Client Disclosure Documents
At Banorte Ventures Ltd., doing business as Binvesting, we are committed to maintaining transparency and providing our clients with easy access to important regulatory and disclosure documents.
This disclosure page is structured to clearly distinguish between: (i) advisory disclosures applicable to Banorte Ventures Ltd.; (ii) broker-dealer disclosures relating to trade execution and brokerage services; and (iii) custodial and clearing disclosures relating to the custody and safeguarding of client assets. This structure is intended to promote transparency regarding regulatory obligations, conflicts of interest, and third-party service arrangements.
If you have any questions regarding these materials or would like to request a printed copy, please contact us at [email protected]
Section I – Investment Adviser Disclosures
When providing advisory services through the BInvesting platform, Banorte Ventures Ltd. acts solely in an investment advisory capacity and is subject to the fiduciary duty of care and loyalty under the Advisers Act.
The firm operates as an internet-based investment adviser and relies on the Internet Adviser Exemption under Rule 203A-2(e), where applicable. Advisory services are delivered through an interactive digital platform that utilizes algorithm-driven portfolio construction and model-based investment strategies.
- Advisory fees
[Download PDF] - Form ADV Part 2A – Firm Brochure
Describes our business, services, fees, and conflicts of interest.
[Download PDF] - Form ADV Part 2A – Appendix 1 (Wrap Fee Program Brochure)
Describes the features, fees, and conflicts specific to our wrap fee program.
[Download PDF] - Form CRS – Client Relationship Summary
A short summary of our services, fees, legal obligations, and conflicts.
[Download PDF] - Form ADV Part 2B – Brochure Supplement
- Salomon Lahana
[Download PDF] - Juan Valdivieso
[Download PDF] - Juan Carlos Barraza
[Download PDF] - Guillermo Peña
[Download PDF]
- Salomon Lahana
- Privacy Policy
Describes how we collect, use, and safeguard your personal information.
Read - Privacy Notice
Read - Terms and Conditions
- Cybersecurity Statement
Overview of how we protect client data and ensure secure access.
Read - Business Continuity Plan Summary
Overview of how we maintain operations during unexpected disruptions.
Read - Complaint and Feedback Procedures
Explains how clients can raise concerns or submit feedback.
Read
These documents describe advisory services, digital methodology, risks, material conflicts of interest, fee arrangements, and regulatory obligations.
Section II – Broker-Dealer Disclosures (Trade Execution)
Client securities transactions effected through the BInvesting platform are executed through a broker-dealer. The broker-dealer is responsible for trade execution, transaction processing, and related brokerage services.
BInvesting currently uses its affiliated broker-dealer, Banorte Securities International Ltd., for execution services. As the platform expands, additional broker-dealers may be added. Any changes will be reflected in updated disclosures.
- Banorte Securities International, Ltd. – CIP Notice
[Download PDF] - Brokerage and Custodial fees
[Download PDF] - ETF Disclosures
[Download PDF] - Banorte Securities International Ltd. – Form CRS – Client Relationship Summary
A short summary of our services, fees, legal obligations, and conflicts.
[Download PDF]
Broker-dealer services are distinct from advisory services and may involve transaction-based fees or other brokerage-related charges as disclosed.
Section III – Custodian and Clearing Firm Disclosures (Asset Custody)
Client assets are maintained with independent third-party custodians and/or clearing firms. Custodians are responsible for safeguarding client funds and securities, maintaining custody records, and delivering periodic account statements directly to clients.
Banorte Ventures Ltd., is deemed to have custody of client assets solely due to its authority to deduct advisory fees directly from client accounts, consistent with Rule 206(4)-2 under the Investment Advisers Act. Clients receive account statements directly from the qualified custodian and are encouraged to review those statements carefully.
The custodian and clearing firm currently utilized for BInvesting accounts is Pershing LLC. Additional custodians may be engaged as the platform evolves.
Custodians and clearing firms do not provide investment advice and operate independently from Banorte Ventures Ltd., except as otherwise disclosed.
Contact Information
If you have questions regarding these disclosures or would like to request printed copies, please contact:
Compliance Department
Banorte Ventures Ltd.
Email: [email protected]
This disclosure page is structured to enhance transparency regarding advisory services, execution arrangements, custody relationships, and the regulatory standards applicable to accounts opened through the BInvesting platform.