Description of Firm IDA (also referred to herein as the “Firm”) is an investment management firm founded in 2018, with its principal office located in Carlsbad, CA. In addition to our principal office, IDA has branch offices in various locations, including Murrieta, California, Scottsdale, Arizona, and Fort Worth, Texas. Please refer to our Form ADV Part 1 for a complete list, along with contact information. As further detailed in Item 4.B. below, IDA offers discretionary investment management, financial planning, and consulting services to individuals, qualified and non-qualified pension and profit- sharing plans, trusts, estates, charitable organizations, corporations, business entities, Private Placement Insurance companies, Eleemosynary Organizations, and Native American Sovereign Nations & Organizations. Some of the investment instruments IDA advises its clientele on include, among other things, mutual funds, exchange traded funds ("ETFs"), equities, bonds, treasuries, certificates of deposits, and affiliated and unaffiliated private funds (“Private Funds”). The Firm is a limited liability company registered with the SEC and has made notice filings in applicable states. IDA’s majority owner is Labrum Wealth Management, LLC1 which is 100% owned by Mr. Jason R. Labrum, who serves as IDA’s Founder & CEO. Please refer to Schedule A in Form ADV Part 1 for details on ownership of IDA. A. Types of Advisory Services Offered IDA provides the following types of advisory services: Financial Planning, Investment Management, and Consulting Services, all of which are more fully described below. Financial Planning Services Through the financial planning process, the IDA team strives to engage our clients in conversations around each clients’ financial goals, objectives, priorities, vision, and legacy – both for the near term as well as for the future. With the unique goals and circumstances of each client in mind, IDA will offer wealth planning ideas and strategies to address the client’s holistic financial picture. IDA does not provide tax or legal advice. However, IDA does have an affiliated certified public accounting (CPA) firm, IDA Tax, LLC (“IDA Tax”), that we recommend to clients for tax planning and preparation services. Please refer to Item 10 below for further details. We also will work with your independent tax and/or legal advisor (CPA and/or Estate Attorney) to help create a plan tailored to your specific needs. When relying on information from others, IDA is not liable for errors in the information provided and is not required to independently verify the information provided. Our specific services in preparing your financial plan may include, depending on client needs:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management and goals-based financial modeling.
• Creation of a unique asset/liability configuration matched to your financial goal(s). 1 Labrum Wealth Management, LLC was an SEC registered investment adviser from 2009 to 2019.
• Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention. Risk management is at the core of our investment philosophy. The objective is to achieve the targeted return needed to fund the client’s financial goal with the least amount of risk. IDA provides specific financial planning recommendations to clients, which are usually outlined in a written financial plan. The plan is reviewed annually or as needed. Depending on the needs of a client, IDA will suggest the services of certain professionals, including the Firm and certain affiliates, to implement recommendations made by IDA. Clients should be aware that this creates a conflict of interest since the Firm and its affiliates would receive compensation should a client engage them, which gives IDA an incentive to provide such recommendations. To mitigate this conflict, clients are free at all times to accept or reject any or all financial planning recommendations made by the Firm and retains the authority and discretion on whether or not to implement any or all of IDA’s recommendations. Clients also are free to implement IDA’s recommendations with any professional(s) of their choosing. Clients that decide to use IDA for investment management services and/or IDA Tax for tax services will be required to enter into separate agreements. 1. Investment Management Services We are committed to helping clients build, manage, and preserve their wealth, and to provide assistance that helps clients achieve their stated financial goals. IDA provides clients with ongoing Investment Management Services, which are performed on a discretionary basis. Prior to engaging IDA to provide Investment Management Services, the client is required to enter into an Investment Advisory Agreement with the Firm setting forth the terms and conditions of the engagement, including the specific scope of the services to be provided. In addition, each client completes a Client Profile setting forth important information related to the client’s investment goals and financial objectives, among other things. Clients are responsible for promptly notifying IDA in writing of any material changes in the information furnished by the client in the Client Profile or information that is otherwise material to the client’s financial situation, investment objectives, time horizon, risk tolerance and investment strategy or if they wish to impose any reasonable restrictions upon IDA’s management services. In the event that a client notifies IDA of changes to the information in their Client Profile, IDA will review such changes and implement in the case of a discretionary account, any necessary changes to the client’s portfolio. IDA meets with clients periodically to review the client’s investment goals and current advisory portfolios. Where appropriate, we provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage us to advise on certain investment products that are not administered or recommended by IDA, such as assets held in employer sponsored retirement plans, qualified tuition plans (i.e., 529 plans), life insurance and annuity contracts. Clients are advised and are expected to understand that our past performance is not a guarantee of future results. Also, that certain market and economic risks may exist that adversely affect an account’s performance, and this could result in capital losses in a client’s account. The Firm’s investment management services are divided into two types: IDA Strategy Portfolios, and IDA Custom Account Management. In addition, IDA offers Retirement Plan Solutions for plan sponsors. Each type of offering is described further below. IDA Model Portfolios IDA uses low cost, institutional share mutual funds, exchange traded funds (“ETFs”), and other investments to formulate a series of asset allocation model portfolios with objectives ranging from capital preservation to aggressive growth, which are then constructed by the Firm’s Investment Committee (“IC”) based on volatility and risk considerations. From time to time and depending on a client’s needs and investment objectives, IDA sometimes: (i) uses certain option strategies in an effort to mitigate market risks, and/or (ii) suggests the use of alternatives and/or Private Funds. Clients can invest in one or more of the model portfolios. Our Wealth Advisers meet with clients to discuss which model portfolio best meets their long-term personal goals and objectives. Portfolio management decisions for the Model Portfolios occur at the Investment Committee level, which meets approximately once per quarter or as often as needed. IDA Custom Account Management IDA offers account management for those clients who desire further customization to their portfolio(s). Based on the client’s goals and investment objectives, IDA will build a customized portfolio consisting of mutual funds, ETFs, closed-end funds, equities, fixed-income and/or cash management instruments, including bonds and other financial products, including Private Funds. In addition, when deemed appropriate and based on client needs and investment objectives, IDA will: (i) use certain option strategies to help mitigate market risks; (ii) suggest the use of certain robo-advisor programs, (iii) use alternatives investments and/or (iv) provide cash management services. Some of the Private Funds, mutual funds and ETFs utilized by IDA employ alternative or riskier strategies, such as the use of leverage, derivatives and/or hedging. Please refer to Item 8 below for detailed information regarding the Firm’s methods of analysis and the risks surrounding investments. IDA customizes clients’ portfolios according to their individual risk tolerance, time horizon and specific goals. For example, a client is able to place certain restrictions on their accounts, such as restricting the Firm from purchasing or selling a specific security, and restrictions on the types of securities, industries or sectors that may be included as part of the client’s account. Note that this may not be possible in all situations, such as when the client invests in mutual funds and ETFs. Clients are charged IDA’s customary asset under management fees pursuant to the terms of the Investment Advisory Agreement regardless of what type of positions are held in the account. Please see Item 12 for important information regarding the trading for this strategy. 2. Retirement Plan Solutions For employer-sponsored retirement plans with participant-directed investments, our firm provides its advisory services as an investment advisor as defined under Section 3(21) and 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary responsibility for the investment decisions made by IDA. IDA is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Investment Management Agreement between IDA and the ERISA plan. Our investment management is limited in that we have the discretion solely to replace funds in plan fund lineups and initiate the transfer of existing balances to the replacements without prior approval from the ERISA Plan client. As a 3(38)-investment manager, IDA provides the following services to the ERISA plan:
• Screen and select the investments that are offered to plan participants.
• Monitor the investments and replace investments with new investment offerings when appropriate.
• Provide a quarterly monitoring report.
• Assist in education and enrollment of plan participants.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor fiduciary responsibility and enhance the participant experience. When serving as an ERISA 3(21) investment adviser, the plan sponsor and IDA share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Investment Advisory Agreement between IDA and the ERISA plan. As a 3(21)-investment manager, IDA provides the following services to the plan sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggest replacement investments when appropriate.
• Provide a quarterly monitoring report.
• Assist in education and enrollment of plan participants.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor fiduciary responsibility and enhance the participant experience. Additional services applicable to IDA’s Retirement Plan Solutions are described in the client agreement. IDA is deemed a “Covered Service Provider” to pension plan clients under ERISA Section 408(b)(2) regulations and is a fiduciary under Sections 3(21) or 3(38) of ERISA. ERISA Section 408(b)(2) requires Covered Service Providers to make required disclosures to the responsible plan sponsor (“RPS”) that are in writing, and include information the RPS needs to (i) assess the reasonableness of total compensation, both direct and indirect, received by the Covered Service Provider, its affiliates, and/or subcontractors, (ii) identify potential conflicts of interest, and (iii) satisfy reporting and disclosure requirements under Title I of ERISA. IDA provides its pension plan clients with such information prior to entering into a written agreement with such clients, and annually thereafter. 4. Futuready 401(k) Platform Futuready 401(k) is a customized solution that is offered by IDA for retirement plans. IDA has teamed up with a custodian, Matrix Trust Company, a Broadridge company (“Matrix”) and a third- party administrator and record-keeper, The Retirement Plan Company, LLC (“TRPC”) to work closely together to deliver lower cost services to retirement plan sponsors and their employees. Under this platform, IDA offers fiduciary services, which include the below, as selected by the client via the agreement entered into with IDA: Section 3(38)-investment manager discretionary fiduciary services:
• Develop Investment Policy Statement (IPS) based on the investment objects, risk tolerance, and goals of the ERISA Plan
• Select & replace designated investment alternatives in line with IPS
• Select & replace qualified default investment alternative (QDIAs) in accordance with IPS
• Provide advice regarding model asset

allocation portfolio models created by IDA Section 3(21) non-discretionary fiduciary services:
• Provide investment advice to participants based on their investment objectives, risk tolerance, and time horizon. Non-fiduciary consulting services (as selected by client):
• Administrative support
• Service provider support
• Investment monitoring support
• Participant services 5. Institutional Robo-Adviser Programs: Betterment IDA does not currently sponsor nor provide management services to any wrap fee program, as that term is defined in the instructions to Form ADV Part 2. However, as described below, from time-to- time IDA will recommend to certain clients that they invest a portion of their assets in a robo- adviser program2, based on the client’s specific financial needs and investment objectives. Certain robo-adviser programs are provided through a wrap program. Specifically, IDA, from time to time recommends the robo-adviser programs that are sponsored by Betterment, LLC, through their wrap program. Betterment is an SEC registered investment adviser and is not affiliated with IDA. The terms and conditions under which the client will enter into the program will vary by program and be set forth in separate written agreements between (1) the client and IDA and (2) the client and the adviser providing the robo-adviser program. IDA shall continue to render advisory services to the client relative to the ongoing monitoring and review of account investments and performance, for which IDA shall receive an annual advisory fee from the client, which is based upon a percentage of the market value of the assets being managed under the program. Importantly, clients should understand that IDA’s advisory fee is exclusive of the fee(s) charged under the robo- 2 Please refer to SEC Investor Bulletin on Robo-Advisers for important information (https://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor-bulletin-robo-advisers ) adviser program. Also, the underlying investments in the program, which typically consist of Exchange Traded Funds (ETFs) have internal management fees and expenses that are deducted from the assets of the ETF. Please see Item 5 below for further information on fees. Factors that IDA shall consider in recommending a robo-adviser program include the sponsor’s reputation, style of management, performance, and services being offered. In addition to IDA’s written disclosure statement (Form ADV Part 2A), the client shall also receive the written disclosure statement from the firm sponsoring the robo-adviser program. These disclosure statements should be read in their entirety in order to understand the services, fees, risks, and conflicts associated with the robo-adviser program. Please refer to Item 12 for information regarding the arrangements for the wrap fee program. 6. Envestnet Services IDA has contracted with Envestnet PMC (“Envestnet”) to provide access to their portfolio modeling, account trading and administration systems. The services provided by Envestnet include:
• Assessment of the client's investment needs and objectives.
• Implementation of asset allocation.
• Delivery of suitable style allocations (e.g., Large Cap, Small Cap, Growth, Value, etc.)
• Facilitation of portfolio transactions.
• Ongoing monitoring of investment vehicle performance.
• Review of client accounts for adherence to policy guidelines and asset allocation.
• Recommendations for account re-balancing, if and when necessary.
• Reporting of client portfolio performance and progress.
• Engaging selected investment vehicles on behalf of the client 7. IDA Adviser Network – TAMP Services IDA offers investment management services to unaffiliated investment advisers under a turnkey asset management arrangement (“TAMP Services”). To perform these services, IDA enters into an agreement with the third-party investment adviser, which outlines that IDA will provide ongoing investment management on a discretionary basis to certain of the adviser’s clients (“TAMP Clients”). In addition, each TAMP client also enters into a client agreement with IDA. The investment management services that IDA offers are generally the same that the Firm offers to other investment management clients. However, the investment management fees paid by TPAM clients are different, and in some cases, lower than what other IDA clients pay. Please see Item 5 below for further information. 8. Held Away Accounts: Pontera IDA provides an additional service through “Pontera” for accounts not directly held at a Qualified Custodian. The platform allows us to avoid taking custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using the platform. A link is provided to the Client allowing them to connect their account(s) to the platform. Once the Client account(s) are connected, IDA may leverage an Order Management System to manage the account and place trades on behalf of the client. These are primarily 401(k) accounts, HSA’s, and other assets, all of which are held away and managed on a discretionary basis. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. C. Private Investments Although the investment advice provided by IDA is not limited to any specific type of investment, IDA does from time to time, depending on the sophistication, risk tolerances, and qualifications of the client, recommend that a portion of such client’s assets be invested in certain affiliated and unaffiliated private investments. These include hedge funds, real estate funds, and other types of private investment vehicles (collectively “Private Funds”). The Private Funds may invest in various types of instruments, including but not limited to equities, debt securities, real estate, first trust deeds, private companies, and other private investment funds. IDA shall continue to render advisory services to the client relative to the ongoing monitoring and review of asset performance and due diligence of the Private Fund. When determining which clients should receive a recommendation to invest in a Private Fund, IDA considers a number of factors, including but not limited to a client’s sophistication and qualification, risk tolerance, investment objectives, and the amount of available assets in the client's account(s). IDA’s goal is to allocate in a fair and balanced manner; however, given these differing factors, the allocation of investment opportunities in Private Funds to our clients is subjective and not all qualifying clients will be provided an investment opportunity. (Please refer to Item 12 for further information on the allocation of Private Fund investments). The client assets with each Private Fund are held at the custodian selected by each Private Fund’s sponsor or investment manager. The performance of these Private Funds typically is reported directly from the sponsor. Clients investing in Private Funds are provided with private placement memorandums and other offering and subscription documentation that detail the nature, risks, and associated fees of each Private Fund. It is important that the client read these documents before investing to fully understand the types of investments, risks and conflicts pertaining to the Private Funds. IDA and certain IDA investment adviser representatives (“IARs”) have affiliations and/or arrangements with the issuer, general partner, managing member, or investment manager (as applicable) of certain Private Funds. Also, there are times when certain IDA Associated Persons invest in Private Funds. Mr. Jason Labrum, who is the owner and Founder/CEO of IDA, and Mr. Alex Klingensmith, President of IDA are partial owners and co-Managing Members of Invictus Real Estate Partners, LLC (“RE Partners”). RE Partners serves as the Managing Member of the Invictus Total Return Real Estate Fund, LP (“Invictus Fund”), which is a private real estate fund. Because the fund is closed to new capital and investors, IDA IARs, Mr. Labrum, and Mr. Klingensmith are no longer recommending the Invictus Fund to qualifying IDA clients. In addition, please refer to Items 5, 6, 8, 10, 11, 13, and 14 for further disclosures regarding the Invictus Fund, including the fees received by Mr. Labrum and Mr. Klingensmith and how IDA addresses the conflict surrounding this arrangement. D. General Information about IDA’s Advisory Services As indicated above, advisory services provided by IDA are customizable based upon the individual needs, objectives, and other financial goals of the client. Early on in the relationship, IDA will typically memorialize each client’s investment objectives, risk tolerance, time horizons and other important information, including any investment guidelines, in a client profile or similar document. This information, together with any other information relating to the client’s overall financial circumstances, will be used by the Firm to determine the most appropriate asset allocation and investment strategy to best meet the client’s financial goals. IDA will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that the Firm may have relied upon in rendering its services. In the event that a client notifies the Firm of such changes, IDA will review the changes and may recommend revisions to the client’s financial plan and/or portfolio. There are times when a client may decide to use margin in their account, or when a margin account is necessary, such as when a client invests in certain types of options. Clients should be aware that the use of margin creates a conflict of interest between IDA and our clients since our investment management asset-based fees are calculated on the full value of a client’s assets under management, including any margin balance, which means clients with margin balances in their account will pay a higher fee than they would if they had a cash account. In addition, clients will be charged margin interest by the custodian on the debit balance in their custodial account. (Please refer to Item 5 below for further information on fees) Margin accounts also carry risks, which are summarized in Item 8 below and should be carefully considered before opening a margin account. Please note that using margin is not suitable for all investors; the use of margin increases leverage in a client’s account and therefore increases overall risk. In addition, depending on the needs of a client the Firm will recommend and assist a client with obtaining a securities-backed loan or line of credit with an unaffiliated third-party bank or custodian. These types of loans are not suitable for all investors and carry some risks (please refer to Item 8 below for details on applicable risks). There also is a conflict of interest surrounding the Firm’s recommendation to obtain such a loan, mainly due to the fact that the loan proceeds can be used in place of a client having to withdraw assets from their account managed by the Firm. Therefore, the Firm continues to receive fees on the securities in the account even though they are used as collateral. To address this conflict, the Firm has implemented policies and procedures to ensure that all recommendations being provided to clients are suitable and the clients are aware of all material risks and conflicts. Clients should not obtain such a loan or line of credit without fully understanding applicable costs, benefits, conflicts, and risks. E. IPO and SPO Consulting Services From time-to-time IDA receives requests from qualified clients for IDA to obtain shares in a specific initial or secondary initial offering (IPO and SPO) on behalf of the client. IDA provides this service on a very limited basis and only when we believe the requesting client is not otherwise prohibited from investing in such public offerings. IDA reserves the right to turn down any requesting client. In addition, there can be times when IDA is not able to obtain some or all of requested shares. IDA does not provide any recommendations or investment advice regarding the IPOs/SPOs, and shares obtained will be held by the client in an unmanaged account. F. Advisory Agreement with IDA Prior to engaging IDA to provide services, each client will be required to enter into one or more written agreements with us, setting forth the services to be provided, the fees to be charged and the terms and conditions under which we will render our services. IDA will provide this Brochure and the applicable Brochure Supplements (Form ADV Part 2B) to each client or prospective client prior to or upon execution of our written agreement. We also provide a copy of Form CRS to each new or prospective retail client. The advisory relationship will continue until terminated by the client or IDA in accordance with the provisions of the executed agreement(s). G. Amount of Client Assets Managed As of March 20, 2024, IDA manages $955,067,966 in assets on a discretionary basis. IDA has a total of $1,267,416,236 under advisement (including regulatory assets under management) which includes $296,976,668 in Retirement Plans. IDA also has an additional $62,333,326 attributable to client cash or courtesy account holdings that are not currently receiving management.