated with Alpaca systems. Clients cannot use another broker-dealer or custodian for the Monflex program. This requirement limits a client's ability to compare or obtain services, pricing, execution, or features available from other firms.
Best Execution
As a fiduciary, Monflex has a duty to seek best execution for client transactions. Best execution is not limited to the lowest commission or price and may include execution quality, speed, likelihood of execution, order-routing practices, financial condition, responsiveness, technology, custody and reporting services, and the overall costs and benefits to clients. Monflex periodically reviews the execution quality provided by Alpaca.
Because all program accounts use Alpaca, Monflex does not solicit competitive bids or select a broker on a trade-by-trade basis. Clients may be able to obtain lower costs, different services, or more favorable execution elsewhere. Monflex periodically evaluates Alpaca execution quality, costs, order routing, financial condition, services, and technological performance to determine whether continued use of Alpaca is consistent with the Firm's best-execution obligations.
Trade Aggregation and Allocation
Monflex does not aggregate client orders. Each client-approved order is submitted separately for that client’s account. Clients may receive different execution prices and times and do not receive an average block price. Separate orders may also forgo pricing or other benefits available through aggregation. An order may be rejected, partially filled, or remain unfilled because of market conditions, available liquidity, order restrictions, or broker procedures. Any partial fill relates solely to the account for which the order was submitted and is not allocated among other clients.
Research and Other Brokerage Benefits
Monflex does not receive research or brokerage products or services under a client commission or soft-dollar arrangement and does not select Alpaca in exchange for client referrals.
Item 13 - Review of Accounts
Automated Reviews
Accounts are reviewed by Monflex’s automated system at least monthly and when specified events occur, which may include deposits, withdrawals, changes to client-profile information, changes to selected bots or assets, open-position activity, or other programmed review triggers. The system monitors the client’s selected securities, bot activity, open positions, available cash, and relevant client-profile information. Under the non-discretionary mode, any trade recommendation generated by the system requires client approval before submission.
Monflex’s Infrastructure team will monitor the operation of the platform, model outputs, data feeds, trade exceptions, and vendor performance. This operational oversight does not involve assigning a human adviser to provide individualized recommendations or manually tailoring advice for a particular client.
Client Reports and Communications
Clients may access electronic information concerning their recommendations and simulated activity through the platform. Clients with connected live accounts may also view supported holdings and transaction information obtained from Alpaca. This information is available on demand and may be affected by data-feed or processing delays. Demo results are identified as simulated and are presented separately from actual account activity.
Alpaca provides live-account statements at least quarterly and transaction confirmations as required. Clients should review Alpaca’s official records and compare them with information displayed through Monflex. Differences may arise from reporting dates, pricing sources, calculation methods, or timing. Monflex does not provide separate periodic written account reports beyond the electronic information described above.
Item 14 - Client Referrals and Other Compensation
Client Referrals
Monflex does not pay cash or non-cash compensation for client referrals, testimonials, or endorsements and does not operate a referral or promotional-incentive program.
Other Compensation
Monflex does not receive sales commissions, 12b-1 fees, or compensation from ETF sponsors for recommending investments. The Firm does not receive client referrals from a broker-dealer or other third party in exchange for brokerage or other business.
Item 15 - Custody
Client assets are maintained in the client’s name with Alpaca, a qualified custodian. Clients may access Alpaca’s account-opening, deposit, and withdrawal functionality through an embedded or integrated interface within the Monflex application. Each deposit or withdrawal instruction is initiated and authenticated by the client and transmitted directly to Alpaca. Monflex cannot initiate a withdrawal, designate or change a destination account, alter a client’s transfer instruction, or transfer client assets to Monflex or a third party.
Monflex does not possess client brokerage credentials and does not deduct advisory fees from custodial accounts. Alpaca sends account statements directly to clients at least quarterly. Clients should carefully review those statements and compare them with information displayed through the Monflex application.
Item 16 - Investment Discretion
Monflex does not accept discretionary authority to select and place a new entry trade in a client account without that client’s approval. Before an entry order is transmitted, the client reviews and approves a proposed trade setup identifying the security, notional position size, proposed entry order, and applicable stop-loss and take-profit instructions. After an approved entry order executes, the platform may transmit an exit order only in accordance with the exit instructions the client previously authorized. Monflex will not change the approved security, position size, or exit parameters or place an additional entry order without further client authorization.
Item 17 - Voting Client Securities
Monflex does not accept authority to vote proxies or other client securities and does not advise clients how to vote a particular proxy. Clients receive proxy materials directly from Alpaca, the relevant custodian, transfer agent, or issuer and are responsible for voting. The Firm does not provide individualized voting advice, clients must contact the issuer for additional information.
Item 18 - Financial Information
Monflex does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy petition during the past ten years.
Monflex does not have custody of client funds or securities. The Firm does not require or solicit prepayment of more than $1,200 in advisory fees per client six months or more in advance. Accordingly, a balance sheet is not required to be included with this brochure.