STRATA Trust Company

Complaint: [redacted] I am rejecting this response because: I am showing a market value on 10/01/of $34,from SDIRA, and then an ending market value on 12/31/2014, of $15,Explanation? A line item above suggesting "change in investment value" -$18,This is toyally unacceptable and undeniably a misuse of trust in the banking industryI expect banks to protect my money, not lose it Regards, [redacted]

January 18, [redacted] *** Revdex.com La Posada DrAustin, TX Re: [redacted] – Revdex.com Complaint ID # [redacted] Dear Ms***: We are in receipt of Mr***’s response to our explanation of the above-referenced complaint First, when Mr [redacted] completed the Self Directed IRA Services Inc(“SDIRA”) account application, he elected to receive his quarterly statements onlineTherefore, his account activity and his quarterly statements were available to him at any timeOur records indicate that Mr [redacted] successfully logged into his account in early June and demonstrated the ability to monitor the activity in his account and view his quarterly statementsSecond, to further reference SDIRA’s account agreement to which Mr [redacted] consented when he established his account, Section 5, Item states, “I understand that my Account is self directed and that I am solely responsible for the selection, management and retention of all investments held within my AccountThese investments may involve a high degree of risk, and SDIRA Services will provide no investment advice nor make any investigation or determination as to the prudence, viability, suitability, legality or safety of the investments that I select.” Mr***, as the accountholder, agreed to not only select the investments in his account, but also to monitor his account as wellMonitoring his account includes reviewing his account online, his quarterly statements to ensure the precious metals he ordered were delivered, and notifying SDIRA of any discrepancies reportedOur records do not indicate that Mr [redacted] notified SDIRA of any such discrepancies or concerns or that he had attempted to follow up with his precious metals broker after reviewing his account and/or statementsFinally, fees were waived on the account as a courtesy once SDIRA was made aware of the situation of National Gold GroupWe understand that Mr [redacted] may be upset with the results of his investment decision and the circumstances surrounding the precious metals dealer he selectedHowever, under the terms of the custodial agreement to which Mr [redacted] consented and agreed, SDIRA is not responsible for any loss to Mr***’s account as a result of his investment direction Please contact me at 866-928-if you need any additional information regarding this matter or if you need documentation supporting SDIRA’s narrative in this response Again, we appreciate the opportunity to respond to this matterSincerely, [redacted] ***VP Compliance/Risk Management

Revdex.com: I have reviewed the response made by the business in reference to complaint ID [redacted] , and find that this resolution is satisfactory to me Regards, [redacted]

December 8, [redacted] *** Revdex.com La Posada Dr Austin, TX Re: [redacted] IRA - Revdex.com Complaint ID [redacted] Dear Ms***: We are in receipt of your complaint notice regarding the above-referenced customerWe appreciate the opportunity to respond to Mr [redacted] ’s concerns regarding his expense payment instructions to Self Directed IRA Services, Inc (“SDIRA”) It should be noted that Mr [redacted] submitted two different expense payment requests on two separate datesThe first was processed by SDIRA on 11/17/in the total amount of $The second was processed by SDIRA on 11/23/in the total amount of $7,Mr [redacted] did not provide an expense payment instruction for $9,on 11/17/as stated in the complaintTherefore, assuming the amount in question ($9,300) was logged into the Revdex.com complaint form incorrectly by Mr [redacted] , we will address the two expense payment requests outlined above The first expense payment request (total: $896.20) was submitted by Mr [redacted] via email on the afternoon of 11/12/Since the request did not contain sufficient information to process, SDIRA emailed him on the morning of 11/13/requesting additional informationMr [redacted] then emailed the corrected forms to SDIRA on 11/17/The expense request was processed, and the checks were sent via regular mail (as requested by Mr [redacted] ) the same dayOn 12/3/2015, Mr [redacted] called SDIRA indicating that the checks had not been receivedHe wanted SDIRA to waive any stop payment fees and overnight new checks to him at SDIRA’s expenseAs a courtesy to Mr [redacted] , SDIRA offered to waive the stop payment fees, but we were not willing to overnight the checks at no cost since no error had occurred on the accountSDIRA left a message with Mr [redacted] regarding this informationOn the afternoon of 12/4/(Friday), Mr [redacted] called SDIRA again and requested that SDIRA overnight new checks at no charge to himSDIRA did not agree to that, so Mr [redacted] agreed for SDIRA to issue a stop payment on the checks at no cost and to mail the new checks to him via regular mailOn 12/7/(Monday), SDIRA issued a stop payment on the checks and sent new checks via UPS ground as a courtesy so the checks could be trackedThat same afternoon, Mr [redacted] called SDIRA to let us know that he had received the first round of checks that dayHe also confirmed with one of our managers that the checks were dated 11/17/2015, and the envelope was postmarked on 11/17/The delay was due to the US Postal Service, and it had nothing to do with SDIRA’s processing timesUnfortunately, Mr [redacted] is unable to provide those checks to the vendor due to the stop payment that he requestedHowever, the new checks will be delivered to Mr [redacted] shortly via UPS groundThe second expense payment request (total: $7,370.78) was submitted by Mr [redacted] via email on the morning of 11/23/The request and supporting documentation was received in good order, and the checks were processed and sent via regular mail (as requested by Mr [redacted] )Those checks have cleared our bank, so the vendor has received and cashed the checks We trust that this response provides the information the Revdex.com needs for its resolution process SDIRA strives to go above and beyond for each client’s experience, and the fact that we processed both of these payments on the same day we received the requests in good order should be evidence of thatIt has not taken four weeks to process as Mr [redacted] claims, and SDIRA did not charge any additional fees for processingIn fact, we waived feesIf Mr [redacted] is not satisfied, SDIRA will also waive the account termination fees if he wants to move his accounts to a different IRA custodian Please contact me at 866-928-if you need any additional information regarding this matter or if you need documentation supporting SDIRA’s narrative in this response Again, we appreciate the opportunity to respond to this matterSincerely, [redacted] ***VP Compliance/Risk Management

Mr [redacted] will only be charged the $termination feeIf an account closes on or near the renewal date, we will credit any fee due towards the termination feeWe do not collect both a termination and annual fee.Thank you[redacted] ***VP Compliance/Risk Management

Dear Ms [redacted] : We are in receipt of your complaint notice regarding the above-referenced customerWe appreciate the opportunity to respond to Mr [redacted] ’s concerns regarding his account STRATA Trust Company (“STRATA”) mailed an invoice to Mr [redacted] which was returned as undeliverableAs a result of not having a current address on file, STRATA contacted Mr [redacted] through his email of record on January 15, notifying him of the returned mail and requested an address updateOn January 21, 2018, Mr [redacted] signed and returned an address change form to STRATA, and the updated address was changed in our system on January 22, Clearly, there was not a delay in processing the address update as specified in Mr [redacted] ’s correspondence with the Revdex.comWe will provide Mr [redacted] with a written confirmation of the change Our year-end statement file was created and sent to our vendor for mailing on January 19, If Mr [redacted] happened to receive his year-end statement at the old address, it was because the address change form with his updated address was received by STRATA after our year-end statements were processed We trust that this response provides the information the Revdex.com needs for its resolution process However, you may contact me directly at ###-###-#### if you need any additional information including copies of any of the documents referenced here Again, we appreciate the opportunity to respond to this matter Sincerely, [redacted] ***VP Compliance/Risk Management

We are in receipt of your complaint notice regarding the above-referenced customerWe appreciate the opportunity to respond to Mr [redacted] ’s concerns regarding his accountSTRATA Trust Company (“STRATA”) is a wholly-owned subsidiary of Horizon Bank and serves only in the capacity of a directed IRA custodianThis means that all accounts are self-directed by the account owner, and STRATA acts only upon the customer’s instructions STRATA only charges a nominal annual fee and ancillary processing fees for its custodial services and does not use any hard sales tactics when an individual is interested in opening an account with usIt appears Mr [redacted] was referred to STRATA by American Bullion, a precious metals dealer which handles precious metals transactions (buys, sales, and exchanges) for its customers There is no ownership affiliation between STRATA and American Bullion, so we are not aware of the sales tactics or discussions Mr [redacted] may have had with American Bullion in prior to his decision to open an account with STRATAWhen an individual completes a STRATA IRA application, a comprehensive fee schedule is included along with the application, custodial agreement, disclosure statement, and financial disclosureOur fee schedule clearly outlines the new account establishment fee, annual fee, termination fee, and ancillary fees such as wire fees or processing feesWhen Mr [redacted] signed the IRA application in 2012, he acknowledged receipt of these documents including the fee scheduleContrary to Mr [redacted] ’s complaint, the fees are clearly outlined and not “buried into some legal disclosure”In addition to the fee schedule provided in 2012, STRATA has updated and revised its fee schedule twice since thenThe first revision was provided to all customers with their December 31, quarterly statementsThe second revision was communicated to customers in their June 30, quarterly statementsIn both cases, the termination fee, annual fee, and all processing fees were clearly outlined in the fee scheduleThe termination fee outlined in the most current fee schedule is $The processing fee for liquidating precious metals is $and was already charged when he liquidated his holdingsAs a gesture of goodwill, STRATA will refund $and only charge a termination fee of $which was in effect in when Mr [redacted] first established his account We trust that this response provides the information the Revdex.com needs for its resolution process However, you may contact me directly at ###-###-#### if you need any additional information including copies of any of the documents referenced here Again, we appreciate the opportunity to respond to this matterSincerely, [redacted] ***VP Compliance/Risk Management

Complaint: ***
I am rejecting this response because:I appreciate the reply and do agree that the sales tactics were in fact American Bullion IncI will accept the proposed resolution only if the other annual fees to include storage fees and late fees are returned as wellI cancelled my account and should not be charged those fees for the next year of storage and administration which I will not be using
Regards,
*** ***

Self Directed IRA Services Inc(“SDIRA Services”) made the decision to increase several of the incidental fees as referenced on the IRA Fee Schedule which is provided to each Accountholder when the IRA account is opened. The Custodial Agreement in place between the Accountholder and
SDIRA Services, allows for changes to be made to the fee schedule provided there is at least a 30-day notification period. In accordance to this provision, notice was included in the Accountholder’s June 30, statement in the “Messages and Announcements” section located on the first page. By his own admission, Mr*** read the announcement, followed the instructions and located the fee schedule on the SDIRA Services website which disclosed the details. One of the changes to the fee schedule included an increase of the termination fee from $to $ Mr*** IRA account holds precious metals and typically the transfer of material is very labor intensive and the fee increase is in line with what Competitors charge across the County With regards to Mr*** claims, his Individual Retirement Account is still opened and has not been assessed any closing fees. However, annual renewal fees are currently due and those fees were not increased during the latest revision of the fee schedule

Complaint: ***
I am rejecting this response because: The response is not accurate. Mr*** states that SDIRA provided me with quarterly statements. Does SDIRA have a record of when they where provided, what address they where sent to? I don't recall ever receiving a quarterly statement from SDIRA. I agree with Mr*** that SDIRA is not responsible for monitoring the performance of the investments in my account. However, as custodian they are responsible for collection and safe keeping of the assets. By definition custodian = guardian/caretaker. The loss didn't occur because of investment performance, the loss occurred because SDIRA didn't do their job as custodian to ensure the assets where delivered to my account.I'm curious as to why Mr*** states - "It should also be noted that SDIRA has not charged any custodial fees on this account." Why didn't they charge their fees, because they knew something was wrong, they felt guilty?Mr*** also states that NGG may have referred clients to SDIRA. If that is the case how may clients at SDIRA had NGG as their broker? Surely I can't be the only one. Are the others being treated in the same manner that I am?Lastly, Mr*** refers to letters that where sent to me. I am only in receipt of the October 25, letter. However that is not important because if the first letter was sent October 11, 2013, that's only two weeks prior to the October 25th letter, which is still approximately months after the order was placed before SDIRA notified me that there was a problem.
Regards,
*** ***

The explanation of what occurred by Mr*** is not very detailed or accurate. He moved all assets out of his Individual Retirement Account with the exception of some notes that were in a forfeiture status. When events like this occur, our procedure is to typically leave a
sufficient amount of cash in the Customer's account to cover future renewal fees or closing fees. That is the reason, the $was held back.However, in order to bring closure to this matter, we will go ahead and grant his desired settlement and send the $to the same IRA that the other transfer amount was sent to.Thank You

Complaint: ***
I am rejecting this response because:
II I had the account opened only a short time and ai was completely unaware of this fee or I would have never opened the accountIt was probably buried somewhere in the fine print of a long documentThe fee is so high that it is unconscionableThis practice is shady, underhanded, and perhaps even fraudulentI hope you can pressure this corrupt organization into refunding my money which they helped themselves to without authorization or service of any kind
*** ***

Under the terms of the custodial agreement to which Mr*** agreed when he established his account, SDIRA provided proper notice in the June 30th quarterly statement to all customers regarding the changes to the service feesThe fee schedule provided online listed the effective dates of the new or changing service fees, and it listed the previous fee alongside the new fee with the effective date of September 1, This was done to make it clear which fees were changing, and the fee schedule is and always has been available at any time on our websiteEven though SDIRA acted in accordance with the terms of the custodial agreement, we will refund $to Mr*** as an act of good faith even though he has now closed his account.Thank you

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID ***, and find that this resolution is satisfactory to me
Regards,
*** ***

Re:   [redacted] IRA – Revdex.com Complaint ID [redacted]   Dear Mr. [redacted]:       We are in receipt of your complaint notice regarding the above-referenced customer. We appreciate the opportunity to respond and clarify some important points regarding...

Mr. [redacted]’s IRA and the associated fees.   Self Directed IRA Services, Inc.  (“SDIRA”) is a wholly-owned subsidiary of Horizon Bank, and there is no ownership affiliation between SDIRA and LendingClub Corp. (“LC”).  SDIRA serves only in the capacity of a directed IRA custodian, meaning that all accounts are self-directed by the account owner.  LC is a peer-to-peer lending and investment platform, and LC may refer its customers to open an IRA account when they wish to invest with LC using their IRA funds.    When Mr. [redacted] established his account with SDIRA, he acknowledged receiving our IRA Fee Schedule and agreed to it. The IRA application that Mr. [redacted] signed also disclosed the following:   “Your account will be subject to the fees shown on the IRA Fee Schedule for a Basic IRA. However, LendingClub has opted to pay your IRA First Year and Annual IRA fees subject to its IRA Custodial Service Agreement (“Service Agreement”) with Self Directed IRA Services, Inc. (“SDIRA Services”), as IRA custodian. You may become responsible for payment of these fees if: (1) either LendingClub or SDIRA Services terminate the Service Agreement, (2) LendingClub ever becomes unwilling or unable to pay these fees, or (3) you purchase or transfer assets other than those permitted under the Basic IRA fee category. SDIRA Services will provide you with notice in the event you become responsible for payment of your IRA fees.”   Contrary to the complaint, SDIRA is not charging a “new” fee of $100.  The IRA has always been charged this fee, but LC was paying the fee on his behalf. However, LC decided in 2016 to discontinue paying the fee on behalf of certain accountholders. Both LC and SDIRA sent notifications to accountholders to make them aware of LC’s decision. All of this is consistent with the disclosures made at the time Mr. [redacted] chose to open and fund his account. Here is the disclosure language directly from LC’s website.   “Lending Club's preferred IRA custodian is Self Directed IRA Services, Inc. (SDIRA), a subsidiary of Horizon Bank. SDIRA charges an annual account fee of $100 at account opening and then annually on the anniversary of account opening. Lending Club will pay the $100 annual account fee due at account opening on your behalf if your account has an initial minimum balance of $5,000 or more invested in Lending Club Notes and maintains this minimum invested balance for the following 12 months. For every subsequent year in which your account maintains a minimum balance of $10,000 or more invested in Lending Club Notes, Lending Club will pay the annual account fee of $100 on your behalf on the anniversary of account opening. All account balances are determined as of the last business day immediately prior to the anniversary date of the opening of your account. You will be responsible for the account fee for any accounts that don't meet the above requirements. Lending Club reserves the right to modify or discontinue this offer at any time.”  [redacted]   Account termination fees are commonly charged by brokerage firms, employer retirement plans, and self-directed custodians. Mr. [redacted] chose to partially terminate his account and transfer funds to another IRA custodian. The fees charged are consistent with the terms of the custodial account agreement and fee schedule to which Mr. [redacted] received and agreed.   There is no “trap” here as alleged by Mr. [redacted]. The situation stems from 1) his decision to invest in highly illiquid consumer loans that normally carry a 3 to 6 year holding period, all which Mr. [redacted] acknowledged at the time of the investments, and 2) LC’s decision to discontinue paying the annual IRA fee. If he can sell his note investments through the LC platform sooner, then he is welcome to completely terminate his SDIRA account. If he is unable to liquidate his LC account, he can also find another IRA custodian who will accept a transfer of the IRA. The full termination fee will be $100 rather than $150.   Please let me know if you need anything further from SDIRA to clear up this matter.   Sincerely,   [redacted]

Revdex.com:
I have reviewed the response made by the business in reference to complaint ID [redacted], and find that this resolution is satisfactory to me.
I will note that the response from the business does not acknowledge the fact that in discussing the case initially with their representatives, no indication would be made about money being "held back", even though I specifically asked about the fees.  I would have structured my decision differently with complete information.  Nor do they acknowledge that I was double charged for the transfer fee, which is something I had to bring to their attention.
Regards,
[redacted]

January 18, 2016          [redacted]  Revdex.com 1005 La Posada Dr. Austin, TX  78752             Re:   [redacted] – Revdex.com Complaint ID #[redacted]                                 Dear Ms. [redacted]:     We are in receipt of Mr. [redacted]’s response to our explanation of the above-referenced complaint.  First, when Mr. [redacted] completed the Self Directed IRA Services Inc. (“SDIRA”) account application, he elected to receive his quarterly statements online. Therefore, his account activity and his quarterly statements were available to him at any time. Our records indicate that Mr. [redacted] successfully logged into his account in early June 2013 and demonstrated the ability to monitor the activity in his account and view his quarterly statements. Second, to further reference SDIRA’s account agreement to which Mr. [redacted] consented when he established his account, Section 5, Item 3 states, “I understand that my Account is self directed and that I am solely responsible for the selection, management and retention of all investments held within my Account. These investments may involve a high degree of risk, and SDIRA Services will provide no investment advice nor make any investigation or determination as to the prudence, viability, suitability, legality or safety of the investments that I select.” Mr. [redacted], as the accountholder, agreed to not only select the investments in his account, but also to monitor his account as well. Monitoring his account includes reviewing his account online, his quarterly statements to ensure the precious metals he ordered were delivered, and notifying SDIRA of any discrepancies reported. Our records do not indicate that Mr. [redacted] notified SDIRA of any such discrepancies or concerns or that he had attempted to follow up with his precious metals broker after reviewing his account and/or statements. Finally, fees were waived on the account as a courtesy once SDIRA was made aware of the situation of National Gold Group. We understand that Mr. [redacted] may be upset with the results of his investment decision and the circumstances surrounding the precious metals dealer he selected. However, under the terms of the custodial agreement to which Mr. [redacted] consented and agreed, SDIRA is not responsible for any loss to Mr. [redacted]’s account as a result of his investment direction.  Please contact me at 866-928-9394 if you need any additional information regarding this matter or if you need documentation supporting SDIRA’s narrative in this response.  Again, we appreciate the opportunity to respond to this matter. Sincerely, [redacted]VP Compliance/Risk Management

Mr. [redacted] will only be charged the $150 termination fee. If an account closes on or near the renewal date, we will credit any fee due towards the termination fee. We do not collect both a termination and annual fee.Thank you.[redacted]VP Compliance/Risk Management

When an IRA account is opened to fund an investment into precious metals, several fees which are clearly disclosed on the SDIRA Services' fee schedule are deducted as soon as the account is opened.  Those fees consist of the following in this instance:$50.00 Establishment Fee, $75 First Year...

Annual Fee, $100 Storage Fee, $25.00 Wire Fee, $40.00 Processing FeeAs according to internal procedures, all these fees were assessed and when the account was later closed, an additional $150.00 closing fee was also assessed.   When the account was closed, no consideration was made for the fact that Mr. [redacted] had cancelled the investment, so the last 3 fees referenced above were no longer in effect.   However, the Establishment Fee, First Year Annual Fee and Closing Fee were actually all assessed properly due to the fact that SDIRA Services did follow all of Mr. [redacted] instructions with regards to opening the Individual Retirement Account and Closing it.Due to the fact that the transaction fees were not properly credited back at closing, SDIRA Services will comply with Mr. [redacted] request and refund $390.00 of the fees taken and see that those funds are forwarded to the same Successor Custodian that the other amount was sent to.

December 8, 2015                        [redacted]        Revdex.com 1005 La Posada Dr.         Austin,...

TX  78752 Re:   [redacted] IRA - Revdex.com Complaint ID [redacted] Dear Ms. [redacted]:            We are in receipt of your complaint notice regarding the above-referenced customer. We appreciate the opportunity to respond to Mr. [redacted]’s concerns regarding his expense payment instructions to Self Directed IRA Services, Inc.  (“SDIRA”).   It should be noted that Mr. [redacted] submitted two different expense payment requests on two separate dates. The first was processed by SDIRA on 11/17/2015 in the total amount of $896.20. The second was processed by SDIRA on 11/23/2015 in the total amount of $7,370.78. Mr. [redacted] did not provide an expense payment instruction for $9,300 on 11/17/2015 as stated in the complaint. Therefore, assuming the amount in question ($9,300) was logged into the Revdex.com complaint form incorrectly by Mr. [redacted], we will address the two expense payment requests outlined above.  The first expense payment request (total: $896.20) was submitted by Mr. [redacted] via email on the afternoon of 11/12/2015. Since the request did not contain sufficient information to process, SDIRA emailed him on the morning of 11/13/2015 requesting additional information. Mr. [redacted] then emailed the corrected forms to SDIRA on 11/17/2015. The expense request was processed, and the checks were sent via regular mail (as requested by Mr. [redacted]) the same day. On 12/3/2015, Mr. [redacted] called SDIRA indicating that the checks had not been received. He wanted SDIRA to waive any stop payment fees and overnight new checks to him at SDIRA’s expense. As a courtesy to Mr. [redacted], SDIRA offered to waive the stop payment fees, but we were not willing to overnight the checks at no cost since no error had occurred on the account. SDIRA left a message with Mr. [redacted] regarding this information. On the afternoon of 12/4/2015 (Friday), Mr. [redacted] called SDIRA again and requested that SDIRA overnight new checks at no charge to him. SDIRA did not agree to that, so Mr. [redacted] agreed for SDIRA to issue a stop payment on the checks at no cost and to mail the new checks to him via regular mail. On 12/7/2015 (Monday), SDIRA issued a stop payment on the checks and sent new checks via UPS ground as a courtesy so the checks could be tracked. That same afternoon, Mr. [redacted] called SDIRA to let us know that he had received the first round of checks that day. He also confirmed with one of our managers that the checks were dated 11/17/2015, and the envelope was postmarked on 11/17/2015. The delay was due to the US Postal Service, and it had nothing to do with SDIRA’s processing times. Unfortunately, Mr. [redacted] is unable to provide those checks to the vendor due to the stop payment that he requested. However, the new checks will be delivered to Mr. [redacted] shortly via UPS ground. The second expense payment request (total: $7,370.78) was submitted by Mr. [redacted] via email on the morning of 11/23/2015. The request and supporting documentation was received in good order, and the checks were processed and sent via regular mail (as requested by Mr. [redacted]). Those checks have cleared our bank, so the vendor has received and cashed the checks.  We trust that this response provides the information the Revdex.com needs for its resolution process.  SDIRA strives to go above and beyond for each client’s experience, and the fact that we processed both of these payments on the same day we received the requests in good order should be evidence of that. It has not taken four weeks to process as Mr. [redacted] claims, and SDIRA did not charge any additional fees for processing. In fact, we waived fees. If Mr. [redacted] is not satisfied, SDIRA will also waive the account termination fees if he wants to move his accounts to a different IRA custodian.  Please contact me at 866-928-9394 if you need any additional information regarding this matter or if you need documentation supporting SDIRA’s narrative in this response.  Again, we appreciate the opportunity to respond to this matter. Sincerely, [redacted]VP Compliance/Risk Management