A. Description of the Advisory Firm Driven Investments LLC (hereinafter “Driven”) is a Limited Liability Company organized in the State of Idaho. The firm was formed in June 2020, and the principal owners are Joshua Cole Weir, Christian Alexander Williams and The M&A Family Trust by Aaron Daniel Pugh, of which Aaron Daniel Pugh is one of the trustees.
B. Types of Advisory Services Portfolio Management Services Driven offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Driven creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels).
Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Driven evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Driven will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
In addition to brokerage accounts, Driven refers clients to an unaffiliated third-party insurance agency and/or broker dealer for possible consideration of a fee-based or other variable annuity.
Driven will manage the sub-accounts of certain fee-based variable annuities that their clients elect to invest in.
Driven seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Driven’s economic, investment or other financial interests. To meet its fiduciary obligations, Driven attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Driven’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time.
It is Driven’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time.
Selection of Other Advisers Driven directs some clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, Driven will always ensure those other advisers are properly licensed or registered as an investment adviser. Driven conducts due diligence on any third-party investment adviser, which can involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. Driven then makes investments with a third-party investment adviser by referring the client to the third party adviser. Driven will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Driven will review the ongoing investment performance of the third-party adviser to ensure suitability with the client’s investment objectives.
Financial Planning Financial plans and financial planning can include: investment planning; tax concerns; structured note research and planning; retirement planning; college planning; private investment research and planning; and debt/credit

planning.
Driven plans consist of questions for discovery, analysis and implementation/execution. Top areas of discussion are risk tolerance, cost, and time horizon. Working with the client to take into account short term, mid-term and long-term goals. Educating the client enough to make informed decisions together. This process begins with an initial client interview, followed by the signing of appropriate agreements outlining the scope of the Driven Investments services. Implementation then begins, and depending on the strategy, complexity of the investment vehicle, investments limitations, and costs, the timeframe is variable but will be outlined to the client. Driven Investment advisor fee is negotiated based on the amount of time a chosen strategy will require to implement. Another variance in service level is how often a client wants to meet, if there is travel associated with the meeting, potential future business the client may bring to the firm, and/or the complexity of investment strategy. If fees ever vary a new agreement will be signed outlining such changes.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you can act on our recommendations by placing securities transactions with any brokerage firm.
We offer project-based financial planning services and ongoing financial planning services.
Services Limited to Specific Types of Investments Driven generally limits its investment advice to mutual funds, fixed income securities, variable annuities, structured notes, equities and ETFs (including ETFs in the gold and precious metal sectors). Driven can use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions Driven offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Clients cannot impose restrictions with regards to third-party money managers and the selection of other advisors’ services.
D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Driven does not participate in any wrap fee programs nor does any third-party adviser use a wrap fee program.
E. Assets Under Management When calculating regulatory assets under management, an investment adviser must include the value of any advisory account over which it exercises continuous and regular advisory or management services. As of December 31 2023, we have $109,2828,771, with $103,662,934 in discretionary and $5,619,777 in non discretionary assets under management.