Disclosures

Relationship to Stance Capital’s advisory business

Stance Capital LLC is a Boston-based quantitative investment manager, founded in 2016 and registered with the SEC as an investment adviser. Stance 351 is one of its services. Its advisory business is a separate offering with its own disclosures: Form ADV, strategy documentation, and fee schedules are available at stancecap.com, and nothing on this platform restates or replaces them.

Using Stance 351 does not make you or your client an advisory client of Stance Capital LLC, and it is not an investment in any Stance Capital strategy. Any advisory engagement is a separate agreement.

Because Stance 351 is a Stance Capital service, a fund affiliated with Stance Capital appearing on the platform is a conflict of interest to be read as such. Where that happens the affiliation is disclosed on the fund page, and the platform applies the same eligibility and diversification tests to it as to any other listing.

Section 351 and tax risk

A qualifying Section 351 exchange produces tax deferral, not tax elimination. The contributing investor's original cost basis and holding period carry over to the fund shares received, which means a later sale will trigger recognition of previously deferred capital gains.

To qualify for non-recognition, a contribution must satisfy strict requirements. The contributed portfolio must meet the diversification test under Section 368(a)(2)(F)(ii) — generally, no more than 25% of value in any one issuer and no more than 50% in five or fewer issuers. In addition, contributing investors must collectively hold at least 80% of the fund immediately after the exchange, as defined by Section 368(c). Failure to satisfy these requirements may cause the entire transaction to be treated as taxable.

Further risks include post-contribution rebalancing risk and the risk that the IRS applies the substance-over-form doctrine to treat the exchange as a pre-arranged sale. Tax treatment is also subject to legislative and regulatory change, which could prospectively or retroactively affect these strategies.

Section 351 exchanges are complex and fact-specific, and there is no guarantee that any particular transaction will qualify. Consult a qualified tax adviser and legal counsel before contributing assets in reliance on Section 351.

Calculations, tests, and projections

Diversification tests, eligibility screens, optimisation results, and tax-deferral figures produced by the platform report whether a basket passes the tests the platform implements, on the data you supply. They are not advice, an opinion, or an assurance of any outcome, and a passing result is not a determination that a transaction qualifies under Section 351.

Results depend on the accuracy and completeness of the holdings, cost basis, and acquisition dates you provide, and on market data that may be delayed or estimated. The platform applies conservative buffers below statutory thresholds; that reduces the chance of a marginal pass, it does not convert a pass into a legal conclusion.

The platform evaluates two distinct statutory tests that are frequently conflated: the Section 368(a)(2)(F)(ii) diversification safe harbour, which protects the contributing investor, and the Regulated Investment Company qualification tests under Section 851(b)(3), which the fund itself must satisfy. Passing one does not imply passing the other.

Fund information

Fund information on this platform is provided by third parties and has not been independently verified. It is not an offer to sell or a solicitation to buy shares of any fund.

Investors should consider a fund's investment objectives, risks, charges, and expenses carefully before investing. This and other information is found in the fund's prospectus or summary prospectus, which should be read carefully before investing or sending money. All investing involves risk, including possible loss of principal. Past performance does not guarantee future results.

Contribution deadlines, launch dates, and terms are set and changed by the issuer, not by us. Where a fund is not yet effective, its terms remain subject to change through the registration process.

Asset and account eligibility

Not all assets can be contributed in kind. Mutual funds cannot be transferred in kind and would need to be liquidated first, which is itself a taxable event. Direct cryptocurrency holdings, private securities, restricted stock and RSUs, options and other derivatives, and cash are not eligible contributions.

Retirement accounts, including IRAs, generally do not produce a capital-gain deferral benefit because there is no gain to defer, and should be reviewed separately. ERISA plans cannot transfer without a Department of Labor exemption. C corporations may face built-in gains tax, and S corporations require further analysis.

Forward-looking statements

Statements about intended fund launches, expected timelines, target fund size, or anticipated tax treatment are forward-looking and subject to change. Fund launches may be delayed, restructured, or cancelled, and committed assets may be returned.