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.