Instrumental Wealth offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Instrumental Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Instrumental Wealth setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement").
Instrumental Wealth registered as an investment adviser in September 2020 and is wholly owned by David Silver.
As of February 16, 2024, we provide continuous management services for $345,348,919 in client assets on a discretionary basis. We also manage $5,063,875 in client assets on a non-continuous basis.
While this brochure generally describes the business of Instrumental Wealth, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Instrumental Wealth's behalf and are subject to the Firm's supervision or control.
Financial Planning and Consulting Services Instrumental Wealth offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
•Business Planning •Retirement Planning
•Cash Flow and Budget Advice •Risk Management
•Trust and Estate Planning •Distribution Planning
•General Financial Advice •Tax Planning
•Coaching Other Advisors •Education Planning
•Insurance Planning •Bill payment support While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below).
In performing these services, Instrumental Wealth is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Instrumental Wealth recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Instrumental Wealth or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Instrumental Wealth under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Instrumental Wealth's recommendations and/or services.
5 Investment and Wealth Management Services Instrumental Wealth manages client investment portfolios on a discretionary basis. In addition, Instrumental Wealth provides the majority of its clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary management of investment portfolios.
Instrumental Wealth primarily allocates client assets among various mutual funds and exchange-traded funds ("ETFs") in accordance with their stated investment objectives. The Firm also expects to allocate certain client assets among fee-based annuities and life policies (both fixed and variable), as well as individual debt and equity securities, including privately placed securities and alternative investments.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Instrumental Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer

sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Instrumental Wealth directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider.
Instrumental Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Instrumental Wealth consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Instrumental Wealth if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Instrumental Wealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts.
Fee-Based Variable Annuities and Variable Life Policies Instrumental Wealth engages a third-party broker-dealer to transact variable annuity business. For information about how these products are billed and associated fee arrangements, see Item 5. Fees and Compensation. A conflict exists in that we will only offer fee-based annuities available to us under this program. This conflict is mitigated, however, because clients are not required to engage Instrumental Wealth for the purpose of investing in variable annuity products.
IRA Rollovers 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 and/or the Internal Revenue 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 6 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. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice, because the assets increase our assets under management and our advisory fees. In contrast, we receive less or no compensation if assets remain in the current plan or are rolled over to another Company plan in which you may participate.
Retirement Plan Consulting Services Instrumental Wealth provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
•Plan Design and Strategy •Plan Fee and Cost Analysis
•Plan Review and Evaluation •Plan Committee Consultation
•Executive Planning & Benefits •Fiduciary and Compliance
•Investment Selection •Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Instrumental Wealth as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Instrumental Wealth's fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement.