Description of Advisory Firm
Invenio Wealth Partners, LLC (“IWP”, the “Firm”, “we”, “our,” or “us”) is a Limited Liability Company
headquartered in Coral Gables, FL. IWP is solely owned by the Firm’s founders through their own LLCs.
The founder/owners include Christina Hudson, Johanna Arbelaez-Perez and Joseph A. Fernandez, CFP®.
The Firm was formed in 2022.
IWP is registered as an investment adviser with the U.S. Securities and Exchange Commission. As of
December 31, 2022, the Firm managed approximately $215,304,665 in assets for approximately 170
accounts, all of which are managed on a discretionary basis. The Firm does not offer a wrap program.
We custody our clients’ assets primarily at Pershing (a division of BNY Mellon) and use traditional as well
as alternative classes of investments.
The Firm offers discretionary investment management, non-discretionary and investment advisory
services as well as financial planning and consulting. Prior to the Firm rendering any of the foregoing
advisory services, clients are required to enter into one or more written agreements with the Firm setting
forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
Advice is provided through consultation with the client and may include determination of financial
objectives, identification of financial issues, cash flow management, tax planning, insurance review,
investment management, education funding, retirement planning, and estate planning.
In performing its services, IWP shall not be required to verify any information received from the client or
client’s other professionals. Moreover, each client is advised that it remains his/her/their responsibility to
promptly notify IWP if there is ever any change in his/her/their financial situation or investment objectives
for the purpose of reviewing/evaluating/revising IWP’s previous recommendations and/or services.
IWP cautions its clients on the use of email. Standard email is inherently unsecure. Most email is
unencrypted. As each email travels to its intended destination, it traverses an untold number of servers
and can be intercepted and viewed by virtually anyone with the proper know-how. This security flaw in
email as it exists today, places confidential data at risk. If you have a service request, do not include your
personal identifiable information in an email when you send it to IWP. Instead, we suggest that you call
your advisor or our client service team, and we will be happy to assist you.
While this brochure generally describes the business of the Firm, 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 any other person who provides
investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
Advisory Services Offered
IWP embraces the fiduciary standard of putting our client’s interests first. IWP provides discretionary
Wealth Management services and Investment Advisory services; furnishes investment advice through
consultations; and serves as an ERISA investment fiduciary and advisor to Plan fiduciaries.
Occasionally, IWP furnishes advice to clients on matters not involving securities, including financial
planning matters such as taxation, insurance, and estate planning.
IWP, as wealth managers, is focused on a comprehensive approach to personal financial management.
The goals and objectives for each client are documented in financial planning software. Investment policy
statements are created that reflect the client’s stated goals and objectives.
Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter into one
or more written agreements with the Firm setting forth the relevant terms and conditions of the
appropriate advisory relationship (the “Advisory Agreement”).
Wealth Management Services
Our core offering is our wealth management service (financial planning-based retirement planning and
investment management) which includes continuous and regular investment supervisory services on a
discretionary basis as well as financial planning and consulting. IWP is an employee-owned firm, dedicated
to providing customized, fee-only, Wealth Management advisory services to high-net-worth individuals,
including professionals, corporate executives, pension and profit-sharing plans, trusts, estates, charitable
organizations, and small businesses. We work with clients and have the ongoing responsibility to select
and/or make recommendations based upon the objectives of the client, as to specific securities or other
investments that IWP recommends or purchases/sells in clients’ accounts. We utilize a variety of
investment types when making investment recommendations/purchases in client accounts which include,
but are not limited to equity securities, fixed income securities, alternatives, ETFs, mutual funds, and
independent investment managers. The investments recommended/purchased are based on the clients’
individual needs, goals, and objectives. The Firm offers investment advice on any investment held by the
client at the start of the advisory relationship. We describe the material investment risks under Item 8 –
Methods of Analysis, Investment Strategies, and Risk of Loss. Financial Planning may be provided to clients
as a part of the Investment Management Services. When being provided as a separate service it is
described in this section under Financial Planning and Consulting Services below.
We start with a series of in- depth conversations and data collection. With that information, we proceed
to develop a plan for you and your family (or your institution) that identifies the specific investment
criteria and strategies based on our review of available investment options, taxation, transaction costs,
and risk and projected hypothetical performance. This plan is prepared in the form of an Investment Policy
Statement (IPS). This vital document, which we review with you to ensure it reflects your needs, sets the
foundation for how we recommend the allocation of your assets between various investment classes.
Upon completion of the initial planning and the client’s approval of the Investment Policy Statement, at
the client’s discretion, IWP will provide on-going Wealth Management services.
Implementation and on-going management of our clients’ accounts includes:
• Design, execution, and maintenance of a customized Investment Policy Statement for those assets
under the limited discretionary authority of IWP;
• Active tax and cost-efficient investment portfolio management for assets under the limited
discretionary authority of IWP. This will include portfolio allocation, investment strategy and
manager selection;
• Maintain and update, as necessary, a financial goal and needs analysis - an analytical process that
evaluates the likelihood of meeting stated goals, based on the client assets, liabilities, and relevant
economic assumptions. This analysis, utilizing our version of E-Money Advisor, is generally
updated on an annual basis - more often if the client experiences a significant unanticipated life
transition or there is a dramatic change in market conditions;
• Monitor independent investment managers and vehicles selected for implementation;
• As necessary, rebalancing, policy and/or strategy modification and/or allocation/manager
replacements;
• As requested, implementation of cash flow strategies for planned cash flow needs, including cash
flow/emergency reserve account(s);
• Quarterly detailed reports of the client investment portfolio(s) under our management;
• As requested, implementation of cost and tax efficient liquidations for unanticipated cash flow
needs;
• As requested, provision of preliminary tax information (e.g., realized, and unrealized gains,
delivery of information and coordination with client's CPA) for client's tax planning, for assets
under our management;
• Establishment and coordination of appropriate accounts along with related asset transfers to the
IWP institutional platform; and/or
• Establish, as requested, “non-managed” cash flow reserve and investment accounts at selected
custodians. IWP does not currently charge for these unmanaged accounts.
Most clients choose to have IWP manage their assets in order to obtain ongoing in-depth advice. The
scope of work and fee for an Advisory Agreement is provided to the client in writing prior to the start of
the relationship.
We discuss our discretionary authority below under Item 16 – Investment Discretion. We describe the fees
charged for investment management services below under Item 5 – Fees and Compensation.
Investment Advisory
An Investment Advisory Agreement may be executed when financial planning is not provided as part of
the relationship.
Investment Advisory Services include:
• Development, implementation, maintenance, and execution of a customized Investment Policy
Statement for those assets under the limited discretionary authority of IWP;
• Active tax and cost-efficient investment portfolio management for assets under the limited
discretionary authority of IWP. This will include allocation and strategy selection;
• Monitor investment managers and vehicles selected for implementation;
• As necessary, rebalancing, policy and/or strategy modification and/or allocation manager
replacements;
• Quarterly detailed reports of the client investment portfolio(s) under our management;
• As requested, implementation of cost and tax efficient liquidations for unanticipated cash flow
needs; and/or
• As requested, provision of preliminary tax information (e.g., realized, and unrealized gains,
taxable interest and dividends, delivery of information and coordination with client’s CPA), for
client’s own tax planning.
Establishment and coordination of appropriate accounts along with related asset transfers to the IWP
wealth management institutional platform.
Financial Planning and Consulting Services
The Firm offers a broad range of financial planning and consulting services, which may include any or all
of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Manager Due Diligence
While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail above).
IWP does not serve as an attorney, accountant, or insurance agent, and no portion of our services should
be construed as same. Accordingly, IWP does not prepare legal documents, prepare tax returns, or sell
insurance products. To the extent requested by a client, we may recommend the services of other
professionals for non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.).
The client is under no obligation to act upon the investment adviser’s recommendation. If the client elects
to act on our recommendations, the client is under no obligation to effect the transaction through us.
The client retains absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from IWP and/or its representatives. If the client engages any professional (i.e.,
attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional.
At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and
not IWP, shall be responsible for the quality and competency of the services provided.
We describe fees charged for Consultation Services below under Item 5 - Fees and Compensation.
Other Third-Party Services
The Firm has entered into a service agreement with Pontera to provide asset management services for
accounts held away from our primary custodial affiliations. Through this, we are able to create a portfolio,
consisting of the securities/investment opportunities available depending on the type of held away
account being managed by our firm. The Pontera platform allows us to avoid being considered to have
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 their
platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. The
client’s individual investment strategy is tailored to their specific needs and may include some or all of the
securities made available. Portfolios will be designed to meet a particular investment goal, determined to
be suitable to the client’s circumstances.
Once the appropriate portfolio has been determined, portfolios
are continuously and regularly monitored, and if necessary, rebalanced.
401(k), Pension and Profit-Sharing
IWP provides fee only, fiduciary investment consulting services to Plan Trustees. IWP serves as an ERISA
Investment Fiduciary advisor to the Plan Trustee(s). IWP, as requested by the client, will assist the Client
with:
• Developing an investment policy statement; and
• IWP assumes the responsibility of:
o Providing professionally selected investment alternatives and risk- based model portfolio
alternatives;
o Ongoing active portfolio management includes monitoring, rebalancing;
o and adjustments to model portfolios;
o Ongoing manager due diligence;
o Investment model and manager customization; and/or
o Recommending custodians that provide low cost open architecture investment
alternatives.
Use of Independent Managers
The Firm may select certain Independent Managers to actively manage a portion of its clients’ assets. The
specific terms and conditions under which a client engages an Independent Manager may be set forth in
a separate written agreement with the designated Independent Managers engaged to manage their
assets.
The Firm evaluates a variety of information about Independent Managers, which may include the
Independent Manager’s public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Manager’s investment strategies, past performance, and risk results in relation
to its clients ’individual portfolio allocations and risk exposure. The Firm also takes into consideration each
Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
The Independent Manager(s) shall have day-to-day responsibility for the active discretionary
management of the allocated assets. IWP shall continue to render investment supervisory services to the
client relative to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. The Firm continues to provide services relative to the discretionary selection of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. The Firm seeks to ensure the Independent Managers strategies and
target allocations remain aligned with its clients ’investment objectives and overall best interests. IWP
may terminate a relationship with Independent Manager(s) at its discretion.
ERISA Plan and 401(k) Individual Engagements
Trustee Directed Plans: IWP may be engaged to provide discretionary investment advisory services to
ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment
objective designated by the Plan trustees. In such engagements, IWP will serve as an investment fiduciary
as that term is defined under the Employee Retirement Income Security Act of 1974 (“ERISA”). IWP will
generally provide services on an “assets under management” fee basis per the terms and conditions of an
Investment Advisory Agreement between the Plan and the Firm.
Participant Directed Retirement Plans: As indicated above, IWP may also provide investment advisory
and consulting services to participant directed retirement plans per the terms and conditions of a
Retirement Plan Services Agreement between IWP and the plan. For such engagements, IWP shall assist
the plan sponsor with the selection of an investment platform from which plan participants shall make
their respective investment choices (which may include investment strategies devised and managed by
IWP), and, to the extent engaged to do so, may also provide corresponding education to assist the
participants with their decision-making process.
Client Retirement Plan Assets: If requested to do so, IWP shall provide investment advisory services
relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established
by the client’s employer. In such event, IWP shall allocate (or recommend that the client allocate) the
retirement plan assets among the investment options available on the 401(k) platform. IWP’s ability shall
be limited to the allocation of the assets among the investment alternatives available through the plan.
IWP will not receive any communications from the plan sponsor or custodian, and it shall remain the
client’s exclusive obligation to notify IWP of any changes in investment alternatives, restrictions, etc.,
pertaining to the retirement account. Unless expressly indicated by the client to IWP to the contrary, in
writing, the client’s 401(k) plan assets shall be included in assets under management for purposes of IWP
calculating its advisory fee.
Asset Management
Assets are invested primarily in equity securities, fixed income securities, certificates of deposit, municipal
bonds, variable annuities, commercial paper, exchange traded funds (“ETFs” and no-load mutual funds
usually through custodial arrangements with institutional or discount brokers. Fund companies charge
each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount
brokerages may charge a transaction fee for the purchase or sale of some securities.
IWP has a fiduciary duty to provide services consistent with the client’s best interest. IWP will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon various factors,
including, but not limited to, investment performance, market conditions, fund manager tenure, style
drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon
these factors, there may be extended periods of time when IWP determines that changes to a client’s
portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below
during periods of inactivity.
Initial public offerings (IPOs) are generally not available through IWP.
Use of Mutual and Exchange Traded Funds
Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective
client can obtain many of the funds that may be utilized by IWP independent of engaging IWP as an
investment advisor. However, if a prospective client determines to do so, he/she will not receive IWP’s
initial and ongoing investment advisory services.
In addition to IWP’s investment advisory fee described previously, and transaction and/or custodial fees
discussed previously, clients will also incur, relative to all mutual fund and exchange traded fund purchases,
charges imposed at the fund level (e.g., management fees and other fund expenses).
IWP may utilize mutual funds and/or exchange traded funds that provide for limited liquidity, generally
on a quarterly basis. Thus, if we determined that the fund was no longer performing or if you ever
determined to transfer your account, the Fund could not be sold or transferred immediately. Rather, sale
or transfer would need to await the quarterly permitted sale date, or longer. Moreover, the eventual net
asset value for the Fund could be substantially different (positive or negative) than the Fund value on the
date that the sale was requested. There can be no assurance that any such strategy will prove profitable
or successful. Considering these enhanced risks/rewards, a client may direct IWP, in writing, not to employ
any or all such strategies for the client’s account.
Cash Positions
IWP continues to treat cash as an asset class. As such, unless determined to the contrary by IWP, all cash
positions (money markets, etc.) shall continue to be included as part of assets under management for
purposes of calculating IWP’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), IWP may maintain cash positions for defensive purposes. In addition, while
assets are maintained in cash, such amounts could miss market advances. Depending on current yields, at
any point in time, IWP’s advisory fee could exceed the interest paid by the client’s money market fund.
Structured Notes
IWP may purchase structured notes for client accounts. A structured note is a financial instrument that
combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a
note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of
an underlying asset or assets (such as the S&P 500 Index or commodities). It is the latter feature that
makes structured products unique, as the payout can be used to provide some degree of principal
protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a
specific market or economic view. In addition, investors may receive long-term capital gains tax treatment
if certain underlying conditions are met, and the note is held for more than one year. Finally, structured
notes may also have liquidity constraints, such that the sale thereof prior to maturity may be limited. In
the event that a client has any questions regarding the purchase of structured notes for his/her/its
account, IWP’s Wealth Managers and Advisors, remain available to address them. In addition, in the event
a client does not want IWP to purchase structured notes for his/her/its account, the client should advise
IWP, in writing.
Interval Funds / Illiquid Investments
Where appropriate, IWP will use investment vehicles that have limited liquidity. Some investments,
known as interval funds, may only offer opportunities to buy and/or sell on a periodic basis. Additionally,
an investor may not be able to sell all or as much as they would like at any given point in time.
An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a
percentage of outstanding shares from shareholders.
Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on
withdrawals. During any periods outside of the specified repurchase offer window(s), investors will be
unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender
shares when or in the amount desired. There can also be situations where an interval fund has a limited
amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition,
the eventual sale price for the interval fund could be less than the interval fund value on the date that the
sale was requested. While an interval fund periodically offers to repurchase a portion of its securities,
there is no guarantee that investors may sell their shares at any given time or in the desired amount. As
interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be
an illiquid investment. Typically, interval funds are not listed on any securities exchange and are not
publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of
investments involve certain additional risk, these funds will only be utilized when consistent with a client’s
investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment
should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of
some, or all, of the investment. There can be no assurance that an interval fund investment will prove
profitable or successful. In light of these enhanced risks, a client may direct IWP, in writing, not to employ
any or all such strategies for the client’s account.
Retirement Account Rollovers
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending on the client’s age, result in adverse tax consequences). If IWP
recommends that a client roll over their retirement plan assets into an account to be managed by IWP,
such a recommendation creates a conflict of interest if IWP will earn new (or increase its current)
compensation as a result of the rollover. If IWP provides a recommendation as to whether a client should
engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), IWP is acting as a
fiduciary 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. No client is under any
obligation to rollover retirement plan assets to an account managed by IWP, whether it is from an
employer’s plan or an existing IRA.