Item 5 Additional Compensation
Item 6 Supervision
Item 7 Requirements for State-Registered Advisers
Charles A. Willhoit founded IWP Wealth Management (“IWP” or “we”) in late 2004, and he remains the primary
shareholder. All our principals own equity in the firm. We provide a very broad range of advisory services, which
we describe below in detail. We do not participate in any “wrap fee programs.”
We manage $217,825,018 of client assets on a discretionary basis and $3,357,999,083 of assets on a non-
discretionary basis. These amounts are based on assets as of December 31, 2023 as calculated during our most
recent routine audit. These amounts include all client assets for which we provide continuous and regular
supervisory or management services. We take a holistic approach to providing true family office services, including
work with clients’ liquid and illiquid assets, trusts, and businesses.
FAMILY OFFICE AND WEALTH MANAGEMENT SERVICES
IWP provides family office and wealth management services primarily to high net worth individuals, families, and
their small businesses (each, a “Family Client”).
IWP provides our Family Clients with a broad range of investment and cash flow management services,
comprehensive estate and financial planning, and consulting services including non-investment related matters.
IWP’s Family Clients sign Wealth Management Agreements and Investment Advisory Agreements that explain the
terms and conditions of the engagement, describe the scope of the services to be provided, and the portion of the fee,
if any, that is due from the Family Client. We tailor our services specifically to the individual needs of our Family
Clients. Our Family Clients can impose restrictions on what individual securities or types of securities we can invest
in on their behalf.
It is the Family Client’s responsibility to let us know if there is a change in their financial situation or investment
objectives so that we can adjust our recommendations as may be necessary.
INVESTMENT MANAGEMENT & FAMILY OFFICE SERVICES
Family Clients may engage IWP to design an investment portfolio, provide ongoing corresponding investment
management services, and provide family office related services such as account reporting and consolidation,
document storage, bill pay, and estate and tax related coordination services. Unless the Family Client directs
otherwise, IWP typically recommends that investment management accounts be maintained at Fidelity Family
Office Services (“FFOS”), an unaffiliated service provider. IWP considers factors like financial strength, reputation,
execution, pricing, reporting, and retail banking services when recommending FFOS (or any other broker-
dealer/custodian) to Family Clients. In addition to IWP’s formal Wealth Management and Investment Advisory
Agreements, Family Clients are required to execute separate custodial/clearing agreements with a custodian of the
Family Client’s choosing. IWP's Wealth Management and Investment Advisory Agreements and the
custodial/clearing agreements may authorize the account custodian to debit the Family Client’s account for the
amount of IWP's investment advisory fee and to directly remit that management fee to IWP.
IWP generally advises Family Clients to be diversified across multiple asset classes (stocks, bonds, commodities,
cash, etc.) and generally uses a variety of securities and investment vehicles to achieve this. Examples are exchange
traded funds (ETFs), mutual funds, individual equities, options, fixed income securities, and private investments.
Family Clients are responsible for fees such as those charged by mutual funds or trading costs charged by
custodians. These fees are in addition to IWP’s ongoing investment advisory fee.
IWP may also recommend
the active, discretionary management of a portion of certain Family Client assets by
independent investment managers selected by IWP (“Independent Managers”). These recommendations are based
on a Family Client’s stated investment objectives. IWP will continue to provide advisory services to the Family
Client including asset allocation, performance monitoring and continuous evaluation of whether the portfolio is
consistent with the Family Client’s investment objectives.
In addition to the Family Client’s stated investment objectives, IWP considers factors like the Independent
Manager’s investment management style, past performance, reputation, financial strength, reporting, pricing, and
research. The investment management fees charged by the Independent Managers, in addition to the fees (if any)
charged by the custodian/broker-dealer of the Family Client’s assets, are exclusive of, and in addition to, IWP’s
ongoing investment advisory fee.
IWP does not benefit from any commissions charged to Family Clients by custodians or broker/dealers and does not
share asset-based distribution or service fees (such as Rule 12b-1 fees) with any outside manager. We seek to find
the highest quality, lowest cost transaction services available for our Family Clients. A significant factor in
recommending FFOS as custodian is that in most cases, IWP is able to obtain very competitive pricing for all
publicly traded securities transactions.
IWP will provide each Family Client with a copy of its Form ADV Part 2 written disclosure statement before or at
the same time as the execution of the Wealth Management and Investment Advisory Agreements.
IWP may also provide investment advice to Family Clients concerning investing in limited liability companies,
limited partnerships, general partnerships, real estate, hedge funds, and other types of non-publicly traded
investments, including the Evolution Fund, funds managed by Evolution Private Investment Collective LLC
(“EPIC”), and other Funds managed by IWP, as well as other legitimate business investment opportunities owned by
the Family Client at the commencement of the advisory relationship or thereafter. Three of IWP’s principals are co-
founders of EPIC and four of IWP’s principals have equity ownership in EPIC.
All individuals that give investment advice on behalf of IWP must have earned a college degree and have
substantive investment-related experience. In addition, all such individuals shall have attained all required
investment-related licenses and/or designations.
Family Clients that choose to use IWP for bill pay services sign a Financial Accounts Agreement that outlines the
services being rendered, details of how the services will be performed, and any limits of liability for IWP.
POOLED INVESTMENT VEHICLE SERVICES
IWP also serves as the investment adviser to multiple pooled investment vehicles (the “Funds” or “Fund Clients”).
IWP has discretionary authority over the investments made by the Funds. IWP tailors its investment advice to the
Funds based on each Fund’s investment objectives. The Funds make direct investments in real estate, securities, and
other assets, as well as investments in other pooled asset vehicles. Certain Funds are organized to make a single,
identified investment, while other Funds are organized under a “blind pool” model, where IWP has discretion to
identify and acquire investments for the Fund after its capital has been raised.
INVESTMENT ADVISORY SERVICES
IWP also provides investment advisory services to clients (each an “Investment Advisory Client”) who do not
receive family office services. Like Family Clients, each Investment Advisory Client enters into an Investment
Advisory Agreement with IWP, and IWP provides each client with a copy of its Form ADV Part 2 written firm
brochure.