Form ADV Part 2A — Firm Brochure

Item 1 — Cover Page

Firm Name: Ohey Inc.

Principal Office: Pleasanton, CA 94588

Website: https://oheyinc.com

Contact: [email protected]

SEC File No.: 801-135267  |  CRD No.: 340093

Additional information about Ohey Inc. also is available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our CRD number is 340093.

Item 2 — Material Changes

Since the initial filing, the following material changes have been made: updated pricing to reflect current subscription tiers (Basic $0/month, Advanced $29/month or $348/year, Pro $79/month or $948/year); clarified the firm's status as an Internet Investment Adviser under Rule 203A-2(e); added California Consumer Privacy Act (CCPA/CPRA) disclosures to the Privacy Policy; expanded investor profile data collection to include date of birth, employment status, liquid net worth, tax status, maximum position size percentage, and approved trading strategies for enhanced suitability compliance; implemented server-side signal filtering enforcement via JWT authentication; and established a signal archival system for advisory content recordkeeping under Rule 204-2.

Item 3 — Table of Contents

• Item 1: Cover Page
• Item 2: Material Changes
• Item 4: Advisory Business
• Item 5: Fees and Compensation
• Item 6: Performance-Based Fees
• Item 7: Types of Clients
• Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
• Item 9: Disciplinary Information
• Item 10: Other Financial Industry Activities
• Item 11: Code of Ethics
• Item 12: Brokerage Practices
• Item 13: Review of Accounts
• Item 14: Client Referrals and Other Compensation
• Item 15: Custody
• Item 16: Investment Discretion
• Item 17: Voting Client Securities
• Item 18: Financial Information

Item 4 — Advisory Business

Item 4.A — Advisory Services: Ohey Inc. provides personalized, non-discretionary investment advisory services exclusively through its operational interactive website at oheyinc.com. As a registered investment adviser, Ohey Inc. owes its clients a fiduciary duty of care and loyalty and is required to act in clients' best interest and provide full disclosure of all material conflicts of interest. We provide the following types of investment advice:

• AI-Generated Trade Signals — Machine-learning models analyze 50+ market parameters to generate specific options trade recommendations (including entry, exit, stop-loss, and position sizing) personalized to each client's risk profile and experience level
• Strategy Recommendations — Algorithm-driven strategy suggestions (e.g., Iron Condor, Credit Spread, Straddle) based on market regime classification and individual client risk tolerance
• Portfolio-Level Analytics — Personalized portfolio risk analysis including gamma exposure, delta hedging recommendations, and volatility surface assessment
• Risk Parameter Guidance — Position sizing, maximum allocation, and leverage recommendations calibrated to each client's stated financial situation and risk tolerance

All investment advice is generated by software-based models and algorithms, based on personal information each client supplies through the interactive website. We do not manage client accounts, execute trades on behalf of clients, or have custody of client funds. All advisory services are non-discretionary — clients make all trading decisions and execute trades through their own chosen broker.

Item 4.C — Tailoring of Advisory Services: Our advisory services are tailored to each client's individual needs based on information collected during our 4-section onboarding process (Personal Information, Trading Preferences, Approved Strategies, and Investment Restrictions). Specifically:

• Risk Profile Tailoring: Clients provide their risk tolerance, which is used to filter and calibrate all recommendations. Conservative clients receive lower-risk strategies; aggressive clients may see higher-risk/higher-reward opportunities.
• Experience-Level Tailoring: Clients indicate their investing experience (Beginner through Expert). The platform adjusts the complexity and risk level of recommendations accordingly. Beginners receive simpler strategies with more detailed guidance.
• Financial Situation Tailoring: Clients provide annual income, liquid net worth, and total net worth. Position sizing and allocation recommendations are scaled to the client's reported financial situation.
• Time Horizon Tailoring: Clients select their preferred investment time horizon (intraday to long-term). Recommendations are adjusted to match the client's stated time horizon.
• Client-Imposed Restrictions: Clients may impose restrictions on the types of advice they receive, including: no leverage, no short selling, maximum position size limits, and maximum options allocation percentages. These restrictions are enforced in the recommendation engine — restricted strategies are excluded from recommendations. Clients can update their restrictions at any time through the platform settings.

Assets Under Management: $0 in discretionary assets; $0 in non-discretionary assets (Ohey Inc. does not manage client assets — clients execute trades through their own brokers).

Item 5 — Fees and Compensation

Item 5.A — Fee Schedule: Ohey Inc. charges fixed subscription fees for access to its advisory platform. Current fee tiers:

• Basic: $0/month — Access to foundational analytics and limited signals
• Advanced: $29/month ($348/year) — Full signal access, portfolio analytics, regime detection
• Pro: $79/month ($948/year) — All Advanced features plus priority signal delivery, advanced risk analytics, and premium strategy recommendations

Current pricing is always available at oheyinc.com/pricing. Fees are billed monthly or annually via Stripe. No performance-based fees, commissions, or transaction fees are charged. Users may cancel at any time; refund policy is detailed in the Terms of Service.

Item 5.C — Other Fees and Expenses: In addition to our subscription fees, clients will incur the following costs charged by third parties (not by Ohey Inc.):

• Brokerage commissions and transaction costs — charged by the client's chosen broker for each trade executed
• Exchange fees — charged by options exchanges for options transactions
• Custodial fees — charged by the client's broker or custodian for account maintenance
• Regulatory fees — SEC fees and FINRA Trading Activity Fees (TAF) applied to securities transactions
• Fund expenses — If a client invests in ETFs or mutual funds, those products carry internal expense ratios

Ohey Inc. does not receive any portion of these third-party fees. Clients should review their brokerage agreement and fee schedule. For more information on brokerage costs, see Item 12 — Brokerage Practices below.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Item 6 — Performance-Based Fees

Ohey Inc. does not charge performance-based fees.

Item 7 — Types of Clients

Ohey Inc. provides services to individual retail investors, professional traders, and institutional users. There is no minimum account size requirement, though certain platform tiers require minimum subscription levels.

Item 8 — Methods of Analysis, Investment Strategies, and Risk of Loss

Methods of Analysis:

• Quantitative models using gradient-boosted trees (XGBoost, LightGBM)
• Deep learning models (TensorFlow MLP, Temporal Fusion Transformers)
• Walk-forward cross-validation with purged k-fold methodology
• Conformal prediction for uncertainty quantification
• Out-of-distribution detection for regime change identification
• Options Greeks analysis (delta, gamma, vanna, charm, vomma)

Investment Strategies: Ohey Inc. generates recommendations across multiple options strategies, including but not limited to:

• Directional strategies: Long calls, long puts, bull call spreads, bear put spreads
• Income/neutral strategies: Iron condors, credit spreads, covered calls, cash-secured puts
• Volatility strategies: Straddles, strangles, calendar spreads, butterfly spreads

Strategy selection is personalized based on each client's risk tolerance, experience level, and stated investment goals as described in Item 4.C.

Risk of Loss: Investing in securities, particularly options, involves substantial risk of loss. Clients should understand the following material risks:

• Leverage risk: Options are leveraged instruments; small changes in the underlying security can cause disproportionate gains or losses
• Time decay (theta) risk: Options lose value as they approach expiration, regardless of the underlying's movement
• Volatility risk: Changes in implied volatility can materially affect option prices independent of the underlying security's direction
• Assignment risk: Short options positions may be assigned at any time, potentially resulting in unexpected obligations
• Liquidity risk: Some options contracts may have limited trading volume, resulting in wider bid-ask spreads and difficulty exiting positions
• Model/algorithmic risk: Our AI/ML models are based on historical data and may not accurately predict future market conditions. Model performance can degrade during regime changes or unprecedented market events
• Technology/latency risk: Platform downtime, network delays, or data feed interruptions may prevent timely execution of recommended trades
• Concentration risk: Over-reliance on a single strategy or asset class may amplify losses

Past performance of the platform's models is not indicative of future results. All backtested performance figures are hypothetical and subject to hindsight bias. Users should be prepared to lose their entire investment. Options trading is not suitable for all investors.

Item 9 — Disciplinary Information

Ohey Inc. has no disciplinary events to disclose. Neither the firm nor any of its management persons have been subject to any legal or disciplinary events material to a client's evaluation of the firm.

Item 10 — Other Financial Industry Activities and Affiliations

Ohey Inc. is not registered as a broker-dealer and has no material relationships with other financial industry entities that would create a conflict of interest.

Control Persons: Sivakumar Patchayappan is the sole owner (100% equity) and serves as Chief Executive Officer and Chief Compliance Officer of Ohey Inc. Mr. Patchayappan is not registered as a broker-dealer or associated person of a broker-dealer. No other individuals or entities control the management or policies of Ohey Inc.

Item 11 — Code of Ethics, Participation in Client Transactions, and Personal Trading

Ohey Inc. maintains a Code of Ethics adopted pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code establishes standards of business conduct reflecting fiduciary duties, compliance with federal securities laws, personal securities transaction and holdings reporting requirements, pre-clearance procedures for IPOs and limited offerings, insider trading prevention policies, and confidentiality obligations. A copy of the Code of Ethics is available upon request by contacting [email protected] or at oheyinc.com/docs/legal/code-of-ethics.html.

Ohey Inc. does not participate in client transactions, engage in principal trading, or trade for its own proprietary accounts in securities that are recommended to clients. Access persons are subject to pre-clearance, quarterly transaction reporting, and annual holdings reporting as detailed in the Code of Ethics.

Item 12 — Brokerage Practices

Ohey Inc. does not execute trades on behalf of clients and does not select or recommend broker-dealers. Users independently choose their own brokerage firms for trade execution.

Soft-dollar arrangements: Ohey Inc. does not receive any soft-dollar benefits or research from broker-dealers.

Directed brokerage: Because Ohey Inc. does not execute trades or select brokers, directed brokerage is not applicable. Clients are responsible for evaluating their own broker's execution quality, commissions, and capabilities.

Best execution: Because clients self-direct all trade execution through their own chosen brokers, Ohey Inc. does not have a best execution obligation with respect to trade execution. Clients should independently evaluate whether their broker provides satisfactory execution quality.

Item 13 — Review of Accounts

Reviews: Sivakumar Patchayappan, Chief Compliance Officer, reviews the advisory relationship and suitability of recommendations on at least an annual basis. Additional reviews are triggered by: (a) material changes in a client's stated financial situation, risk tolerance, or investment objectives; (b) significant model performance degradation; (c) material changes in market conditions or regulatory requirements.

Automated monitoring: Model performance is reviewed continuously via automated validation pipelines, walk-forward testing, and real-time monitoring of signal quality metrics. Alert thresholds trigger immediate human review when model accuracy falls below acceptable levels.

Reports to clients: Clients can view their signal history, profile-matched recommendations, and performance tracking through the platform dashboard at any time. The platform does not produce periodic written reports, as all information is available in real-time through the interactive website.

Supervision and Compliance Oversight

Sivakumar Patchayappan serves as both Chief Executive Officer and Chief Compliance Officer (CCO). The CCO is responsible for administering the firm's written compliance policies and procedures, including:

• Monitoring all algorithmic signal generation for consistency with stated investment methodology
• Reviewing suitability determinations for each client based on their investor profile
• Conducting periodic compliance testing of the technology platform
• Maintaining and enforcing the Code of Ethics
• Reviewing marketing materials prior to publication (see Advertising Review Policy)

Because Mr. Patchayappan serves in a dual CEO/CCO capacity, the firm engages independent outside counsel to conduct an annual compliance review pursuant to Rule 206(4)-7. This review provides independent oversight of the compliance program, including evaluation of the CCO's performance and the adequacy of compliance policies and procedures. The most recent annual review was completed in Q1 2026.

Item 14 — Client Referrals and Other Compensation

Ohey Inc. does not pay referral fees or receive compensation from third parties for client referrals.

Item 15 — Custody

Ohey Inc. does not have custody of client funds or securities.

Item 16 — Investment Discretion

Ohey Inc. does not exercise investment discretion over client accounts.

Item 17 — Voting Client Securities

Ohey Inc. does not vote proxies on behalf of clients and does not have authority to do so. Clients retain full authority over proxy voting for securities held in their accounts. Clients will receive proxy materials directly from their broker or custodian and are responsible for voting their own securities. Clients should direct any questions about proxy voting to their broker or custodian.

Item 18 — Financial Information

Ohey Inc. does not require prepayment of fees more than $1,200 six months or more in advance, and has no financial condition that would impair its ability to meet contractual commitments to clients.