Goldman Sachs Smart Beta Portfolio Strategy Disclosure

The Goldman Sachs Smart Beta portfolio strategy (“smart beta portfolio”) is available for investors who wish to take greater systematic risk at a given allocation between stocks and bonds than is possible with a comparable allocation in the standard, default Betterment portfolio strategy (“Betterment’s core portfolio”).

The smart beta portfolio incorporates certain stock exchange traded funds (“ETFs”) that do not weight their holdings solely based on market capitalization (“smart beta equity ETFs”). The smart beta equity ETFs make rules-based adjustments to the market weights of their holdings based on four factors that have been identified in academic research as persistent drivers of investment returns in stocks: good value (measured by price to cash flow, price to sales, and price to book value ratios), high quality (measured by gross profits to total assets), low volatility (measured by standard deviation of returns), and strong momentum (measured by risk-adjusted returns over a defined period of time). For additional descriptions of the factors, see http://www.betterment.com/resources/inside-betterment/product-news/smart-beta-portfolio-strategy.

The smart beta portfolio also incorporates certain fixed income ETFs that do not weight their holdings solely based on market capitalization (“smart beta fixed income ETFs,” collectively with smart beta equity ETFs, “smart beta ETFs”). The smart beta fixed income ETFs make rules-based adjustments to the market weights of their holdings based on certain historical factors that have detracted from performance, including metrics relating to the amount of debt and profitability of the bond issuers.

In addition to using certain smart beta ETFs, the smart beta portfolio differs from Betterment’s core portfolio in several material ways. The smart beta portfolio may, at times, allocate more of its bond holdings to high yield and longer duration bonds, which may be riskier than the bonds held in Betterment’s core portfolio. Additionally, the smart beta portfolio could include exposure to a Real Estate Investment Trust (“REIT”) ETF, which is included in the stock allocation of the portfolio. Betterment’s core portfolio includes exposure to REITs through certain stock ETFs, but it does not include investments in REIT ETFs. REITs are subject to unique risks. In particular, REIT ETFs are sensitive to interest rate movements. REIT ETF dividends are also taxed at ordinary income rates, rather than at the preferential rates at which dividends from other ETFs may be taxed.

The smart beta portfolio is designed by Goldman Sachs Asset Management (“Goldman Sachs”) and is generally comprised of ETFs managed by Goldman Sachs but may also include ETFs managed by other fund managers. Because Goldman Sachs sets the fund fees (expense ratio) for Goldman Sachs ETFs selected for the smart beta portfolio, Goldman Sachs has a financial incentive to select its own funds for inclusion in the portfolio, even if those funds have higher costs than comparable ETFs offered by other fund managers.

The smart beta portfolio currently includes smart beta equity ETFs for U.S. large capitalization, U.S. small capitalization, international developed market, and international emerging market stocks, and the portfolio also includes smart beta fixed income ETFs for investment grade corporate bonds, high yield corporate bonds, international bonds, and inflation protected bonds. Further detail regarding the ETFs included in the smart beta portfolio, and Goldman Sachs’ methodology for constructing its smart beta ETFs, can be found in the prospectuses drafted by the managers of those funds. Copies of those prospectuses are available in the portfolio tab of your account.

The selection and relative weights of ETFs in the smart beta portfolio for a given allocation of stocks and bonds is determined by Goldman Sachs. Goldman Sachs may, at its discretion based on an evaluation of market conditions, change the relative weights of sub-asset classes within a particular allocation of stocks and bonds. For example, the target percentages of U.S. stocks, international developed market stocks, and emerging market stocks in a portfolio may vary even though the investor makes no change to the portfolio’s overall stock/bond allocation.

Betterment places trades to achieve the designated ETF allocations but retains discretionary authority not to place trades to implement a portfolio update provided by Goldman Sachs if Betterment determines that the update would be inconsistent with an investor’s initial investment direction. Goldman Sachs periodically reevaluates the selection of ETFs for each allocation, at which time Goldman Sachs may add or remove ETFs from the smart beta portfolio. Although Betterment will endeavor to implement changes to the smart beta portfolio as soon as possible after they are communicated by Goldman Sachs, Betterment retains discretion on whether and when to implement any such changes. If Goldman Sachs adds an ETF to the smart beta portfolio, Betterment typically will obtain exposure to that ETF through future investor contributions, dividend reinvestments, and/or rebalancing transactions to correct drift in the portfolio’s overall allocation.

The ETFs in the smart beta portfolio may be less diversified than the ETFs for comparable asset classes in Betterment’s core portfolio because the smart beta ETFs may concentrate their investments in certain industries or groups of industries, or exclude certain securities that do not satisfy the factor criteria. This may increase the risk of loss due to adverse economic, business, or other developments that affect those industries or companies. Reduced diversification also may increase the volatility of the smart beta portfolio relative to Betterment’s core portfolio.

Smart beta ETFs may be less liquid than the broad market ETFs used in Betterment’s core portfolio. This means that it may be more difficult to buy and sell certain ETFs in the smart beta portfolio without affecting their prices, relative to the ETFs in Betterment’s core portfolio. As a result, there may be increased trading costs to enter or exit positions in the smart beta portfolio relative to funds representing the same asset classes in Betterment’s core portfolio. This also may result in wider discrepancies between the market prices of the ETFs in the smart beta portfolio and the prices of their underlying baskets of securities than for comparable ETFs in Betterment’s core portfolio, particularly during times of market stress.

Investors in the Betterment smart beta portfolio will incur additional fund costs compared to investors in Betterment’s core portfolio because the ETFs in the smart beta portfolio have higher aggregate expense ratios than the funds used in Betterment’s core portfolio. The specific fees for each fund in the smart beta portfolio are listed in the funds’ prospectuses, which are available on the portfolio tab in your account

With respect to rebalancing, Investing portfolios require a portfolio minimum balance in order for a rebalancing transaction to occur (which can be the aggregate of balances in a tax-coordinated portfolio); see Betterment’s portfolio minimum disclosures for further details. If your Smart Beta portfolio balance exceeds the required minimum, Betterment will perform automatic rebalancing to correct drifts in allocations, aligning back to the target weights. The smart beta ETFs are rebalanced quarterly to match the indices the funds track, which also are updated quarterly. Such portfolio turnover may lead to increased trading costs relative to the ETFs in Betterment’s core portfolio, including brokerage commissions and taxes on short term capital gains. These costs are not included in the expense ratios of the smart beta ETFs (described above) but are included in the funds’ overall performance. Accordingly, portfolio turnover costs may cause smart beta ETFs to underperform the indices they track by a relatively greater amount than the ETFs in Betterment’s core portfolio, which have less turnover.

Investors considering the smart beta portfolio should understand how it impacts the operation of Betterment’s tax coordinated portfolio feature. The smart beta portfolio can be elected for goals in a tax coordinated portfolio, but all goals in that tax coordinated portfolio currently are required to use the smart beta portfolio.

Investors considering the smart beta portfolio should understand how it impacts the operation of Betterment’s tax loss harvesting feature. Betterment typically implements its tax loss harvesting feature by shifting allocations among three ETFs in each sub-asset class. The smart beta portfolio uses only two ETFs for certain asset classes, which limits the functionality of tax loss harvesting for households with IRAs that have elected the smart beta portfolio for one or more goals. Additionally, electing the smart beta portfolio for one or more goals in your account while simultaneously electing a different portfolio for other goals in your account may reduce opportunities to harvest losses. See Betterment’s TLH disclosures for further detail.