These documents were prepared as part of the Plaid integration application process and cover information security, data access, terms of service, privacy policy, and the Thesis business model.
| Field | Detail |
|---|---|
| Legal Name | Thesis (operating name) |
| Business Type | Financial Technology Platform |
| Jurisdiction | United States |
| Regulatory Status | Unregulated (not an RIA, Broker-Dealer, or Bank) |
| SEC Registration | Not required — does not meet the definition of Investment Adviser under the Investment Advisers Act of 1940 |
| State Registration | Not required |
| FINRA Membership | Not applicable |
| SIPC Membership | Not applicable |
| FDIC Insurance | Not applicable |
Thesis is an educational investing platform — a mobile application that helps users learn investing fundamentals, build their own investment thesis (the "why" behind their buys), and compare their real brokerage holdings against their self-directed thesis model.
Revenue is generated exclusively through affiliate partnerships with brokerages, high-yield savings providers, and credit card issuers. Thesis earns a referral fee when a user opens an account through an affiliate link.
Thesis does not:
Last updated: June 2026
Personal Financial Management (PFM) with Investment Thesis Builder
Thesis is a mobile application in the Personal Financial Management category — similar to Monarch, Copilot, and Mint with an added educational investing layer. Users connect their existing financial accounts to view their complete financial picture and compare their real portfolio allocation against a self-built investment thesis model.
Learn (courses + glossary + Ask AI)
↓
Thesis Builder (pick themes, customize allocation, name conviction)
↓
Connect Accounts (Plaid — see real portfolio)
↓
Compare (real holdings vs thesis model)
↓
Research (duel comparisons, catalyst sweeps, AI analyst debates)
↓
Act (open brokerage account via affiliate link — execute thesis independently)
Purpose: Authenticate users' bank and brokerage accounts so they can link them to Thesis.
User benefit: One-tap account linking instead of manual data entry.
Purpose: Display real-time account balances across all linked accounts.
User benefit: Users see their total financial picture — cash, investments, debts — in one place.
Purpose: Import 24 months of transaction history for cash flow analysis.
User benefit: Users understand their monthly investable capacity before building a thesis.
Purpose: Import brokerage holdings, securities data, cost basis, and portfolio composition.
User benefit: Users compare their actual portfolio (via Plaid) against their thesis portfolio (self-built in the app). This is the core value prop: "Your portfolio is 65% aligned with your AI Infrastructure thesis."
Purpose: On-demand holdings updates when users open the app.
User benefit: Portfolio data is current, not stale.
Purpose: Import loan data — student loans, credit cards, mortgage, auto loans.
User benefit: Full financial context. Users should understand their debt situation before allocating capital to investments.
All investment decisions are made by the user, not by Thesis:
| Feature | Thesis | Monarch | Copilot | Robinhood | Betterment |
|---|---|---|---|---|---|
| Account aggregation | Yes | Yes | Yes | No | Yes |
| Investment thesis builder | Yes | No | No | No | No |
| Educational courses | Yes | No | No | Yes | No |
| AI research tools | Yes | No | No | No | No |
| Trade execution | No | No | No | Yes | Yes |
| Investment advice | No | No | No | No | Yes |
| AUM fees | No | No | No | No | Yes |
Last updated: June 2026
| Data Category | Plaid Product | What We Access | Purpose |
|---|---|---|---|
| Account identity | Auth | Account holder name, institution, account type, mask | Identify linked accounts for display |
| Balances | Balance | Current and available balances | Show financial overview |
| Transactions | Transactions | 24-month transaction history, amounts, dates, merchant names | Cash flow analysis, monthly investable capacity |
| Investments | Investments | Holdings, securities, quantities, cost basis, account allocation | Portfolio comparison against thesis model |
| Liabilities | Liabilities | Loan types, balances, interest rates, payment schedules | Debt context for thesis risk calibration |
Thesis does not:
Users can disconnect accounts at any time:
Last updated: June 2026
Under Section 202(a)(11) of the Investment Advisers Act, an "investment adviser" is any person who, for compensation, engages in the business of advising others about the value of securities or the advisability of investing in securities.
Thesis does not meet this three-part test:
| Prong | Requirement | Thesis Position |
|---|---|---|
| 1. Advice about securities | Must provide specific recommendations about securities | ❌ Thesis provides educational content, research tools, and a thesis builder. Users build their own thesis. No buy/sell/hold recommendations are made. All AI-generated content includes disclaimers. |
| 2. As part of a business | Must be engaged in the business of providing advice | ⚠️ Thesis is a business, but does not hold itself out as an adviser. Marketing explicitly states: "Educational tool. Not investment advice." |
| 3. For compensation | Must receive compensation for advisory services | ❌ Thesis revenue is exclusively affiliate referral fees from brokerages. No fees are charged for investment recommendations, portfolio construction, or any advisory service. Users pay nothing. |
Conclusion: Thesis satisfies at most 1 of 3 prongs. Thesis is NOT an Investment Adviser under federal law. SEC registration is not required.
Most state investment adviser statutes mirror the federal definition. Thesis does not meet state-level RIA definitions for the same reasons. No state registration is required.
Thesis does not:
Thesis is not required to register as a broker-dealer under Section 15 of the Securities Exchange Act of 1934.
All analysis screens include educational disclaimers:
| Risk | Mitigation |
|---|---|
| Being perceived as an RIA | Clear disclaimers, no compensation for advice, user-driven thesis builder |
| AI-generated content being seen as advice | "No investment recommendations" label on every AI output, probabilistic disclaimer |
| Affiliate model resembling advice-for-compensation | Affiliate links are to brokerage accounts, not specific securities. Users choose what to buy independently. |
| State regulators | Standardized disclaimers, no AUM fees, no discretionary authority |
Thesis will:
If Thesis ever:
None of these are planned for v1 or the foreseeable roadmap.
Last updated: June 2026
Disclaimer: This document is an internal compliance analysis, not legal advice. Consult qualified securities counsel for a formal regulatory opinion before launch.
Last Updated: June 2026
By accessing or using the Thesis mobile application ("Thesis," "the App," "we," "our," or "us"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree, do not use the App.
Thesis is an educational investing platform. We provide:
IMPORTANT: THESIS IS NOT AN INVESTMENT ADVISER.
Thesis is not a fiduciary. We do not act in your best interest as a legal standard — we provide tools and information for you to make your own decisions.
Thesis is not a broker-dealer, exchange, or trading platform. We do not:
To invest, you must open an account with a registered broker-dealer independently. Affiliate links to brokerages are provided for convenience and do not constitute a recommendation of any specific brokerage.
Thesis uses Plaid Technologies, Inc. ("Plaid") to enable you to connect your financial accounts. By linking accounts:
Thesis is not responsible for the accuracy, completeness, or availability of data provided through Plaid.
Thesis includes experimental AI-powered research features ("Alpha Research"). By using these features:
You agree that you will not:
The Thesis application, including its design, code, educational content, and branding, is the intellectual property of Thesis. You may not copy, modify, distribute, or create derivative works without permission.
User-generated content (thesis models, conviction notes) remains your intellectual property.
Thesis contains links to third-party websites and services, including affiliate links to brokerages, banks, and credit card issuers.
THE APP IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:
Financial data may be delayed, inaccurate, or unavailable. Thesis relies on third-party data providers and is not responsible for data quality.
TO THE MAXIMUM EXTENT PERMITTED BY LAW:
You agree to indemnify and hold harmless Thesis and its founder, employees, and affiliates from any claims, damages, or expenses arising from your use of the App or violation of these Terms.
We may update these Terms from time to time. Material changes will be communicated through the App. Continued use after changes constitutes acceptance.
These Terms are governed by the laws of the United States and the state of the user's residence, without regard to conflict of law principles.
For questions about these Terms:
This is a plain-English summary — the full Terms above govern:
Last updated: June 2026
Last Updated: June 2026
Thesis ("we," "our," "us") is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use it, and your rights regarding your data.
When you link financial accounts through Plaid:
| Purpose | Data Used |
|---|---|
| Build and display your investment thesis | Profile data, theme selections, portfolio allocations |
| Show your real financial picture | Plaid account data, balances, holdings |
| Provide AI-powered research | Profile data, thesis model, research queries |
| Improve the app and fix bugs | Usage data, crash logs |
| Recommend relevant educational content | Experience level, interests, thesis themes |
| Display affiliate offers | Profile data, account types |
You have the right to:
To exercise these rights, contact us at founder@makeyourthesis.com or use the in-app settings.
Thesis is not intended for users under 13 years of age. We do not knowingly collect data from children under 13.
We may update this Privacy Policy from time to time. Material changes will be communicated through the App. Continued use after changes constitutes acceptance.
For privacy-related questions or requests:
As required by Plaid, users linking financial accounts are also subject to Plaid's End User Privacy Policy, available at: https://plaid.com/legal/#end-user-privacy-policy
Last updated: June 2026
Thesis generates revenue exclusively through affiliate partnerships with financial service providers. When a user opens an account through an affiliate link in the app, Thesis earns a one-time referral fee. This is the sole revenue model for v1.
| Characteristic | Investment Adviser Fee | Thesis Affiliate Fee |
|---|---|---|
| What triggers payment | Providing advice about securities | User opening a brokerage account |
| Tied to specific securities? | Yes — advice about what to buy | No — user independently chooses investments |
| Ongoing vs one-time | Typically ongoing (AUM) | One-time per account |
| User pays? | Yes (directly or via fund fees) | No — brokerage pays the referral fee |
| Does fee vary by user action? | Typically % of AUM, flat fee, or hourly | Fixed referral amount regardless of user's investments |
The affiliate fee is a customer acquisition cost paid by the brokerage, not compensation for investment advice. The user pays nothing to Thesis.
When you open and fund an account through this link, Thesis may receive a referral fee. This does not affect your cost. Offers ranked by user profile fit, not commission amount.
Thesis earns referral fees when users open accounts through affiliate links. We never accept payment to recommend specific securities. Investment decisions are yours alone.
Affiliate offers are ranked by user profile fit, not by commission amount:
| Metric | Conservative | Moderate | Optimistic |
|---|---|---|---|
| Monthly active users | 1,000 | 5,000 | 25,000 |
| Conversion rate (user → account) | 2% | 4% | 6% |
| Average fee per account | $75 | $100 | $125 |
| Monthly revenue | $1,500 | $20,000 | $187,500 |
Potential future revenue streams, all of which will be re-evaluated for regulatory implications:
Any subscription tier will include renewed regulatory analysis to ensure it does not cross into "compensation for investment advice."
Last updated: June 2026
Note: Actual affiliate partnerships, fee amounts, and terms are subject to individual agreements with each partner. The figures above are illustrative for business planning.
Thesis uses Enrich to automatically categorize bank transactions so users see their real monthly investable capacity without manual data entry. Income minus categorized expenses (housing, food, subscriptions, debt payments) = investable capacity. This powers the Investable Capacity Calculator ("You have ~$400/month to invest") and the Emergency Fund Check (compares essential spending against savings balances). No manual categorization required.
Thesis imports brokerage holdings via Investments to power the core product: comparing a user's real portfolio against their self-built thesis model. A user builds an "AI Infrastructure" thesis with target weights (NVDA 25%, AMD 15%, SMH 10%), then connects their brokerage to see their Thesis Alignment Score ("Your portfolio is 62% aligned. You're overweight NVDA and missing semiconductor ETF exposure.") Also powers Portfolio X-Ray (ETF look-through overlap detection) and concentration risk flags. Read-only comparison — users make their own decisions.
Thesis imports loan data to give users the full financial picture before they build an investment thesis. Credit card debt at 22% APR mathematically beats most stock returns — Thesis surfaces this: "Paying down this debt is your highest-return move right now." Student loans, mortgages, and auto loans calibrate thesis risk: a user with $80K in student debt gets different suggestions than someone debt-free. Also powers the net worth dashboard and contextual affiliate offers (balance transfer cards when high-interest debt is detected). Education-first: fix the foundation before building the portfolio.
Thesis imports 24 months of transaction history to calculate real monthly investable capacity from actual data rather than user estimates. Income minus spending minus debt obligations = investable capacity. Powers three features: (1) Investable Capacity Calculator, (2) Emergency Fund Check comparing essential spending to savings, (3) CFO/AI context so responses are grounded in real cash flow data. Educational tool — teaches good financial habits, not product recommendations.
Last updated: June 2026
Last Updated: June 2026
Owner: Jaiden Rabatin, Owner/CEO
This policy applies to all systems, data, and personnel involved in the Thesis application ("the App"), including the mobile client, backend API server, database, and third-party integrations (Plaid, Supabase, DeepSeek API).
| Role | Name | Responsibility |
|---|---|---|
| Security Owner | Jaiden Rabatin | All security decisions, incident response, policy maintenance |
| Developer | Jaiden Rabatin | Secure coding, dependency management, deployment |
As a sole-founder operation, all security responsibilities are held by the owner. A group contact email is maintained for continuity: founder@makeyourthesis.com.
| Asset | Classification | Location |
|---|---|---|
| Plaid access tokens | Sensitive — financial data access | Server (encrypted storage) |
| Plaid API keys | Critical — would allow unauthorized data access | Environment variables only, never in source code |
| User profile data | Confidential — PII-lite (email, investment preferences) | Supabase (encrypted at rest) |
| Source code | Internal | GitHub private repository |
| Mobile app | Public | Expo / TestFlight distribution |
.env), never committed to version controlnpm audit run on each dependency installation| Provider | Service | Security Review |
|---|---|---|
| Plaid | Financial data aggregation | SOC 2 Type II, ISO 27001 certified |
| Supabase | Database & authentication | SOC 2, encrypted at rest, RLS |
| Railway | Server hosting | SOC 2, isolated containers |
| DeepSeek | AI/LLM API | API key authentication, no financial data sent |
| Google OAuth | Consumer authentication | Industry-standard OAuth 2.0 |
This policy is reviewed every 6 months or after any significant system change, whichever comes first. Next review: December 2026.
Acknowledged by:
Jaiden Rabatin, Owner/CEO — June 2026
Application: Thesis (makeyourthesis.com)
Contact: Jaiden Rabatin, founder@makeyourthesis.com
Date: June 2026
Answer: Yes
Refer to the Information Security Policy document (above).
Answer: Yes — Phishing-resistant MFA (TOTP/Google Authenticator)
Implementation: POST /v1/mfa/setup → QR code → Google Authenticator → POST /v1/mfa/verify
Answer: Yes
Supabase, Plaid, and GitHub dashboards all have MFA. Server access via SSH keys only.
Answer: Yes
HTTPS/TLS 1.2+ on all connections (Railway, Supabase, Plaid API).
Answer: Yes
Filesystem encryption on server. Supabase AES-256 at rest. Tokens never on mobile device.
Answer: Yes
Document: Privacy Policy (see above)
URL: makeyourthesis.com/privacy
Answer: Yes
Plaid Link in-flow consent + Privacy Policy + Terms of Service acceptance.
Answer: Yes
Plaid tokens deleted on disconnect. User deletion by request. Policy reviewed every 6 months.
| Question | File |
|---|---|
| Q2 | Information Security Policy |
| Q4 | Screenshot of MFA setup screen (QR code) |
| Q9 | Privacy Policy (or link to makeyourthesis.com/privacy) |