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ADV Pass terms of sale

Effective 19 October 2026 (revised). Replaces the version first published the same day. These terms are between Imperium Advisors, LLC, a California limited liability company ("Luna"), and the firm that buys an ADV Pass ("Firm"). Paying for an ADV Pass means the Firm accepts them. Luna's Terms of Service and Privacy Policy also apply; where they differ, these terms govern the ADV Pass.

Read this part first

Luna is not a law firm and gives no legal advice. The ADV Brochure Review describes how the Firm's brochure compares with what comparable firms commonly disclose. It makes no finding about whether the brochure meets any rule. A topic most peers address is common practice, not a requirement. Using Luna creates no attorney-client relationship.

The Firm decides. Every point to consider, every suggested wording and every item in the policies check is a suggestion for a person at the Firm to review. What the brochure says, and what is filed, is the Firm's decision and responsibility.

1. What the ADV Pass includes

  1. One ADV Brochure Review of the Firm's current Form ADV Part 2A brochure, as filed with the SEC: each of the 48 topics read, compared with firms of similar size and business model, with each point to consider quoted from the brochure or noted as absent.
  2. The review delivered by email as a PDF and a Word file, within one business day of Luna confirming the Firm's identity under Section 2.
  3. One refreshed review if the Firm files an amended brochure within 120 days of purchase (the "cycle").
  4. Suggested wording for each point to consider: the facts to confirm first, and one or more starting points for the brochure text, written for the Firm from its own brochure and Form ADV. Placeholders mark anything Luna does not know. Suggested wording is never copied from another firm's brochure.
  5. A policies check, if the Firm sends its compliance manual or written policies and procedures: where the manual describes a practice the brochure does not mention, where the brochure describes a practice the manual does not address, and where the two describe the same practice differently. The check compares the two documents. It does not test what the Firm actually does.
  6. Answers by email to questions about the review during the cycle.

The ADV Pass does not include preparing or filing the Firm's Form ADV, legal advice, or access to other Luna modules. Suggested wording is a starting point: the Firm edits and approves anything it files.

2. Who can buy it

An ADV Pass is for an SEC-registered investment adviser's own brochure. The buyer must be an employee or officer of the Firm, using an email address at a domain listed among the Firm's websites on its Form ADV, or otherwise verified by Luna. Luna does not prepare reviews of a firm for anyone outside that firm. If Luna cannot verify the buyer, Luna refunds the purchase in full.

One ADV Pass covers one firm (one CRD number) for one cycle.

3. Price and credit

The ADV Pass costs $795, charged once, plus any applicable tax. If the Firm subscribes to an annual Luna plan within 90 days of buying the ADV Pass, Luna credits the full $795 against the first annual invoice. The credit applies once, to annual plans only, and has no cash value.

4. Refunds

The Firm may cancel for a full refund at any time before its review is delivered, by writing to info@lunacompliance.io. After delivery, purchases are final, except where the law requires otherwise.

5. Information Luna uses

The review is prepared from the Firm's public Form ADV filings. Luna uses the buyer's name, email address and the Firm's CRD number to verify the buyer and deliver the review, as described in the Privacy Policy.

Any manual or policies the Firm sends are confidential. Luna uses them only to prepare the Firm's policies check, shares them with no one outside Luna, does not use them to train any model, and deletes them within 30 days after the cycle ends, or sooner if the Firm asks. Luna never names the Firm or quotes its brochure in anything it publishes.

6. Liability

The review is provided as is. Luna's total liability for an ADV Pass is limited to the amount the Firm paid for it. The limitations and exclusions in Luna's Terms of Service apply.

7. Contact

Questions about these terms: info@lunacompliance.io.