A. Invariant Investment Management LLC (“Adviser”) is an investment adviser founded in August 2013, registered with the U.S. Securities and Exchange Commission (“SEC”), and is principally owned by Seth Arbogast, David Borowsky, Gary Smith, and Jonathan Turner.
B. Adviser offers the following types of advisory services: i.Portfolio Management Services: Adviser offers ongoing portfolio management services directly to investing clients based on the individual goals, objectives, time horizon, and risk tolerance of each client. Adviser creates an Investment Policy Statement for each client, which outlines his or her current holistic financial situation.
Portfolio management services include, but are not limited to, the following: ● Investment strategy recommendations ● Personal investment policy crafting ● Asset allocation recommendations ● Asset selection recommendations ● Risk tolerance evaluations ● Ongoing portfolio monitoring Adviser evaluates the current investments of each client with respect to his/her risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
Portfolio Management Services are primarily offered on a discretionary basis, in which case Adviser will be granted a limited power of attorney by clients to buy and sell securities in their accounts. Adviser will manage client portfolios on an ongoing basis in-line with the Investment Policy Statement, which may involve periodic rebalancing transactions and portfolio adjustments as necessary in its discretion. Alternatively, Adviser offers non-discretionary Portfolio Management Services, in which case clients will be required to approve purchases and sales of securities by Adviser before implementation into their portfolios.
ii.Financial Planning Services: Financial Planning Services are generally included as part of Adviser’s Portfolio Management Services for no additional fee, but from time Adviser may also offer a one-time, standalone financial plan for a client that does not otherwise receive portfolio management services. Such Financial Planning Services generally incorporate analyses and recommendations with respect to cash flow, savings, retirement planning, investment composition, tax efficiency, debt reduction, and estate planning (among other related topics). Since Adviser’s financial planning recommendations are often dependent on clients implementing such recommendations in conjunction with their own independent legal, tax, and other professionals, Adviser does not provide any legal, tax, or other professional advice in conjunction with its Financial Planning or other services.
iii.Subadvisory Services: Adviser also offers ongoing portfolio management services in the capacity of a subadviser to other independent and unaffiliated registered investment advisers (“Independent Advisers”) and their respective investing clients. In this sub-advisory capacity, Adviser builds and manages model investment portfolios (“Model Portfolios”)

that are designed to incorporate varying levels of risk, return potential, asset class exposure, and securities allocation. Though the Independent Advisers are responsible for selecting and implementing the Model Portfolios for their respective clients, Adviser retains the responsibility to trade and rebalance the Model Portfolios based on its own independent investment research and judgment.
Invariant generally limits its investment advice to mutual funds, equities, fixed income securities, exchange traded funds (“ETFs” (including ETFs in the gold and precious metal sectors), real estate funds (including real estate investment trusts, or “REITs”), non-U.S. securities, commodities, and insurance products including annuities. From time to time and when appropriate to the particular client, Adviser will use other securities to help diversify a portfolio.
C. Adviser tailors its advisory services to the individual needs of its clients by taking the time to understand clients’ current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment recommendations and decisions that reflect clients’ individual needs and objectives on an initial and ongoing basis.
Adviser’s recommendations and decisions will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser.
D. Adviser does not participate in any wrap fee programs.
E. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ●Meet a professional standard of care when making investment recommendations (give prudent advice); ●Never put our financial interests ahead of yours when making recommendations (give loyal advice); ●Avoid misleading statements about conflicts of interest, fees, and investments; ●Follow policies and procedures designed to ensure that we give advice that is in your best interest; ●Charge no more than is reasonable for our services; and ●Give you basic information about conflicts of interest.
F. Adviser manages the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2023: i.Discretionary:$100,665,772 ii.Non-Discretionary:$371,056 iii.Total:$101,036,828