3(38) Investment Fiduciaries provides pension consulting.
3(38) Investment Fiduciaries reports 207 pension and profit-sharing plans. Of its assets, 100.0% ($1.04B across 207 accounts) are managed with discretion.
| Client type | Clients | Assets |
|---|---|---|
| Pension and profit-sharing plans | 100% | 100% |
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| Pension and profit-sharing plans | 207 | $1.04B | 100.0% | $5M |
| Total | 207 | $1.04B | 100% | $5M |
- Clients
- 207
- Regulatory AUM
- $1.04B
- AUM share
- 100.0%
- Avg. per client
- $5M
Total
- Clients
- 207
- Regulatory AUM
- $1.04B
- AUM share
- 100%
- Avg. per client
- $5M
- Clients outside the U.S.
- 0%
- Clients advised without assets under management last fiscal year
- 0
- Private funds advised
- 0
3(38) Investment Fiduciaries is paid through a percentage of assets under management and fixed fees (other than subscription fees); its fees and minimums are set out in its brochures on the SEC website.
Steven Wilkinson owns 75% or more of 3(38) Investment Fiduciaries. The leadership team of 3(38) Investment Fiduciaries includes President Steven Wilkinson. It has 2 employees.
Leadership
- Steven WilkinsonPresident & Chief Compliance Officer
Investment adviser representatives
2 representatives listed in the SEC register as of 9 October 2026.
- Adrian Edward Ramirez
- Steven T Wilkinson
Staff
- 2 employees
- 2 in advisory functions
- 2 state-registered reps
- 1 insurance agent
- Owns 75% or more of 3(38) Investment Fiduciaries Inc.
Steven Wilkinson
Control person · since July 2018
- Owns 75% or more of 3(38) Investment Fiduciaries Inc.
Fiducion LLC
Control person · since March 2026
- Owns 75% or more of Fiducion LLC
The Wilkinson Family Trust Dated October 26, 2018
Control person · since March 2026
Ashley Wilkinson
Trustee · Control person · since October 2018
3(38) Investment Fiduciaries’ regulatory assets grew Infinity× from $0 (May 2021) to $1.04B (June 2026); clients rose from 100 to 207 and employees were 2 in both filings.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| June 2026 | $1.04B | 207 | 2 | 2 |
| June 2025 | $843M | 175 | 3 | 2 |
| June 2024 | $0 | 138 | 3 | 2 |
| February 2023 | $0 | 123 | 2 | 2 |
| February 2022 | $0 | 97 | 2 | 1 |
| May 2021 | $0 | 100 | 2 | 1 |
Besides its headquarters, 3(38) Investment Fiduciaries has 1 office (1 private residence, listed without an address), with 1 listed address in California.
California · 1 listed address
- 3355 Cochran Street, Suite 101, Simi ValleyHQ
Contact and registration details
- Legal name
- 3(38) Investment Fiduciaries Inc.
- Headquarters
- 3355 Cochran Street, Suite 101, Simi Valley, CA 93063
- Website
- 338if.com
- Phone
- 818-296-9529
- @3-38-investment-fiduciaries
- SEC file
- 801-114078
- Structure
- California corporation
- Fiscal year end
- December
3(38) Investment Fiduciaries uses Empower ($997M) as custodian for its separately managed accounts. 3(38) Investment Fiduciaries does not have custody of client assets.
- EmpowerEmpower Financial Services, Inc. · Greenwood Village, CO · $997M100%
At year end, 3(38) Investment Fiduciaries’ separately managed accounts were largely in funds (40%) and cash (20%).
What the accounts hold
- Funds40%
- Cash20%
- Other40%
- Cits and group annuities40%
How many clients does 3(38) Investment Fiduciaries have?
3(38) Investment Fiduciaries has 207 clients and manages $1.04 billion for them, as of June 2026. They include 207 pension and profit-sharing plans.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 22 June 2026
What services does 3(38) Investment Fiduciaries offer?
3(38) Investment Fiduciaries provides pension consulting.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
Which custodians does 3(38) Investment Fiduciaries use?
3(38) Investment Fiduciaries’ separately managed account assets are held at Empower Financial Services, Inc. (Greenwood Village, CO), with $997M. Only custodians holding at least a tenth of those assets are named.
Source: Form ADV Part 1A, Schedule D, Section 5.K.(3), filed 22 June 2026
How many financial advisors does 3(38) Investment Fiduciaries have?
3(38) Investment Fiduciaries has 2 investment adviser representatives registered with state securities authorities, out of 2 employees, and 2 perform investment advisory functions. 0 employees are registered representatives of a broker-dealer and 1 employee is a licensed insurance agent.
Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file
What does 3(38) Investment Fiduciaries invest in?
At the end of its last fiscal year, 3(38) Investment Fiduciaries’ separately managed accounts held 40% registered funds (mutual funds, ETFs, BDCs), 40% other and 20% cash and equivalents. The 40% other category is described as: Cits and Group Annuities.
Source: Form ADV Part 1A, Items 5.K.(1) and 7.B, from the SEC's 2 October 2026 data file
Who owns 3(38) Investment Fiduciaries?
3(38) Investment Fiduciaries’ direct owners are Steven Wilkinson (75% or more) and Fiducion LLC (75% or more).
Source: Form ADV Part 1A, Schedules A and B, filed 22 June 2026
How does 3(38) Investment Fiduciaries get paid?
3(38) Investment Fiduciaries is paid through a percentage of assets under management and fixed fees. Its Form ADV lists no commissions or performance-based fees among how it is paid.
Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file
How do I contact 3(38) Investment Fiduciaries?
3(38) Investment Fiduciaries’ main office is at 3355 Cochran Street, Suite 101, Simi Valley, CA 93063. Its phone number is 818-296-9529. Its website is 338if.com.