Wealth

Account opening

What are the requirements to sign up for Scalable Wealth?
 

Our service is primarily aimed at persons residing in Germany or Austria. Persons residing outside of Germany or Austria may become customers if they (i) request our service on their own initiative (as an offer from a foreign provider) and (ii) meet all of the following requirements:

  1. You are over 18 years of age.
  2. You are not subject to US taxation (not a “US person” under US tax law).
  3. You have a place of residence in the European Union.
  4. You have a current account that is kept at a credit institution based in the SEPA area.
  5. You will invest the minimum investment amount.

Please also note that the custodian bank only pays taxes for customers who are taxable in Germany. If you are subject to tax abroad, you must carry out the correct taxation of all securities transactions yourself.

Feel free to contact us at service@scalable.capital if you are not a resident of Germany or Austria and would like to become a customer.

Is there a minimum deposit?
 

The minimum investment amount for Wealth starts from a monthly savings plan of 20 euros or a lump sum of 1,000 euros.

However, partial payouts that would reduce the investment amount below 1,000 euros are not possible. In this case, you would have to cancel your contract and have your entire investment amount paid out, this is possible at any time.

How do you choose a suitable investment strategy for me?
 

As a regulated financial services institution, we are legally obliged to form a picture of your financial situation and other relevant circumstances. Only then are we allowed to recommend an investment strategy that is suitable for you.

At the beginning of the registration process, we will guide you through a questionnaire. Based on the information you provide, we assess which investment strategy best meets your investment objectives. Of course, we also check whether the risks associated with a particular investment strategy are financially viable for you and whether you understand these risks based on your knowledge and experience.

From this information, we determine your risk profile, recommend an investment strategy that is suitable, and implement it for you.

Why do I need to verify my identity?
 

The Money Laundering Act (MLA) requires us to identify our customers. This identification is also in your interest, as it ensures a higher level of security in the customer relationship.

An MLA-compliant identification is carried out conveniently via POSTIDENT video, online identification using your ID (eID), or in the traditional way at your post office.

What is the identification process?
 

The identification is done by our partner, POSTIDENT. With POSTIDENT, you can choose between POSTIDENT video, online identification using your ID (eID), and identification in person at a post office branch.

Identification via online ID (eID) is the fastest and easiest way to open an account with Scalable Capital. You can find all information about the eID procedure here.

You can also identify yourself through our partner POSTIDENT with your foreign identity card or passport. A list of the ID cards supported by POSTIDENT-Video can be downloaded here (German only).

If your ID document is not supported for POSTIDENT-Video, you can carry out identification in person at a post office. You can find a list of the ID cards accepted in branch offices here (German only).

You can start the identification process conveniently in our app or online by logging in to your Scalable Capital account after completing the registration.

Once you have successfully completed the identification, you do not need to do anything else. The identification data is transmitted to Scalable Capital, and the opening of both the clearing account and the custody account is initiated. It can take up to three working days to open the accounts. You will be informed automatically as soon as the account opening is completed.

If any questions arise from the transmitted identification data, we will contact you proactively.

Are joint accounts offered?
 

We currently do not offer joint accounts with custody account management via Baader Bank.

If you already have a joint account with ING, this can be used as a reference account for a joint Scalable securities account. For this purpose, please use our registration via ING.

Can I open an account for my underage child?
 

Children's accounts can be opened with Scalable Capital from a minimum investment of 20 euros per month. If you do not wish to set up a savings plan initially, the minimum investment amount is 1,000 euros. Please note that a children's account is currently only possible in the form of our wealth management at Baader Bank. Our brokerage offer is aimed exclusively at private individuals of full age.

To open a children's account, register your child for wealth management via our homepage. Please note that the account must be in your child's name. You will then receive an automated e-mail with further information.

Can I transfer an existing portfolio to Scalable Wealth?
 

In the case of a securities account transfer to Scalable Wealth, all transferred securities are sold during the process and the resulting liquid funds are added to the existing portfolio in accordance with your chosen investment strategy.

This is due to the fact that a transfer of securities does not allow for the transfer of the securities history. As a result, our algorithm would not be able to work appropriately with the securities in accordance with your chosen investment strategy.

If you are interested in a transfer or have further questions, please feel free to contact our team at service@scalable.capital.

Can I open a wealth portfolio as a broker client?
 

As a broker client you can also add an automated ETF-based wealth management portfolio.

To do so, log in to your account and click on the plus icon ("+") in the mobile app or on "Add product" in your web browser. Then, select the wealth portfolio option. In order to determine your risk profile, you will need to complete our questionnaire. You will not need to verify your identity again.

Please note that a new clearing account and a new securities account will be opened for each new portfolio. The minimum investment amount must be fulfilled for each portfolio as well.

Can I open multiple portfolios?
 

You can hold multiple portfolios with different investment strategies at Scalable Capital. You can add additional portfolios in the customer area under "Home". Please note that a new clearing account and securities account must be opened for each new portfolio and the minimum investment must be deposited.

Referral Program

Can I recommend the broker and/or the wealth management as part of a referral program?
 

As a broker and/or wealth management client you can recommend both products to your friend(s) and receive a reward.

For a successful recommendation of our wealth management product you will receive 50 Euro, and for a successful recommendation of the broker you will receive 25 Euro as a thank you.

How can I invite my friends?
 

Click on "Invite" in our app or online by logging in to your Scalable Capital account. There you will see your individual invitation link that you can share with your friends via email, SMS, WhatsApp, or other messenger services.

How and when will I receive my reward?
 

First, share the invitation link with your friends.

After the referred person has successfully opened a brokerage account based on your link and has made one or more purchase orders or savings plans executed with a total volume traded of €25 or more, you will receive your bonus. The referred person needs to remain a client, with a positive cash balance, of the corresponding brokerage securities account, for 6 months after successful opening.

The bonus will be paid to your clearing account in the following month after the referred person has made a one-off purchase or started a savings plan.

Can I receive multiple rewards?
 

You will be credited with 50 euros or 25 euros for each friend who successfully opens an account based on your link.

For a successful recommendation of our wealth management product, you will receive 50 euros. For the successful recommendation of the broker, you will receive 25 euros.

Deposits and withdrawals

What criteria must my clearing account fulfill?
 

The reference account that you register with us must be a current account (payment transaction account) in your name at a credit institution located in the SEPA area.

The use of a overnight deposit account is not permitted. If your reference account is a joint account, you must ensure that you are registered as the beneficial owner.

How can I make deposits and withdrawals?
 

Deposit
Via the item "Payments" you can instruct a one-time payment in the Scalable customer area at any time, which will be debited from your reference account (current account) via SEPA direct debit.

Alternatively, you can also transfer the desired deposit to the clearing account belonging to the respective portfolio. You can find the IBAN in your web customer area under "Profile" and "Products" or in the mailbox document "SEPA mandates" in the top right-hand corner.

Transfers to your clearing account must be made from your stored reference account. Deposits that cannot be clearly assigned to you (e.g. PayPal, Payward, Transferwise) are not permitted.

Regardless of when a deposit to your clearing account is received by the custodian bank, the amount will be invested immediately, at the latest with the next adjustment of the portfolio in accordance with your investment strategy.

Withdrawal
Withdrawals can be instructed via the Scalable customer area on our website or via our app.

To do so, click on the "Payments" item and select "Payout." Enter the desired withdrawal amount and click on "Don't park, withdraw anyway". Check the details and confirm the payout.

Then create appropriate liquidity by selling securities in your portfolio. We will carry this out for you as quickly as possible, usually no later than the next banking day. After the proceeds of the sale have been received, we will transfer the payment to your checking account. The value date on your checking account will generally take five to seven banking days.

When will my deposited funds be invested?
 

Your deposited balance will be invested after it is credited to the settlement account, but no later than the next rebalancing of your portfolio.

Can I set up a savings plan?
 

You can create a savings plan from a monthly savings rate of 20 euros. You can set the savings plan either during the account opening or subsequently in your personal customer area.

When will the deposit for my savings plan be debited from my reference account?
 

The direct debits for monthly savings plans are instructed by us on the first banking day of each month. Your reference account will be debited on the second or third banking day of the month and the amount will be credited to your portfolio at Scalable Capital on the following banking day.

Note: If you open the account with a monthly savings plan only, then the direct debit for the first savings installment will be instructed immediately after the account opening.

Can I set up a withdrawal plan?
 

You can easily set up a monthly withdrawal plan in your Scalable account. To do so, open the "Savings Plan" section, select "Withdrawal Plan" there and then set the desired amount.

The withdrawal will be initiated on the first banking day of each month. The securities sales required for the withdrawal will be ordered automatically.

What happens if my investment amount falls below the minimum investment due to a withdrawal plan?
 

A withdrawal that would reduce the investment amount of your portfolio below the minimum investment amount is not possible. Instead, your monthly withdrawal plan will be deactivated.

Where can I view individual transactions?
 

You can view every single transaction and every securities event (such as distributions) both in the login area on our website and on your smartphone using our app. In addition, the custodian bank will provide you with a monthly account statement where you can view a summary of all transactions and key figures that have taken place.

Investment Strategy

Is Scalable Capital an active wealth manager?
 

Scalable Capital is not an active asset manager in the conventional sense. We offer passive investment with active risk management. Within the various asset classes (e.g. equities or bonds), we invest exclusively in passive ETFs and, where applicable, ETCs that track a specific market at the lowest possible cost. The weighting of the various asset classes is carried out dynamically on the basis of our investment and risk management technology on the one hand - and strategically on the basis of the management of the equity quota in our sustainable strategies on the other - and is thus active in the strictest sense.

We thus only make adjustments to your portfolio if your risk of loss is forecast to exceed or fall below a higher probability (dynamic risk management strategies) or if your portfolio weights deviate from the target weights (sustainable strategies). In this way, your investment risk is always controlled.

Unlike an active asset manager, we do not make portfolio reallocations based on opinions about the price performance of specific asset classes. An active asset manager selects individual stocks based on expected value growth (so-called stock picking). However, countless empirical studies show that this is not effective.

Who makes the investment decisions at Scalable Capital?
 

We use leading technology and the latest findings from capital market research and financial econometrics to manage portfolios. Unlike an active asset manager, we do not make portfolio reallocations based on subjective opinions about price developments of specific asset classes. Portfolio adjustments are essentially the result of deviations in the loss risks or target weights of the current portfolios from our clients' chosen risk category.

However, the actual trading, i.e., the execution of securities orders, takes place by a real investment team, which reviews and bundles the securities orders and finally passes them on to our trading bank.

In this way, we ensure that there is still a human control instance, which, however, does not actively intervene in portfolio management, but rather further develops, monitors and checks the system.

What types of investment strategies are there?
 

In addition to the Sustainable and Sustainable + Gold investment strategies, you can choose from the following investment strategies as part of Wealth Select:

  • Climate Protection
  • Megatrends
  • Dynamic Risk Management
  • Allweather
  • Value
  • GDP Global.

Detailed information on all available investment strategies can be found here.

Why don't any investment strategies match my sustainability preferences?
 

Even though we at Scalable Wealth attach great importance to selecting products according to sustainable criteria (more on this in the Sustainability Disclosure), the products available on the market currently generally do not yet fulfill the specified sustainability criteria according to EU regulation 2021/1253. This is due in particular to the fact that the fulfillment of sustainability preferences is usually unclear due to a lack of data. As soon as a robust data basis is available, a reclassification of sustainable investment strategies will be reviewed in the context of sustainability preferences.

Can I change the investment strategy after registration?
 

The investment strategy can be changed after registration.

We have determined suitable investment strategies for you based on your investment objectives, knowledge and experience and financial circumstances. If there have been any changes, you can carry out the suitability check again and adjust your investment strategy.

To do so, log in to your client area and open the "Profile" section. Under the item "Products", then select "Change investment strategy", where you can carry out the suitability check again and adjust your investment strategy.

We would like to point out that in your interest, a change of investment strategy should really only be made if your circumstances have changed. For long-term wealth accumulation, it is important that you pursue your investment strategy consistently and do not allow yourself to be tempted into short-term action by daily events on the capital market.

How do you select sustainable ETFs?
 

Our sustainable investment strategies adhere to the strictest sustainability criteria. This means that only equity ETFs are used that take the highest sustainability standard into account (SRI: Socially Responsible Investing). Furthermore, a so-called best-in-class filter is used in the ETF selection: companies are compared with each other within their sector and only the most sustainable are subsequently selected.

How often is my portfolio adjusted?
 

Your portfolio is constantly monitored and if the weighting of the asset classes and ETFs no longer matches the target weighting of your chosen investment strategy, your portfolio is automatically adjusted. For example, if you choose an investment strategy with a 60% equity allocation, 60% of your investment amount will be invested in equities. If share prices rise sharply due to market movements, shares are sold and bonds are bought so that the target weighting of shares of 60% is restored.

Depending on the investment strategy, risk is managed differently and accordingly your portfolio is adjusted differently depending on the investment strategy.

For the "dynamic risk management" investment strategy, we continuously calculate the risk of your portfolio with the help of simulations. If your previously defined risk of loss (measured by VaR) deviates from the current risk of loss, your portfolio will also be adjusted.

What happens to distributions?
 

Distributions ( for example, from dividends or interest) from the ETFs we use are credited to your clearing account and automatically reinvested in accordance to your investment strategy.

Investment universe & ETF selection

What exactly do you invest my money in and how are the ETFs selected?
 

Depending on the investment strategy, we invest for you with different focus in asset classes or thematic areas. The investment universe includes all major asset classes: Equities, government bonds, secured bonds (Pfandbriefe and covered bonds), corporate bonds, real estate, commodities and money market.

To realize your investment strategy, we invest exclusively in ETFs (exchange-traded funds or exchange-traded index funds), ETCs (exchange-traded commodities) or other ETPs (exchange-traded products), each of which also fits your preferences, investment objectives and other characteristics when considered individually. Eight asset classes with up to 8,700 individual securities from up to 80 countries are covered.

The ETFs are selected in an extensive, multi-stage process. The most important quantitative and qualitative selection criteria here are:

  • Low costs
  • High liquidity
  • Low tracking error
  • Appropriate diversification
  • Safe replication methods.
How much money should I invest?
 

Investing in the capital market comes with risks. We therefore advise our clients to keep an immediately available emergency reserve for unforeseen events which should cover all of your current expenses and obligations for at least six months.

Is there a minimum investment period or a minimum term?
 

There is no minimum holding period or minimum term. Our service can be cancelled at any time. We invest exclusively in ETFs with exchange day tradability to provide you with the best possible liquidity.

However, a longer investment horizon can be advantageous for the investment and reduce investment risks. Especially in the case of negative performance, a longer holding period increases the likelihood that the portfolio can recover.

Do you also consider tax criteria when selecting ETFs?
 

Tax criteria are also taken into account when selecting ETFs. As we also explain here, the tax treatment of ETFs for private investors has been significantly simplified by the Investment Tax Act (InvStG) 2018. Domestic and foreign funds are now taxed according to the same system, so since the beginning of 2018, unlike under the old tax regime, foreign accumulating funds are now also used.

The tax burden is paid directly by the custodian bank. This means that there is no additional expense for the private investor in the tax return.

Why are individual ETFs in my portfolio marked as "phase-out"?
 

If Scalable Capital identifies a more suitable ETF in an asset class, the exchange for existing customers is carried out gradually. In contrast to a one-time sale of all old shares, an additional tax expense can be reduced in this way, if necessary.

Additional purchases in the event of further deposits or a higher target weighting of these asset classes are made exclusively in the new ETF, while sales always first reduce the holdings of the old product. The old fund is indicated to the customer by the marking "Phase-Out".

What happens if an ETF provider declares becomes insolvent?
 

Should an ETF provider become insolvent, the assets managed by the ETF are protected from insolvency by their status as special assets. In the course of the insolvency proceedings, the insolvency estate as well as the claims of the creditors against this insolvency estate are determined and the creditors are served according to their claim. The assets managed by ETFs do not become part of the insolvency estate and are thus protected from access by the creditors of the investment company. Only the holders of the unit certificates of the ETFs are entitled to their pro rata share of the assets managed by the ETF.

Costs

What are the total costs of Scalable Wealth?
 

The costs of the investment services consist of the remuneration of the asset manager Scalable Capital and the transaction fee for the securities trading of the custodian bank and add up to 0.75% p.a. until September 2022.

From 1 October 2022, investment services fees will be charged depending on the amount of the investment per portfolio.

The fee varies as follows:

  • 0.75 % p.a. for a portfolio value up to and including 100,000 euros
  • 0.69 % p.a. for the portfolio value above 100,000 euros up to and including 500,000 euros
  • 0.49 % p.a. for the portfolio value above 500,000 euros

Please note that the minimum fee for wealth management via ING is 75 euros p.a..

The calculation is made on a daily basis on the basis of the average client assets under management, and the asset manager and the custodian bank are invoiced separately on a monthly basis. The debit is made from your clearing account at the custodian bank. There are no further costs, e.g. for account and custody account management. There are also no hidden costs, front-end loads or other commissions. For details, please refer to our list of prices and services.

The costs of the financial instruments (ETFs) add up to 0.19 % p.a. on average. Due to changes in the weighting, fees and costs of the financial instruments as well as the exchange of financial instruments, the product costs are subject to fluctuations. The costs for the Megatrends investment strategy are shown separately and amount to 0,43 %.

The costs mentioned are already included in the market prices and would therefore also be borne by investors who trade in securities themselves.

How can I benefit from a reduction in the wealth management fee?
 

The costs for investment services are calculated in stages depending on the amount of the investment. The amount of the investment per portfolio is decisive. If you have investments in different portfolios, these will be considered separately for the management fee.

The management fees are calculated in the following stages:

  • 0.75 % p.a. for the portfolio value up to and including 100,000 euros
  • 0.69 % p.a. for the portfolio value above 100,000 euros and up to 500,000 euros
  • 0.49 % p.a. for the portfolio value above 500,000 Euro

Please note that the minimum fee for wealth management via ING is 75 euros p.a..

Example 1:
You invest 650,000 euros in a portfolio.
The first 100,000 euros are charged a fee of 0.75% p.a., the following 400,000 euros are charged a fee of 0.69% p.a. and the 150,000 euros above that are charged a fee of 0.49% p.a.

Example 2:
You invest a total of 120,000 euros, 60,000 euros of which are invested in each portfolio.
A fee of 0.75 % p.a. is charged for both portfolios, as the investment value per portfolio is decisive.

The calculation is made on a daily basis on the basis of the average client assets under management, the settlement is made monthly separately for the asset manager and the custodian bank.

Where can I view paid fees?
 

In the respective portfolio you can view your paid fees and taxes under the menu item "Performance". For a display of the absolute values, you must first change the display from percent to euro.

Does Scalable Capital receive refunds, commissions or other financial benefits from other companies?
 

We believe that only a truly independent asset management company can act in the best interests of the customer. That is why we do not accept any hidden costs or issue surcharges. If we receive such inducements, we undertake under the asset management agreement to pay you these inducements.

We only accept non-monetary benefits if they improve the quality of asset management and do not conflict with our clients' interests. These are, for example, financial analyses, information material, training or technical services. We will, of course, disclose the acceptance of these types of inducements to you.

Reporting & Taxes

Which reports do I receive on my portfolio?
 

You will receive a quarterly report on the performance of your portfolio in your Scalable mailbox. The report includes an overview of performance, benchmark, trades made, distributions, and other metrics related to your portfolio.

In addition, at the end of each year, you will receive an annual account statement. This contains the holdings in your custody account, but not the assets in your clearing account.

You can obtain an overview of your portfolio, including cash holdings, in your personal customer area. All relevant information about your account and securities account is provided there.

What happens during tax optimization?
 

If your portfolio shows profits before the end of the year, we realize these in the amount of the exemption order you have placed. This puts you in a better tax position than if all income was only taxed at the end of the investment period.

Will tax optimization affect my broker portfolio?
 

Tax optimization may affect your broker portfolio. Dividends, coupons and sales in the broker may result in taxable events after the wealth tax optimization in mid-December.

However, before the tax optimization - between the end of November and mid-December - you still have the option to opt out of the tax optimization by phone or email at service@scalable.capital.

How is the percentage return calculated in the account summary?
 

For the calculation of the percentage return, which is displayed in your personal customer area, we use the time-weighted method. The time-weighted return is adjusted for deposits and withdrawals and thus allows a direct comparison with a benchmark or an alternative portfolio.

To calculate the time-weighted return, the entire investment period is broken down into different time periods. Whenever a pay-in or pay-out occurs, the return up to that point is calculated and a new period begins. To obtain the time-weighted return for the entire investment period, the returns of the individual periods are multiplicatively linked.

Why is my percentage return different from my absolute return?
 

The time-weighted return shown in the account summary is adjusted for deposits and withdrawals. Therefore, your portfolio may have a positive or negative percentage return because the underlying portfolio has moved positively or negatively over time, but your absolute return may still be negative or positive. This occurs especially if the majority of your portfolio was deposited and invested at a relative market high or low.

Two extreme examples to illustrate:
You have an initial investment amount of 10,000 Euros invested with us. Subsequently, the market rises by 50% and your portfolio increases to a value of 15,000 euros. Now let's assume you were to deposit an additional 1,000,000 euros into your portfolio and the market immediately fell by 10%. In this case, your portfolio would lose over 100,000 Euros in value (significantly more than your initial gain of 5,000 Euros). Nevertheless, the percentage performance of your portfolio would be positive (50% increased and only 10% decreased).

You have invested an initial amount of 10,000 Euros with us. Subsequently, the market crashes by 50% and your portfolio drops to a value of 5,000 Euros. Now let's assume you were to deposit an additional 1,000,000 euros into your portfolio and the market immediately rose by 10%. In this case, your portfolio would gain over 100,000 Euros in value (significantly more than your initial loss of 5,000 Euros). Nevertheless, the percentage performance of your portfolio would be negative (50% down and only 10% up).

How can I set up or change my tax allowance?
 

With an exemption order, you instruct your bank to exempt accruing investment income from automatic tax deduction. Without this order, the bank will pay 25% capital gains tax as well as 5.5% solidarity surcharge and, if applicable, church tax to the tax office.

The statutory maximum limits are 801 euros exemption order of an individual and 1,602 euros joint exemption order of a married couple or registered partner.

To set up or change an exemption order, please log into your personal customer area on our website and open the "Profile" menu item. In the "Taxes" section, you can set up or change your exemption order.

The exemption order applies at bank level. So, for example, if you have asset management with us with custody account management at Baader Bank, the exemption order set up for this also applies to Scalable Broker.

Please submit your exemption order before the end of the current year. Exemption orders are always valid from 01 January of the current year or from the beginning of the business relationship.

How do I know my tax allowance is already used?
 

To see how much of your tax allowance has already been used, please log into your Scalable Capital account on our app or online and go to "Profile." In the "Taxes" section you can find all relevant information.

Will capital gains taxes already paid be refunded as soon as I set up an exemption order?
 

If an exemption order is set up retrospectively, taxes already paid (capital gains tax, solidarity surcharge and church tax, if applicable) will be refunded. Please note that the exemption order must still be set up in the current calendar year.

Will I receive a tax certificate at the end of the year?
 

If you are liable to pay tax in Germany, you will receive an annual tax certificate for your securities account and your clearing account. This will be provided to you electronically in the spring of the following year. You will find it in your mailbox in our app or online by logging in to your Scalable Capital account.

How do I obtain a loss statement?
 

To apply for a loss statement for an existing securities account, please complete the form "Application for the issue of a loss statement" in the Baader Bank form center. Please send the completed form directly to Baader Bank.

Please note that the application must be received by 15 December of the current year in order for the loss certificate to be issued.

For a securities account that has already been closed, a possible loss statement will be provided to you automatically in the spring of the following year.

How does the final withholding tax work?
 

The final withholding tax on investment income (capital gains tax, solidarity tax, and, where applicable, church tax) is paid on a transaction-by-transaction basis. The respective levies are withheld by the custodian bank after each sale, taking into account tax allowance and loss pots where applicable, and forwarded to the tax office.

This only applies to customers subject to taxation in Germany. Customers who have a tax residence outside of Germany are obliged to determine and pay the applicable taxes themselves. Please note that Scalable Capital can not provide tax advice in this regard. If you have any questions regarding your individual tax situation, please contact your tax advisor or your tax office.

You can find the amount of withholding tax paid by you in your personal customer area. To do this, please log into your Scalable Capital account on our website, open the menu item "Profile" and click on "Taxes".

Please note that crypto ETPs classified according to §23 are not subject to capital gains tax. You can find more information on this below under "How are crypto ETPs treated for tax purposes?".

How does the payment of the church tax work?
 

After your registration, Baader Bank automatically queries your church tax status at the Federal Central Tax Office (Bundeszentralamt für Steuern). If you are liable to pay church tax, the church tax will be paid directly to the tax office together with the capital gains tax and the solidarity tax on a transaction basis.

Please note that Baader Bank only checks your church tax status once a year in September for the following year. If your religious affiliation changes after this date, the change cannot be made during the year. The change will not be made until the next check in the following tax year. However, you can claim back any excess church taxes that have been paid when you file for your tax return. Please contact your tax advisor for this.

You can find the amount of church tax paid by you in your personal customer area. To do this, please log into your Scalable Capital account on our website, open the menu item "Profile" and click on "Taxes".

When will the advance flat rate be debited?
 

Broker: The advance fee is debited by the custodian bank at the beginning of the year. The debit will be made from your clearing account. Please ensure that there are sufficient funds in your account. If the booking of an advance fee results in a negative balance, the custodian bank may charge interest of 6.00% p.a. in accordance with the "List of Prices and Services" (p. 65).

Wealth management: The advance fee is debited by the custodian bank at the beginning of the year. The debit will be made from your clearing account. We will ensure that there are sufficient funds for you. You do not have to worry about anything in this regard.

Kündigung

How can I cancel my Wealth portfolio?
 

You can request a cancellation via your personal customer area. To do so, open the menu item "Profile". The "Products" submenu takes you to a list of your portfolios. Via the button "Cancel portfolio" you can order the cancellation for the corresponding portfolio.

We will then sell the securities in your portfolio. Pending transactions will be brought to settlement beforehand. We will carry this out for you as quickly as possible, usually on the next banking day at the latest. Please note that even on trading days, same-day execution cannot be guaranteed.

We will then instruct the custodian bank to transfer your credit balance to the current account on deposit and close the account and custody account. The value date on your current account is usually within 6 to 9 banking days after the value date of the sales.

Customers with custody account management at ING you have the additional option to cancel only the asset management (keep securities). If you choose this option, ING will convert your Scalable securities account into a Direct securities account and your Scalable account into an Extra account. The securities will not be sold and will remain in the direct custody account. Your cash balance remains in the Extra account (after deduction of outstanding compensation claims).

After your cancellation, you can still log in to your personal area and retrieve documents in your mailbox. There you will receive important documents, such as your annual tax certificate. However, if necessary, access to your personal area can also be deactivated. To do so, please send us an e-mail at service@scalable.capital.

Is the cancellation free of charge?
 

Cancellation is free of charge and possible at any time.

In the event of termination, can I continue to hold my securities account with the custodian bank or transfer it to another bank?
 

In case of a termination of Scalable Wealth, the managed custody account will be closed.

However, a transfer of the securities or ETFs held at the time of termination into a custody account of another provider is possible.

If you are interested in a transfer or have further questions, please contact our team at service@scalable.capital.

Complaint

How do I make a complaint?
 

We take complaints seriously as each and every one of our clients are important to us. We believe you have a right to a fair, swift and courteous service at all times. We are a regulated entity, we treat our clients fairly and adhere to the regulations on transparency and protections related to financial services.

A complaint is any expression of dissatisfaction made by a client or potential client (complainant) to an investment services firm in connection with the latter's provision of an investment service or ancillary investment service. The term "complaint" does not necessarily have to be used. A complaint does not require a specific form.

Complaints can be made free of charge orally, in writing or electronically to the address below or to our other contact details, which can be accessed under https://de.scalable.capital/kontaktdaten in German and under https://de.scalable.capital/en/contact-details in English in their most current version.

Scalable Capital GmbH
Seitzstr. 8e,
80538 Munich,
Germany

Scalable Capital has established a complaints management function that is responsible for investigating complaints. This is the compliance department. You can reach it as follows:

Scalable Capital GmbH
Compliance Department
Seitzstr. 8e,
80538 Munich,
Germany

Please also see the “Complaints and disputes” section of our client documentation.

Scalable Capital Complaints Procedure
 

After the (potential) client has submitted the complaint, the complaint will be transferred to the client relationship management system (CRM).

The content of the complaint will be assessed (this may also include questions to the client), it will be determined whether the client's dissatisfaction is justified as regards its substance and, if necessary, a proposal for a solution will be developed. This is followed by consultation with a superior. Depending on the type, content and scope of the complaint, it may be necessary to involve the complaint management function at an early stage. Finally, feedback is provided to the (potential) client, in which Scalable Capital communicates its position regarding the complaint. The processing period between the submission of a complaint and the provision of feedback should normally not exceed five (5) business days. If no response can be provided within this period, Scalable Capital will inform the complainant of the reasons for the delay and the expected processing time.

If the client is not satisfied with our final feedback then they may contact the arbitration board of the Association of Independent Asset Managers Germany. The arbitration board of the Association of Independent Asset Managers Germany is responsible for any monetary disputes arising from or in connection with financial services contracts: VuV Ombudsman's Office, Stresemannallee 30, 60596 Frankfurt am Main, Germany, http://vuv-ombudsstelle.de/. Scalable Capital is a member of the Association of Independent Asset Managers Germany and is obliged under the latter's articles of association to participate in dispute resolution proceedings of the VuV Ombudsman's Office. The (potential) client therefore has the option of referring a complaint or other dispute to the VuV Ombudsman's Office.

Scalable Capital is not affiliated with any other recognised private consumer arbitration board.

The European Commission provides a platform for online dispute resolution for consumers who reside in the EU (in accordance with Article 14 (1) of the ODR Regulation) at http://ec.europa.eu/consumers/odr/. Scalable Capital does not participate in the online dispute resolution.

Irrespective of the option of appealing to the VuV Ombudsman’s Office, the (potential) client is free to file a civil action at their discretion.

In addition, clients may contact the complaints body of the national competent supervisory authority which may also provide for an arbitration procedure:
France: Autorité des marchés financiers – AMF
Italy: Commissione Nazionale per le Società e la Borsa – CONSOB
The Netherlands: Autoriteit Financiële Markten – AFM
Spain: Comisión Nacional del Mercado de Valores – CNMV
Austria: Finanzmarktaufsichtsbehörde – FMA.

Security and privacy

Is Scalable Capital an independent and regulated company?
 

Scalable Capital is an independent securities institution with the regulatory permission of the German Federal Financial Supervisory Authority (BaFin) to provide securities services pursuant to section 15 WpIG. Scalable Capital offers in particular the service of contract brokerage ("brokerage"). We are subject to supervision by the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht) and the German Federal Bank (Deutsche Bundesbank).

BlackRock (Netherlands) B.V. is (indirectly) a minority shareholder in the parent company of the securities institution. In the context of asset management, Scalable Capital makes the selection of ETFs for the investment universe as an operational decision exclusively on the basis of objective criteria aligned with customer interests. There are therefore no economic incentives to favour certain ETFs, whether from BlackRock. or another provider.

How secure are my money and my investments? What happens in the event that Scalable Capital or your partner bank becomes insolvent?
 

As a financial services institution, we are not authorized to obtain possession or ownership of the customer's assets. The customer's assets are held in the custody of our partner bank(s). In case of insolvency of Scalable Capital GmbH, the customer's assets contained in the custody account will therefore not fall into the insolvency estate of Scalable Capital GmbH.

In the event of the insolvency of the partner bank, your clearing account is protected by the statutory deposit protection of the Compensation Scheme of German Banks (Entschädigungseinrichtung deutscher Banken) up to a deposit amount of 100,000 euros (see details on this at www.edb-banken.de/en) and beyond that up to a certain amount by the deposit protection fund of the Association of German Banks (Bundesverband deutscher Banken). In addition, there is a claim to surrender of your securities in the portfolio in the event of insolvency of the custodian bank. This last aspect is particularly important for your investment with Scalable Capital GmbH, because your money is predominantly invested in securities with us and thus predominantly does not fall under the topic of deposit protection (like the cash on the clearing account).

As a regulated financial services institution, Scalable Capital GmbH is assigned to the Compensatory Fund of Securities Trading Companies (Entschädigungseinrichtung der Wertpapierhandelsunternehmen; EdW). The EdW provides compensation if an institution is no longer able to fulfill its "liabilities from securities transactions" to its customers for reasons directly related to its financial situation (and BaFin has determined the compensation case). For this compensation, the protection is limited to 90 %, up to a maximum of 20,000 euros per investor. Such a compensation case can only arise in special constellations for a financial services institution without permission to accept possession or ownership of assets of the customer (such as Scalable Capital GmbH); for example, the acceptance of customer funds despite the lack of the corresponding regulatory permission could be considered. Secondary claims (such as damages due to faulty investment) are generally not compensable.

How does Scalable protect my account?
 

At Scalable we want to ensure that your account is protected against any type of attack. Therefore, the Scalable Login utilises leading edge technology to scan the Web and track large security breaches that occur on third-party sites (unrelated to Scalable). If the Scalable Login identifies that any of our users’ credentials were part of such external breach it will notify you via your registered email and ask you to change your password.

How can I change my password?
 

To change your password, click on "Forgot your password?" under the input mask on the login page or on "Reset" in the Scalable customer area in the menu item "Profile" in the section "Password".

After entering your email address, you will receive an email from us with a link to change your password.

Why does a browser window open when logging in via the app?
 

For security reasons, we conduct the login process to your personal customer area via web browser. This guarantees a higher security standard when logging in and reduces the risk of falling victim to a phishing or fraud attempt.

The login to your Scalable client area is always done via a secure subdomain. Customers with a custody account at Baader Bank use secure.scalable.capital/login, customers with a custody account at ING can log in via ing-secure.scalable.capital/login.

Why can’t I log in?
 

If you have made sure that the combination of your e-mail address and password is correct, but you are still unable to log in, please check if you are using the correct login form for your custodian bank. For technical reasons, we use separate entry forms for customers with clearing accounts at Baader Bank and ING Bank.

To switch between the login forms, click either "To ING login?" or "Not an ING customer?" on the login page. In the app, you have the option to enable or disable the ING login before opening the login page.

If your account does not hold any active portfolios, we will block it after a few months of inactivity for security reasons. A blocked account can be manually unlocked by our customer service. In this case or in case of technical problems, please contact our customer service at service@scalable.capital.

How do I enable or disable two-factor authentication?
 

Activation
Log in to your Scalable Capital account in our app. Go to "Profile" and then select "Two-factor authentication" in the menu. During the activation process, you will receive an email with an activation link that you will need to confirm on the mobile device that you want to link.

Deactivation
Log in to your Scalable Capital account in our app. Go to "Profile" and then select "Two-factor authentication" in the menu. Select the option to disable two-factor authentication. You may reenable two-factor authentication in the same way again at any time.

As part of the activation process, you will receive a backup code. Keep this in a safe place that is only accessible to you. You may need the backup code in case you change or lose your smartphone.

Deactivation with backup code
Log in to your Scalable Capital account in our app. Go to "Profile" and then select "Two-factor authentication" in the menu. Select "I don't have access to my linked device", and then enter your backup code.

If you do not have access to you linked device or backup code, please contact our customer service at service@scalable.capital.

How can I switch between my Baader Bank and ING portfolios?
 

Due to security reasons, we offer separate login forms for each custodian bank. This means you have to select the custodian bank for your account in the login process in order to successfully login. For customers with accounts at both Baader Bank and ING Bank, it is therefore necessary to log out and log in again using the login form of the other bank.

The function of switching between your Baader Bank and ING accounts within your personal customer area can therefore no longer be offered.

How secure is my personal data?
 

Data protection is very important to us. We use modern IT infrastructure to ensure the security of your data. Your personal data (e.g. address, account data, financial circumstances) is transmitted in the course of registration as well as contract conclusion, and your data is always encrypted and stored in a data center in Germany.

Please refer to our privacy policy in this context.

How can I change my personal data?
 

To change your personal data, such as your address, reference account or phone number, please log in to your personal customer area via our website or app.

You can change your data under "Profile". Please activate two-factor authentication in the Scalable Capital app before making any changes.

As an ING customer, please contact our customer service by email at service@scalable.capital.

How can I download a copy of my personal data?
 

In accordance with Art. 15 GDPR, you can request a copy of the personal data processed about you. To do so, please log into your personal customer area on our website and go to "Profile". Under the "Personal Information" section, you can request your data at any time. Confirm your request via two-factor authentication (2FA) in the Scalable Capital app. Please note that access is only available via the web browser. It is not possible to make a request via iOS or Android app.

The scope as well as the manner of processing your personal data depends on which of our offers you use. For example, if you have only subscribed to a newsletter from us, the processing of your personal data is different than if you are a customer of our wealth management or brokerage offering. For more information, please also refer to our privacy policy.

Turquoise Line