Carry Advisors is a investment adviser based in Brooklyn, NY, that holds a 92.2/100 Fidelon TransparencyScore (77th percentile among investing apps), with 1 registered advisor. Score based on public SEC and FINRA filings.
Carry Advisors
Carry Advisors LLC · CRD #323620
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Carry Advisors LLC is an SEC-registered investment adviser in Brooklyn, NY. It used to be called Ocho Investment Advisors, LLC. It has one registered advisor. It manages $180.9 million across 8,933 client accounts. It charges one yearly percentage of your account, and it does not report earning commissions. Its services include financial planning. Its record shows no customer complaints, regulatory actions or fines.
This firm gives most advice through an app and also has 1 registered advisor. You may not be matched with a specific one.
Peer Context
Ranked among investing apps, not against advisory firms that work with you in person.
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the All accounts band, charged at 0.00% on the full amount.
Not included above
- • Carry Core Membership costs $29/month or $299 annually. Carry Pro Membership costs $49/month or $499 annually (paid to parent Lettuce Financial Labs Inc.). Internal fund expenses (ETFs, mutual funds, money market funds). DriveWealth custodian fees for account maintenance, wire transfers. Cash sweep revenue sharing to affiliated broker-dealer. No 12b-1 fees or revenue sharing from fund sponsors.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| All accounts | 0.00% |
Billed monthly in arrears
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“Reinvested dividends grow your account, which increases the advisory fees we collect.”
“Our parent company, Lettuce Financial Labs Inc., earns those membership fees, so we have an indirect financial incentive for you to remain a Carry member.”
Source: the firm’s own Form CRS, filed 2026-07-27 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
97/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
82/100
Strong
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 63/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
What to askAsk the advisor to name every way the firm gets paid besides your fee, and how each one can affect their advice.
- 58/100
- Can you tell what you would pay?
- What you pay
What to askAsk what you would pay in a year, in dollars, including fund and trading costs.
- 59/100
- Is it written in plain English?
- Plain language
- 95/100
This firm's Form CRS averages 69 out of 100 and adds 2.19 points to the score above.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity88/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
The current annual advisory fee for these programs is 0.00% of assets under management (i.e., no advisory fee is charged).p. 2
- Does it say whether the fee can be negotiated?Not found in the brochureItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
What to askAsk whether the fee is negotiable, and what other clients at your account size pay.
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
If and when an advisory fee is reinstated, fees would be calculated daily, accrued and deducted monthly in arrears by instructing the qualified custodian to liquidate fund shares or debit cash.p. 10
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
If and when an advisory fee is reinstated, fees would be calculated daily, accrued and deducted monthly in arrears by instructing the qualified custodian to liquidate fund shares or debit cash.p. 10
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
You will also incur certain charges imposed by third parties other than the Firm.p. 13
- Does it say how you get money back if you leave mid-period?Does not applyItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity82/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If it has an affiliated adviser or private fund, does it explain what that means for you?
An affiliated adviser or private fund
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Carry Advisors is a wholly owned subsidiary of Lettuce Financial Labs Inc. (“Lettuce”), which acquired the Firm on May 27, 2026.p. 19
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
We therefore have an indirect financial interest in clients maintaining a Carry membership.p. 19
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Clients must maintain an active Carry membership, which is provided by Lettuce, to access our advisory services, and membership fees are paid to Lettuce.p. 19
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?CoveredStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
The Carry membership fees may be similar to, or more expensive than, fees offered by other similar firms.p. 13
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether any fund or adviser recommended to you is owned by or tied to the firm, and what fees that adds.
If it uses an affiliated broker-dealer, does it explain what that means for you?
An affiliated broker-dealer
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Carry Advisors is under common control with Global Carry LLC, a FINRA-member introducing broker-dealer that routes orders to DriveWealth LLC, an unaffiliated clearing broker-dealer and qualified custodian.p. 19
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This financial arrangement creates an incentive for us to transfer and retain your account at Global Carry and to maintain uninvested cash in the sweep program.p. 20
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Because Carry Advisors and Global Carry LLC are under common control (both are wholly owned subsidiaries of Lettuce Financial Labs Inc.), we receive indirect economic benefits when assets are custodied at DriveWealth through Global Carry LLC.p. 19
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
These benefits include a share of the interest DriveWealth earns on uninvested client cash swept into the Bank Sweep Deposit Programp. 19
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether your trades or products go through a company the firm owns or is tied to, and what that costs.
If the firm gets payments from product sponsors, does it explain them?
Revenue sharing with product sponsors
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
DriveWealth and its administrative service provider earn fees from the program banks based on the average daily deposit balance, which reduces the interest rate paid to you.p. 13
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This creates a conflict of interest: we have a financial incentive to maintain uninvested cash in your account rather than deploying it into securities or recommending that you move it to a higher-yielding alternative.p. 13
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Our affiliated introducing broker-dealer, Global Carry LLC, receives a share of the interest DriveWealth earns on swept cash.p. 13
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?CoveredStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
DriveWealth and its administrative service provider earn fees from the program banks based on the average daily deposit balance, which reduces the interest rate paid to you.p. 13
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk which product companies pay the firm, how much, and whether those products end up in your account.
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes no research or services from brokers
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #323620