# 3(38) Investment Fiduciaries

3(38) Investment Fiduciaries is a RIA based in Simi Valley, United States.

## Overview

- **Organization type:** RIA
- **Headquarters:** Simi Valley, United States
- **Region:** North America
- **Assets under management:** Undisclosed
- **LinkedIn:** https://www.linkedin.com/company/338if

## Regulatory record

- **CRD number:** 298053
- **SEC file number:** 801-114078
- **Registration status:** Registered
- **Reports private funds:** No
- **IAPD record:** https://adviserinfo.sec.gov/firm/summary/298053

## About

3(38) INVESTMENT FIDUCIARIES is an SEC-registered investment adviser in SIMI VALLEY, CA, registered since 2018. The firm manages approximately $1.0 billion in assets. It has 2 employees and 2 investment advisers.

## Sectors

- Private Credit
- Hedge Funds
- Real Estate

## Questions

### What does the '3(38)' in the firm's name mean?

The name refers to ERISA Section 3(38), which defines an investment manager with discretionary authority over retirement-plan assets. By accepting this designation, the firm assumes legal liability for investment decisions — a step beyond a 3(21) co-fiduciary, which provides advice but leaves final decisions to the plan sponsor.

### Who runs investment decisions at 3(38) Investment Fiduciaries?

The firm does not publicly name its principals or investment committee. The 3(38) structure, however, means that whoever holds discretionary authority is personally liable under ERISA for portfolio outcomes. Without public disclosures, the internal decision-making process remains opaque.

### What asset classes does 3(38) Investment Fiduciaries typically use?

The firm is known in the retirement-plan space for including private credit, hedge funds, and real estate alongside traditional equities and fixed income. Its focus is diversification within the constraints of ERISA prudence rules.

### How does the 3(38) fiduciary status affect the firm's fees?

A 3(38) fiduciary's fee must be reasonable under ERISA. The firm cannot accept hidden compensation or kickbacks from underlying fund managers. Any revenue-sharing or 12b-1 fees must be disclosed and credited to the plan — a transparency requirement not shared by most investment advisors.

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Last updated: 2026-06-03T20:00:00.000Z

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