Innovative Wealth Building LLC

Innovative Wealth Building LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Innovative Wealth Building LLC. If you have any questions about the contents of this brochure, please contact us at 240-237-8086 or by email at: tp@teamiwb.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Innovative Wealth Building LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Innovative Wealth Building LLC’s CRD number is: 314942. 23567 Oak View Drive, Suite A California, MD 20619 240-237-8086 tp@teamiwb.com wwww.innovativewealthbuilding.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 03/12/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Innovative Wealth Building LLC on 02/28/2025 are described below. Material changes relate to Innovative Wealth Building LLC’s policies, practices or conflicts of interests. • IWB has updated its principal owners. (Item 4) • For certain clients, IWB will recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. (Item 8) • For certain clients, IWB will recommend options trading, which involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital (Item 8). • IWB Insurance Services, LLC (“IWB Insurance”) is an insurance agency affiliated with IWB. The recommendation that clients purchase an insurance product through IWB Insurance presents a conflict of interest, as the receipt of commissions provide an incentive to recommend insurance products based on commissions to be received, rather than on a client’s particular need. (Item 10) • IWB uses Advisors Excel, an insurance marketing organization, to help select insurance companies and products that fit a client’s situation and to provide various support services to IWB, some of which do not benefit existing clients. The firm and its representatives can receive commissions, incentive compensation, bonus payments, and trips from Advisors Excel and insurance companies for reaching certain sales levels, which creates conflicts of interest. (Item 10) • Certain IWB representatives compensate SmartAsset as a lead generator for advisory referrals. (Item 14) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................6 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................6 Item 9: Disciplinary Information .........................................................................................................................10 Item 10: Other Financial Industry Activities and Affiliations .........................................................................10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............12 Item 12: Brokerage Practices ................................................................................................................................13 Item 13: Review of Accounts ................................................................................................................................13 Item 14: Client Referrals and Other Compensation ..........................................................................................14 Item 15: Custody ....................................................................................................................................................15 Item 16: Investment Discretion ............................................................................................................................16 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................16 Item 18: Financial Information .............................................................................................................................16 iii  Item 4: Advisory Business A. Description of the Advisory Firm Innovative Wealth Building LLC (hereinafter “IWB”) is a Limited Liability Company organized in the State of Maryland. The firm was formed in March 2021, and the principal owners are Terry Everett Parham, Jennifer Hill and Warren Brooks. B. Types of Advisory Services Portfolio Management Services IWB offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IWB creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring IWB evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented for each client family. IWB seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of IWB’s economic, investment or other financial interests. To meet its fiduciary obligations, IWB attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, IWB’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 IWB’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. Financial Planning & Consulting Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Financial consulting services may include, but are not limited to: investment consulting; insurance consulting; tax consulting; retirement consulting; education consulting; and debt/credit consulting. 2  Services Limited to Specific Types of Investments IWB generally limits its investment advice to fixed income securities, insurance products including annuities, equities and ETFs (including ETFs in the gold and precious metal sectors). IWB may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions IWB will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IWB on behalf of the client. IWB may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent IWB from properly servicing the client account, or if the restrictions would require IWB to deviate from its standard suite of services, IWB reserves the right to end the relationship. D. Wrap Fee Programs IWB acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes IWB’s non-wrap fee advisory services; clients utilizing IWB’s wrap fee portfolio management should see IWB’s separate Wrap Fee Program Brochure. IWB manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. IWB receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management IWB has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $650,026,264.00 $7,186,172.00 December 2025 3  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fee $0 - $1,000,000.00 0.90% $1,000,000.01 - $2,000,000.00 0.85% $2,000,000.01 - $3,000,000.00 0.80% $3,000,000.01 - $4,000,000.00 0.75% $4,000,000.01 - $5,000,000.00 0.70% $5,000,000.01 - $10,000,000.00 0.60% $10,000,000.01 AND UP 0.50% The advisory fee is calculated using the value of the assets in the Account based on a billing period ending on the 23rd of each month. The fees are negotiable. The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the Investment Advisory Contract immediately upon written notice. Financial Planning & Consulting Fees Fixed & Hourly Fees The fixed rate for financial planning and consulting services is between $300 and $2,500. The hourly rate for financial planning and consulting services is between $50 and $500. The fees are negotiable and the final fee schedule will be disclosed in the Financial Planning & Consulting Agreement. Clients may terminate the Financial Planning & Consulting Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis, based on a billing period ending on the 23rd of each month. Fees are paid in advance. 4  Payment of Financial Planning & Consulting Fees Financial planning & consulting fees are paid via ACH, check, or credit/ debit card. Fixed and hourly financial planning & consulting fees are paid 100% in advance, but never more than six months in advance. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by IWB. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees IWB collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. E. Outside Compensation For the Sale of Securities to Clients The investment adviser representatives of our firm are licensed, independent insurance agents (see Item 10 below). As such, they earn commission-based compensation for selling insurance products, including insurance products sold to clients. Insurance commissions earned by investment adviser representatives are separate and in addition to our advisory fees. This practice presents a conflict of interest as the investment adviser representatives has an incentive to recommend insurance products to a client for the purpose of generating commissions rather than solely based on the client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person associated with IWB. 5  Item 6: Performance-Based Fees and Side-By-Side Management IWB does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients IWB generally provides advisory services to the following types of clients: ❖ ❖ ❖ Individuals High-Net-Worth Individuals Charitable Organizations There is no account minimum for any of IWB’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis IWB’s methods of analysis include Fundamental analysis and Modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies IWB uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis 6  Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and 7  credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Cryptocurrency ETFs: For certain clients, IWB will recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. Crypto ETFs can track the value of cryptocurrencies by investing in futures 8  investing in digital currencies directly. contracts for digital currency, or by Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real assets or tangible securities and are more volatile than traditional currencies and financial assets. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. A cryptocurrency is a peer-to-peer, decentralized, cryptocurrency, the implementation of which relies on the principles of cryptography to validate the transactions and generation of the currency itself. A network (or utility) token relies on a network protocol with similar principles to a cryptocurrency, but also purports to serve functions other than the storage of value. The creation and use of cryptocurrency is not currently subject to a fully developed set of legal or regulatory requirements, and trading in crypto assets is subject to high levels of volatility and the potential for market abuse. Risks associated with Crypto ETFs include but are not limited to; the cost to own these ETFs may be more than owning the actual crypto (but may eliminate the risk of investors being hacked or losing passwords or private keys needed to access their investment when it is stored in a secure bitcoin wallet), the risk of the individual ETF fund company failure, (which would require liquidation of the fund and the costs associated with the failure of the company), risk of underlying assets being blocked by regulatory authorities, reinvestment risk, high transaction costs and limited historical data. Additionally, Crypto ETFs may have no earnings, dividends, or interest payments generated by underlying holdings. Operational and management costs may decrease the value of the ETF as a whole. Expense ratios should be considered and understood as presented in the ETF Prospectus. Due to the above risk factors along with other risk factors, we assess that the value at risk at any given time is always 100% downside, therefore, we must limit total exposure along with carefully considering the risks and needs of each individual investor. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term 9  goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither IWB nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither IWB nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 10  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests The investment adviser representatives of our firm are independent licensed insurance agents, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IWB always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IWB in connection with such individual's activities outside of IWB. IWB Insurance Services, LLC (“IWB Insurance”) is an insurance agency affiliated with IWB. In this capacity, IWB Insurance acts as a broker for term and permanent life insurance, fixed annuities, disability insurance, and long-term care insurance. This service is made available and offered to our clients by our IARs in their separate individual capacities as licensed insurance agents. The recommendation that clients purchase an insurance product through IWB Insurance presents a conflict of interest, as the receipt of commissions provide an incentive to recommend insurance products based on commissions to be received, rather than on a client’s particular need. No client is under any obligation to purchase any insurance product from IWB Insurance. Clients may purchase recommended insurance products through nonaffiliated insurance agents of their choice. IWB will utilize the services of Advisors Excel, a third-party insurance marketing organization ("IMO") to select appropriate products. IMOs offer special incentive compensation to meet certain overall sales goals by placing annuities and/or other insurance products through the IMO. The receipt of commissions and additional incentive compensation itself creates a conflict of interest. Clients are not required to purchase any insurance products through any representative’s separate capacity as insurance agents. The purpose of the IMO is to assist in finding the insurance company that best fits the client’s situation. Advisors Excel provides marketing assistance and business development tools to acquire new clients, technology with the goal of improving the client experience and IWB’s efficiency, back office and operations support to assist in the processing of insurance products (through Advisors Excel) for clients, business succession planning, business conferences and incentive trips for agents of IWB. Although some of these services can benefit a client, other services obtained by us from Advisors Excel such as marketing assistance, business development and incentive trips will not benefit an existing client. IWB can also receive bonus payments from an insurance company for selling a targeted number of annuities during a specified period of time which creates a conflict of interest. IWB has taken steps to manage these conflicts of interest by requiring that each investment advisor representative only recommend insurance and annuities when in the best interest of the client and without regard to the financial interest of IWB and its investment advisor 11  representative and disclose material conflicts of interest related to insurance or annuity recommendations. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections IWB does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics IWB has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. IWB's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests IWB does not recommend that clients buy or sell any security in which a related person to IWB or IWB has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of IWB may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of IWB to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. IWB will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities 12  From time to time, representatives of IWB may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of IWB to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, IWB will never engage in trading that operates to the client’s disadvantage if representatives of IWB buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on IWB’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and IWB may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in IWB's research efforts. IWB will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. IWB will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. IWB does not receive products or services other than execution (“soft dollar benefits”) from a broker-dealer or third-party for generating commissions. B. Aggregating (Block) Trading for Multiple Client Accounts IWB does not aggregate or bunch the securities to be purchased or sold for multiple clients, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for IWB's advisory services provided on an ongoing basis are reviewed at least annually by the investment advisor representative assigned to the account, with regard to clients’ respective investment policies and risk tolerance levels. 13  All financial planning accounts are reviewed upon financial plan creation and plan delivery by the investment advisor representative assigned to the account. Financial planning clients are provided with a financial plan and will typically receive assistance after plan delivery. At the conclusion of the financial planning period, a client can request to continue working together for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of IWB's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) IWB does not receive any economic benefit, directly or indirectly from any third party for advice rendered to IWB's clients. With respect to Schwab, IWB receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For IWB client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. 14  Schwab also makes available to IWB other products and services that benefit IWB but may not benefit its clients’ accounts. These benefits may include national, regional or IWB specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of IWB by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist IWB in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of IWB’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of IWB’s accounts. Schwab Advisor Services also makes available to IWB other services intended to help IWB manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to IWB by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to IWB. IWB is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals IWB has an agreement with a promoter to provide referrals to our firm. This is considered a paid endorsement. IWB will pay the promoter for referrals to our firm in accordance with the agreement between the parties. The payment of referral fees with not affect the client’s fees paid to IWB. Certain IWB representatives compensate SmartAsset as a lead generator for advisory referrals. The IWB representative provides data to SmartAsset that matches certain clients with the services of IWB. Compensation will be paid by IWB’s representatives for referrals, and the fee for referrals will be properly disclosed to any potential clients of IWB in accordance with the Promoter Agreement entered into between the parties. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, IWB will be deemed to have limited custody of client's assets and must have written authorization from the 15  client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because IWB has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, IWB will follow the safeguards specified by the SEC rather than undergo an annual audit. Item 16: Investment Discretion IWB can provide discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, IWB generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, IWB’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to IWB. Item 17: Voting Client Securities (Proxy Voting) IWB will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet IWB neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither IWB nor its management has any financial condition that is likely to reasonably impair IWB’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years IWB has not been the subject of a bankruptcy petition in the last ten years. 16 

Innovative Wealth Building LLC Wrap Fee Program Brochure This wrap fee program brochure provides information about the qualifications and business practices of Innovative Wealth Building LLC. If you have any questions about the contents of this brochure, please contact us at 240-237-8086 or by email at: TP@teamiwb.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Innovative Wealth Building LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Innovative Wealth Building LLC’s CRD number is: 314942. 23567 Oak View Drive, Suite A California, MD 20619 (240) 237-8086 TP@teamiwb.com wwww.innovativewealthbuilding.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 03/12/2026 1  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure on 02/28/2025. Material changes relate to Innovative Wealth Building LLC’s policies, practices or conflicts of interests. • For certain clients, IWB will recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. (Item 6) • For certain clients, IWB will recommend options trading, which involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital (Item 6). • IWB Insurance Services, LLC (“IWB Insurance”) is an insurance agency affiliated with IWB. The recommendation that clients purchase an insurance product through IWB Insurance presents a conflict of interest, as the receipt of commissions provide an incentive to recommend insurance products based on commissions to be received, rather than on a client’s particular need. (Item 9) • IWB uses Advisors Excel, an insurance marketing organization, to help select insurance companies and products that fit a client’s situation and to provide various support services to IWB, some of which do not benefit existing clients. The firm and its representatives can receive commissions, incentive compensation, bonus payments, and trips from Advisors Excel and insurance companies for reaching certain sales levels, which creates conflicts of interest. (Item 9) • Certain IWB representatives compensate SmartAsset as a lead generator for advisory referrals. (Item 9) 2  Item 3: Table of Contents Item 1: Cover Page General ............................................................................................................................................. 1 Item 2: Material Changes .......................................................................................................................... 2 Item 3: Table of Contents .......................................................................................................................... 3 Item 4: Advisory Business......................................................................................................................... 4 Item 5: Types of Clients ............................................................................................................................. 6 Item 6: Portfolio Manager Selection and Evaluation ............................................................................. 6 Item 7: Client Information Provided to Portfolio Managers .............................................................. 12 Item 8: Client Contact with Portfolio Managers .................................................................................. 12 Item 9: Additional Information .............................................................................................................. 12 3  Item 4: Advisory Business A. Description of the Advisory Firm Innovative Wealth Building LLC (hereinafter “IWB”) provides portfolio management to clients under this wrap fee program as sponsor and portfolio manager. Total Assets Under Management Annual Fee $0 - $1,000,000.00 0.90% $1,000,000.01 - $2,000,000.00 0.85% $2,000,000.01 - $3,000,000.00 0.80% $3,000,000.01 - $4,000,000.00 0.75% $4,000,000.01 - $5,000,000.00 0.70% $5,000,000.01 - $10,000,000.00 0.60% $10,000,000.01 AND UP 0.50% These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization on a monthly basis, based on a billing period ending on the 23rd of each month. Fees are paid in advance. The advisory fee is calculated using the value of the on the 23rd of each month. Upon termination, for any unearned asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (The daily rate is calculated by dividing the annual fee percentage by 365.) Clients may terminate the Investment Advisory Contract immediately upon written notice. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). 4  C. Additional Fees IWB will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. IWB will charge clients one fee, and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that IWB has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. In a wrap program account, IWB has an incentive to limit trading and/or to favor assets types that do not have a transaction fee such as U.S. equities, ETFs, and no transaction fee (NTF) mutual funds over other asset types because IWB would otherwise pay the transaction fee to the broker-dealer executing the transaction in the client account. By selecting an asset that does not have a transaction fee, IWB retains a greater portion of the advisory fee and increases its compensation. In addition, mutual fund companies may compensate the broker-dealer to be included in the broker-dealer’s NTF program. In some cases, an NTF fund may be more expensive in the long run than a fund with a transaction fee because the NTF fund has a higher internal expense ratio which is paid annually by fund shareholders. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. As IWB absorbs certain transaction costs in wrap fee accounts, IWB may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. D. Compensation of Client Participation Neither IWB, nor any representatives of IWB receive any additional compensation beyond advisory fees for the participation of clients in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, IWB may have 5  a financial incentive to recommend the wrap fee program to clients. Item 5: Types of Clients IWB generally offers advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals There is no account minimum. Item 6: Portfolio Manager Selection and Evaluation A. Selecting/Reviewing Portfolio Managers IWB will not select outside portfolio managers for management of this wrap fee program. IWB will be the sole portfolio manager for this wrap fee program. IWB will use industry standards to calculate portfolio manager performance. IWB reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is monthly and is reviewed by IWB. B. Related Persons IWB and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses IWB’s management of the wrap fee program. However, IWB addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. C. Advisory Business IWB offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IWB 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: • • • Determine investment strategy Asset allocation Assessment of risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring 6  IWB evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. IWB 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. Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. IWB will charge clients one fee, and pay transaction fees using the advisory fee collected from the client. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that IWB has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. To address this conflict, IWB will always act in the best interest of its clients consistent with its fiduciary duty as an investment adviser. Services Limited to Specific Types of Investments IWB generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs, ETFs in the gold and precious metal sectors, REITs, and insurance products including annuities. IWB may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions IWB will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IWB on behalf of the client. IWB may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients are not permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Wrap Fee Programs As discussed herein, IWB sponsors and acts as portfolio manager for this wrap fee program. IWB manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts The fees paid to the wrap account program will be given to IWB as a management fee. 7  Amounts Under Management IWB has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $650,026,264.00 $7,186,172.00 December 2025 Performance-Based Fees and Side-By-Side Management IWB does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. Methods of Analysis and Investment Strategies Methods of Analysis IWB’s methods of analysis include fundamental analysis and fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various assets. Investment Strategies IWB uses/recommends long term investing. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. 8  Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the 9  possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Cryptocurrency ETFs: For certain clients, IWB will recommend ETFs that track the price performance of one or more cryptocurrencies by investing in a portfolio linked to their instruments. Crypto ETFs can track the value of cryptocurrencies by investing in futures contracts for digital currency, or by investing in digital currencies directly. Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real assets or tangible securities and are more volatile than traditional currencies and financial assets. In general, investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and subject to numerous risks. A cryptocurrency is a peer-to-peer, decentralized, cryptocurrency, the implementation of which relies on the principles of cryptography to validate the transactions and generation of the currency itself. A network (or utility) token relies on a network 10  protocol with similar principles to a cryptocurrency, but also purports to serve functions other than the storage of value. The creation and use of cryptocurrency is not currently subject to a fully developed set of legal or regulatory requirements, and trading in crypto assets is subject to high levels of volatility and the potential for market abuse. Risks associated with Crypto ETFs include but are not limited to; the cost to own these ETFs may be more than owning the actual crypto (but may eliminate the risk of investors being hacked or losing passwords or private keys needed to access their investment when it is stored in a secure bitcoin wallet), the risk of the individual ETF fund company failure, (which would require liquidation of the fund and the costs associated with the failure of the company), risk of underlying assets being blocked by regulatory authorities, reinvestment risk, high transaction costs and limited historical data. Additionally, Crypto ETFs may have no earnings, dividends, or interest payments generated by underlying holdings. Operational and management costs may decrease the value of the ETF as a whole. Expense ratios should be considered and understood as presented in the ETF Prospectus. Due to the above risk factors along with other risk factors, we assess that the value at risk at any given time is always 100% downside, therefore, we must limit total exposure along with carefully considering the risks and needs of each individual investor. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are retirement products for those who may have the ability to pay a premium now and want to guarantee they receive certain payments or a return on investment in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long- range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 11  Voting Client Securities (Proxy Voting) IWB will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 7: Client Information Provided to Portfolio Managers All client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. Item 8: Client Contact with Portfolio Managers IWB does not restrict clients from contacting portfolio managers. IWB’s representatives can be contacted during regular business hours using the information on the Form ADV Part 2B cover page. Item 9: Additional Information A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative Neither IWB nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Registration as a Futures Commission Merchant, Commodity Pool 12  Operator, or a Commodity Trading Advisor Neither IWB nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests The investment adviser representatives of our firm are independent licensed insurance agents, and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. IWB always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of IWB in connection with such individual's activities outside of IWB. IWB Insurance Services, LLC (“IWB Insurance”) is an insurance agency affiliated with IWB. In this capacity, IWB Insurance acts as a broker for term and permanent life insurance, fixed annuities, disability insurance, and long-term care insurance. This service is made available and offered to our clients by our IARs in their separate individual capacities as licensed insurance agents. The recommendation that clients purchase an insurance product through IWB Insurance presents a conflict of interest, as the receipt of commissions provide an incentive to recommend insurance products based on commissions to be received, rather than on a client’s particular need. No client is under any obligation to purchase any insurance product from IWB Insurance. Clients may purchase recommended insurance products through nonaffiliated insurance agents of their choice. IWB will utilize the services of Advisors Excel, a third-party insurance marketing organization ("IMO") to select appropriate products. IMOs offer special incentive compensation to meet certain overall sales goals by placing annuities and/or other insurance products through the IMO. The receipt of commissions and additional incentive compensation itself creates a conflict of interest. Clients are not required to purchase any insurance products through any representative’s separate capacity as insurance agents. The purpose of the IMO is to assist in finding the insurance company that best fits the client’s situation. Advisors Excel provides marketing assistance and business development tools to acquire new clients, technology with the goal of improving the client experience and IWB’s efficiency, back office and operations support to assist in the processing of insurance products (through Advisors Excel) for clients, business succession planning, business conferences and incentive trips for agents of IWB. Although some of these services can benefit a client, other services obtained by us from Advisors Excel such as marketing assistance, business development and incentive trips will not benefit an existing client. IWB can also receive bonus payments from an insurance company for selling a targeted number of annuities during a specified period of time which creates a conflict of interest. IWB has 13  taken steps to manage these conflicts of interest by requiring that each investment advisor representative only recommend insurance and annuities when in the best interest of the client and without regard to the financial interest of IWB and its investment advisor representative and disclose material conflicts of interest related to insurance or annuity recommendations. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections IWB does not utilize nor select third-party investment advisers. B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics IWB has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. IWB’s Code of Ethics is available free upon request to any client or prospective client. Recommendations Involving Material Financial Interests IWB does not recommend that clients buy or sell any security in which IWB or a related person has a material financial interest. Investing Personal Money in the Same Securities as Clients From time to time, representatives of IWB may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of IWB to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. IWB will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of IWB may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of IWB to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such 14  transactions may create a conflict of interest; however, IWB will never engage in trading that operates to the client’s disadvantage if representatives of IWB buy or sell securities at or around the same time as clients. Frequency and Nature of Periodic Reviews Accounts are reviewed at least annually by the investment advisor representative assigned to the account, with regard to clients’ respective investment policies and risk tolerance levels. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Content and Frequency of Regular Reports Provided to Clients Each client will receive a quarterly account statement from the custodian. Economic Benefits Provided by Third Parties for Advice Rendered to Clients With respect to Schwab, IWB receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For IWB client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to IWB other products and services that benefit IWB but may not benefit its clients’ accounts. These benefits may include national, regional or IWB specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of IWB by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist IWB in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide 15  research, pricing information and other market data, facilitate payment of IWB’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of IWB’s accounts. Schwab Advisor Services also makes available to IWB other services intended to help IWB manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to IWB by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to IWB. IWB is independently owned and operated and not affiliated with Schwab. Compensation to Non – Advisory Personnel for Client Referrals IWB has an agreement with a promoter to provide referrals to our firm. This is considered a paid endorsement. IWB will pay the promoter for referrals to our firm in accordance with the agreement between the parties. The payment of referral fees with not affect the client’s fees paid to IWB. Certain IWB representatives compensate SmartAsset as a lead generator for advisory referrals. The IWB representative provides data to SmartAsset that matches certain clients with the services of IWB. Compensation will be paid by IWB’s representatives for referrals, and the fee for referrals will be properly disclosed to any potential clients of IWB in accordance with the Promoter Agreement entered into between the parties. Balance Sheet IWB neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients IWB does not have any financial condition that would impair its ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years IWB has not been the subject of a bankruptcy petition. 16