Investable Wealth, LLC is a Limited Liability Company headquartered in the State of Utah. The Firm
specializes in concierge discretionary portfolio management services and is fee-based. Investable Wealth,
LLC was founded in 2013 by John Anthony Pugliano and he is the Firm’s Managing Member, Chief Compliance
Officer, and Principal Money Manager. Mr. Pugliano’s experience, education, and background can be found in
the accompanying Brochure Supplement Form ADV Part 2B.
INITIAL CONSULTATION & FIRM INTRODUCTION
Investable Wealth, LLC begins each Client relationship with at least one free consultation. The purpose of
the consultation is to:
Introduce the Client to Investable Wealth, LLC‘s investment philosophy, services and staff.
Acknowledgment that a potential conflict of interest exists because it is to the Firm’s benefit to
accumulate Client assets.
Advise the client to give careful consideration to the selection of a broker/custodian, a registered
investment adviser or the decision to leave a former employer’s retirement plan (e.g. 401k
rollover). Prior to the decision, the Client should understand the benefits and limitations of
available options and consider factors such as differences in investment related expenses, plan
or account fees, available investment options, distribution options, legal and creditor protections,
the availability of loan provisions, tax treatment, and other concerns specific to their individual
circumstances.
Ascertain information about the Client’s investment objectives, financial condition, and risk
tolerance, which are used to establish if the Firm’s services can act in the Client’s best interests.
Agree on the terms of service and compensation arrangements (Advisory Agreement).
Investable Wealth, LLC specializes in constructing long term growth objective portfolios consisting primarily
of Common Stocks, Exchange Traded Funds and Option Contracts. The degree of trading and asset allocation
fluctuates based on market conditions. The securities mentioned reflect a broad range of investment risk,
some of which may entail high degrees of risk. For more information on the Firm’s investment philosophy
see Item 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS.
DISCRETIONARY PORTFOLIO
MANAGEMENT
Investable Wealth, LLC manages Client portfolios on a discretionary basis. Discretionary authority is needed
to execute trade recommendations in a timely fashion. The Client will grant Investable Wealth, LLC limited
trading authority (discretionary authority) in the Client’s brokerage account by executing the appropriate
documents with the Client’s broker/custodian. The discretionary authority will allow Investable Wealth, LLC
to enter securities transactions on the Client’s behalf, determining which securities and the amount of
securities to buy or sell. Acting as the Client’s fiduciary, Investable Wealth, LLC will base investment
decisions on the Client’s predetermined investment objectives. With prior notice (as noted in Advisory
Agreement Amendment or Client correspondence), Investable Wealth, LLC will honor the Client’s
restrictions on investing in certain securities or types of securities because of their personal beliefs or social
conscience.
Clients will be notified of all transactions by trade confirmations from their broker/custodian. The Client
should always review their brokerage account statements/notices to verify the trading activity and
withdrawals that occur in their account(s). See also Item 15: CUSTODY.
Investable Wealth, LLC will also request the Client provide written authorization to allow automatic deducts
to pay advisory fees from the Client’s account (see Item 5: FEES & COMPENSATION); however, Investable
Wealth, LLC will not have the authority to make any other withdrawals from the Client’s account(s) under
management other than first-party transfers the Client has authorized with their broker/custodian.
Investable Wealth, LLC does not provide any “wrap programs” (programs that bundle brokerage and
advisory services under a single comprehensive fee); therefore, all securities transactions will include
additional charges by the Client’s broker/custodian separate from Investable Wealth, LLC’s portfolio
management fee. Clients are encouraged to use a discount broker/custodian that charges no, or
minimal transaction fees.
As of this filing, the Firm manages in excess of $60 million in discretionary assets. The Firm does not manage
non-discretionary accounts.