Referral Program

Agreement Terms and Conditions

October 2021

Front Financial (“we,” “us” and “Front”) offers you the opportunity to earn awards by referring friends to try our services. Your participation in the Front Referral Program can earn you gift cards of varying values, and may also get you additional rewards. We reserve the right to terminate the Program at any time for any reason. The Program is administered by Front, which may, outsource certain elements of administration to third parties (collectively “Administrator”).

This Agreement and these Terms and Conditions apply to a user’s participation in the Program. By participating in the Program, users agree to use the Program as outlined herein, and consistent with any other terms we may apply to the Program. If you do not agree to these Terms in their entirety, then you cannot participate in the Program. By participating in the Front Financial (“Front”) Referral Program, you agree to the following:

  1. Definitions

When the following bolded terms are used above or below in this Agreement, the following definitions apply:

Act means the Investment Advisers Act of 1940, as amended. The Act is in the U.S. Code at 15 U.S.C. §§80b-1.

Award means the referral incentive amounts as indicated in the relevant referral promotion in paragraph 2, below.

Brochure means the Wrap Fee Program Brochure that Front files with the SEC on Part 2A of Form ADV, which can be found here: .

Disclosure means the disclosure screen Potential New Clients will see after being referred by a Referring Client and before opening an Front Account.

Potential New Client means an individual (i) whom a Referring Client, using social media or other functionality provided by Front in connection with a Referral, invites to become a new Front subscriber and open an Front Account and (ii) who has never subscribed to any Front products or services or opened a Front Account before being invited by the Referring Client.

Referred Client means a Potential New Client who has (i) downloaded the Front application, (ii) connected a valid US-based brokerage account with a minimum of $25 of assets (cash, stocks, or crypto, and (iii) is at least 18 years of age.

2. Award for Referrals

$5 Gift Card

Front will provide a $5 debit gift card to each Referring Client who refers a Referred Client only after the Referring Client and the Referred Client have met all of the following eligibility criteria under these Terms and Conditions.  After each Referred Client (1) originates and uses the referral code from the Referring Client, (2) downloads the Front mobile application, (3) opens a Front Account, and (4) links a brokerage account with a minimum of $25 of assets, Front will send the Referring Client an email with a redemption code for a $5 debit gift card.  A valid email is required for receipt of the gift card redemption code.

Additional Referral Bonus

In addition, Referring Clients will be eligible to win up to $1,000 according to the below probabilities for each Referred Client:

The amount awarded to each Referring Client will be determined all the conditions are met for the $5 Gift Card. The Referring Client will receive the additional award in an email with a redemption code for a debit gift card with the Additional Referral Bonus. A valid email is required for receipt of the gift card redemption code.

You acknowledge and agree that, notwithstanding anything else in this Agreement, you shall not be entitled to any Award for a Referral (i) unless and until the Potential New Client is accepted as a Referred Client; (ii) unless and until the Referred Client maintains a relationship with Front; (iii) if Front determines at its sole discretion that you have breached any term, condition, obligation, duty, covenant, undertaking, representation or warranty in this Agreement (see Section 3 below on Compliance); and (iv) unless you invite a client using the links Front provides. Front, at its sole discretion, may make different Reward Amounts to other Front users or prospective users. This promotions shall have no bearing whatsoever on your Agreement or relationship with Front.

As a condition of being awarded any prize, a winner may (in Front’s sole discretion) be required to execute and deliver a signed affidavit of eligibility, acceptance of these Terms and Conditions, release of liability, and any other legal, regulatory, or tax-related documents required by Front in its sole discretion. All Federal, State, and local taxes associated with the receipt of any awards are the sole responsibility of each Referring Client. For prizes valued at $600 or greater, winners must provide a completed W-9 to Front, who will file an IRS Form 1099 with the Internal Revenue Service for such winners. If a Referring Client refuses to  complete a W-9 for a prize worth $600.00 or greater within 15 business days after the request is made, the Referring Client will be disqualified from receiving any award under this Agreement. 

Front reserves the right to provide an alternative form of Award of equal value at its discretion.

3. Compliance

In connection with your participating in the Referral Program, you agree to the restrictions listed below.

Violation of any of these restrictions may result in termination of your eligibility to participate in the Referral Program and may deny you any Referrals earned in violation or suspected violation of these restrictions at Front’s sole discretion.

4. Disclosure

You acknowledge and agree that, before Front presents a Potential New Client invited by you with the opportunity to maintain a relationship with Front, the Potential New Client will be shown the Disclosure, which shall contain the following information:

You also acknowledge and agree that the Potential New Client will be required to provide an acknowledgement that the Potential New Client has received the Disclosure.

5. Brochure

You acknowledge and agree that, before Front presents a Potential New Client invited by you with the opportunity to maintain a relationship with Front, the Potential New Client will be presented with a link to the most recently filed version of the Brochure and required to provide an acknowledgement that the Potential New Client has received the Brochure.

6. Front’s Registration

Front represents and warrants to you that it is registered with the SEC under the Act as an investment adviser.

7. Legal and Regulatory History

You represent and warrant to Front that you are not a person: (A) subject to an SEC order issued under section 203(f) of the Act, or (B) convicted within the previous ten years of any felony or misdemeanor involving conduct described in section 203(e)(2)(A) through (D) of the Act, or (C) who has been found by the SEC to have engaged, or has been convicted of engaging, in any of the conduct specified in paragraphs (1), (5) or (6) of section 203(e) of the Act, or (D) is subject to an order, judgment or decree described in section 203(e)(4) of the Act.

8. Relationship to Front Services

You acknowledge and agree that all Awards provided to you under this Agreement for Referrals are subject to the terms and conditions of Front’s Terms of Services at To the limited extent the express terms and conditions of this Agreement and those of the Terms of Service directly conflict, this Agreement shall govern.

9. Dispute Resolution, including Pre-Dispute Arbitration Clause

All controversies that may arise between you and Front concerning any subject matter, issue, or circumstance whatsoever (including controversies concerning any account, order, or transaction, or the continuation, performance, interpretation, or breach of this, the other Agreements, or any other agreement between you and Front, whether entered into or arising before, on, or after the date this account is opened) shall be determined by binding arbitration through the American Arbitration Association (“AAA”). You acknowledge that judgment upon any arbitration award may be entered in any court of competent jurisdiction.

No person shall bring a putative or certified class action to arbitration, nor seek to enforce any pre-dispute arbitration agreement against any person who has initiated in court a putative class action; or who is a member of a putative class who has not opted out of the class with respect to any claims encompassed by the putative class action until: (i) the class certification is denied; or (ii) the class is decertified; or (iii) the customer is excluded from the class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under this Agreement except to the extent stated herein.

10. Termination

You may terminate this Agreement at any time by notifying Front in writing at [email protected] that you no longer desire to make Referrals or to receive Awards for Referrals. Upon termination you will no longer be a Referring Client. Front may terminate this Agreement at any time by notifying you at the email you have provided to Front for your Front Account(s). If Front terminates this Agreement and you have not breached this Agreement, Front will credit your Account with any Award you have earned from Referrals in which the Referred Client has, before we notified you that we terminated this Agreement with you.

11. Miscellaneous

By participating in the Front Referral Program, you undertake to perform your duties under this Agreement in a manner consistent with this Agreement, any and all of Front’s instructions to you and the provisions of the Act and the Rules. You agree to seek guidance promptly from Front if you are in doubt about what the Act or the Rules allow or do not allow you to say or do in connection with Referrals.

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