# 3(38) Investment Fiduciaries

> 3(38) Investment Fiduciaries is an SEC-registered investment advisory firm in Simi Valley, CA, registered since 2018, reporting $1 billion to $5 billion in regulatory assets under management in its Form ADV filing dated June 22, 2026.

- CRD: 298053
- Filed as: 3(38) INVESTMENT FIDUCIARIES
- Legal name: 3(38) Investment Fiduciaries Inc.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Simi Valley, CA
- Filing period: October 2026
- Form ADV filing dated: June 22, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/298053
- AdvisorCensus page: https://advisorcensus.com/firm/3-38-investment-fiduciaries-simi-valley-ca-298053

## Quick answers

**How is 3(38) Investment Fiduciaries compensated?**
On its Form ADV (Item 5.E, October 2026), 3(38) Investment Fiduciaries reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees).

**How much does 3(38) Investment Fiduciaries charge?**
Its Form ADV Part 2A brochure dated June 18, 2026 states: Asset-based fee: 0.02% to 0.5% a year (a range, as the brochure states it). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is 3(38) Investment Fiduciaries located?**
3(38) Investment Fiduciaries' principal office is in Simi Valley, CA, according to its Form ADV.

**Is 3(38) Investment Fiduciaries registered with the SEC or a state?**
3(38) Investment Fiduciaries is an SEC-registered investment advisory firm, registered since 2018. Status as filed: Approved. CRD 298053.

**How much does 3(38) Investment Fiduciaries manage?**
3(38) Investment Fiduciaries reports $1,035,072,002 in regulatory assets under management in its Form ADV filing dated June 22, 2026 (100% discretionary).

**How have 3(38) Investment Fiduciaries' assets and staff changed since 2021?**
In the Form ADV data for 3(38) Investment Fiduciaries: Regulatory assets under management: $842,588,293 in the October 2025 data and $1,035,072,002 in the October 2026 data, up 23%. Total employees: 2 in October 2021 and 2 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does 3(38) Investment Fiduciaries serve?**
By number of clients on Form ADV Item 5.D: pension and profit sharing plans (but not the plan participants or government pension plans) (207).

**Which custodians does 3(38) Investment Fiduciaries use?**
3(38) Investment Fiduciaries' most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Empower Financial Services, Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does 3(38) Investment Fiduciaries report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/298053

**What changed in 3(38) Investment Fiduciaries' recent Form ADV filings?**
In the July 2026 filing data: Updated its list of owners and control persons (Schedule A).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Fixed fees (other than subscription fees)

### Fees and minimums (Form ADV Part 2A brochure dated June 18, 2026)

- Asset-based fee: 0.02% to 0.5% a year (a range, as the brochure states it)

> It is generally based upon a percentage (%) of included plan assets as reported by the plan custodian or recordkeeper (generally ranging between .02% to .50% annually, depending on the nature and scope of services provided to the particular ERISA Plan Client)

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Empower Financial Services, Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $1,035,072,002
- Discretionary: $1,035,072,002
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 0 | $0 |
| High net worth individuals | 0 | $0 |
| Banking or thrift institutions | 0 | $0 |
| Investment companies | 0 | $0 |
| Business development companies | 0 | $0 |
| Pooled investment vehicles (other than investment companies and business development companies) | 0 | $0 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 207 | $1,035,072,002 |
| Charitable organizations | 0 | $0 |
| State or municipal government entities (including government pension plans) | 0 | $0 |
| Other investment advisers | 0 | $0 |
| Insurance companies | 0 | $0 |
| Sovereign wealth funds and foreign official institutions | 0 | $0 |
| Corporations or other businesses not listed above | 0 | $0 |
| Other | 0 | $0 |

### Advisory services (Item 5.G)
- Pension consulting services

### Firm details
- Registered since: 2018 (8 years)
- Employees: 2 total, 2 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, CA, HI, ID, NJ, OR, TX, UT, WA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- [338if.com](https://338if.com)
- [338investmentfiduciaries.com](https://338investmentfiduciaries.com)
- LinkedIn @3-38-investment-fiduciaries

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | Not reported | 2 | May 3, 2021 |
| October 2022 | Not reported | 2 | August 16, 2022 |
| October 2023 | Not reported | 2 | February 24, 2023 |
| October 2024 | Not reported | 3 | June 4, 2024 |
| October 2025 | $842,588,293 | 3 | June 16, 2025 |
| October 2026 | $1,035,072,002 | 2 | June 22, 2026 |

Regulatory assets under management: $842,588,293 in the October 2025 data and $1,035,072,002 in the October 2026 data, up 23%.
Total employees: 2 in October 2021 and 2 in October 2026.

## Changes in the filing (last 12 months)

### July 2026
- Updated its list of owners and control persons (Schedule A).

### June 2026
- Employees performing advisory functions went from 3 to 2.

### April 2026
- Regulatory assets under management went from $842,588,293 to $1,035,072,002 (+23%).

### December 2025
- Registered or notice-filed in NJ.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. 3(38) Investment Fiduciaries (CRD 298053): Form ADV filing data as of October 2026.