General Information Infinity Wealth Counsel, LLC ("IWC") was formed in 2014 and provides financial planning, investment management and retirement plan advisory services to its clients.
Christopher Oberholzer ("Chris") is the sole owner of IWC. Please see Brochure Supplement, Exhibit A, for more information on Mr. Oberholzer.
As of February 20, 2024, IWC managed $120,662,000 in client assets on a discretionary basis and $2,130,000 on a non-discretionary basis. IWC does not participate in or offer any wrap programs.
SERVICES OFFERED At the outset of each client relationship, IWC spends time with the client, asking questions, discussing the client's investment experience and financial circumstances, and broadly identifying major goals of the client.
Clients may elect to retain IWC to prepare a full financial plan. This written report is presented to the client for consideration. In most cases, clients subsequently retain IWC to manage the investment portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need financial planning but retain IWC for investment management services, based on all the information initially gathered, IWC generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the client's risk tolerance level (the "Financial Profile" or "Profile");
•the client's investment objectives and guidelines (the "Investment Plan" or "Plan"). The Financial Profile is a reflection of the client's current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments IWC will make on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents.
Financial Planning One of the services offered by IWC is financial planning, described below. This service may be provided as a stand-alone service or can be coupled with ongoing investment management.
Financial planning includes advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client's particular situation, financial planning includes some or all of the following: Gathering factual information concerning:
•Client's personal and financial situation;
•Assisting the client in establishing financial goals and objectives;
•Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
•Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; 4
•Making recommendations to help achieve retirement plan goals and objectives;
•Designing an investment portfolio to help meet the goals and objectives of the client;
•Providing estate planning strategies;
•Assessing risk and reviewing basic health, life and disability insurance needs;
•Providing tax planning strategies;
•Asset protection planning;
•Charitable planning; or
•Reviewing goals and objectives and measuring progress toward these goals. Please note that a conflict exists between the interests of IWC and the interests of the client. Once financial planning advice is given, the client may choose to have IWC implement the client's financial plan and manage the investment portfolio on an ongoing basis. IWC and its Advisory Representative will receive compensation for investment management services. IWC attempts to mitigate any conflict of interest by providing you with these disclosures. The client is under no obligation to act upon any of the recommendations made by IWC under a financial planning engagement and/or engage the services of any recommended professional.
Investment Management As described above, at the beginning of a client relationship, IWC meets with the client, gathers information, and performs research and analysis as necessary to develop the client's Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by IWC based on information provided by the client regarding changes in the client's financial circumstances.
To implement the client's Investment Plan, IWC will manage the client's investment portfolio on a discretionary basis. As a discretionary investment adviser, IWC will have the authority to supervise and direct trades in the portfolio as agreed but without specific consultation with the client.
Notwithstanding the foregoing, clients can impose certain written restrictions on IWC in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of IWC. Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflict with the advice we give to other clients regarding the same security or investment.
Third Party Advisors (Closed to New Clients) From time to time, IWC recommends the use of a Third Party Advisor. In such cases IWC will typically gather information from clients about the client's financial situation, investment objectives, and reasonable restrictions clients want imposed on the management of the account. IWC does not review specific securities purchased by the Third Party Advisor, on a trade by-trade basis. IWC will periodically review reports provided to the clients by the Third Party Advisor. IWC will contact the client periodically, as agreed to with the client, to review the client's financial situation and objectives; communicate information to the Third Party Advisor managing the account as warranted; 5 and assist the client in understanding and evaluating the services provided by the Third Party Advisor. Clients will be expected to notify IWC of any changes in their financial situation, investment objectives, or account restrictions. Clients can also contact directly the Third Party Advisor managing the account.
A complete description of the programs and services

available through the Third Party Advisor will be provided to the client upon receipt and review of the applicable Third Party Advisor's Form ADV Part 2A and 2B and/or equivalent brochures, investment advisory contracts, and account opening documents. IWC ensures that any investment advisers that the firm selects or recommends to clients are properly licensed or exempt from registration.
Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. IWC will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services are offered individually or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 ("ERISA") sets forth rules under which Plan Fiduciaries retain investment advisers for various types of services with respect to Plan assets. For certain services, IWC will be considered a fiduciary under ERISA. For example, IWC will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain IWC to act as an investment manager within the meaning of ERISA § 3(38), IWC will provide discretionary investment management services to the Plan. With respect to any account for which IWC meets the definition of a fiduciary under Department Of Labor rules, IWC acknowledges that both IWC and its Related Persons are acting as fiduciaries. Additional disclosures are found elsewhere in this Brochure or in the written agreement between IWC and Client.
Fiduciary Consulting Services
•Investment Selection Services: IWC will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
•Non-Discretionary Investment Advice: IWC provides Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
•Investment Monitoring: IWC will assist in monitoring the plan's investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and IWC will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Fiduciary Management Services
•Discretionary Management Services: When retained as an investment manager within the meaning of ERISA § 3(38), IWC provides continuous and ongoing supervision over the designated retirement plan assets. IWC will actively monitor the designated retirement plan 6 assets and provide ongoing management of the assets. When applicable, IWC will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
•Investment Management via Model Portfolios: IWC will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual fund options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services
•Participant Education: IWC will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages IWC for such services. Plan Participants are responsible for implementing transactions in their own accounts.
•Participant Enrollment: IWC will assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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 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 a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
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