Brighter Financial Capital Management LLC

Types of Clients
 BFCM generally provides investment advice to individuals, high net worth individuals,
 corporations or business entities.
 Client relationships vary in scope and length of service.

 1 For information regarding Schwab, please refer to their website: https://www.schwab.com/.
 2 FINRA is the largest independent regulator for all securities firms doing business in the United States. For
 more information, please refer to FINRA’s website: http://www.finra.org/.
 3 For information regarding SIPC, please refer to their website: http://www.sipc.org/.

Item 6: Portfolio Manager Selection and Evaluation
 Portfolio Manager
 Megan Clark manages all Program Accounts. Since no other unaffiliated persons will manage
 the wrap program, there are no additional processes for selection or review of managers.
 Clients make the decision to select BFCM as their portfolio manager.
 Since all programs are managed by our Investment Advisor Representatives, there is no
 conflict of interest regarding portfolio managers.

 Conflicts of Interest
 No agency-cross transactions or principal transactions are effected by BFCM in Program
 accounts.
 The Program may cost the Client more or less than purchasing Program services separately.
 Factors that bear upon the cost of the Program account in relation to the cost of the same
 services purchased separately include: the type and size of the account, the historical and/or
 expected size or number of trades for the account, and the number and range of
 supplementary advisory and Client related services provided to the account.
 The Annual Fee is an ongoing fee for investment advisory services and may cost the Client
 more than if the assets were held in a traditional brokerage account. In a brokerage account,
 a Client is charged a commission for each transaction and the representative has no duty to
 provide ongoing advice with respect to the account. If the Client plans to follow a buy and
 hold strategy for the account or does not wish to purchase ongoing investment advice or
 management services, the Client should consider opening a brokerage account rather than a
 Program account.
 BFCM receives compensation as a result of the Client’s participation in the Program. The
 amount of this compensation may be more or less than what BFCM would receive if the Client
 participated in other programs or paid separately for investment advice, brokerage and
 other Client services. Therefore, BFCM may have a financial incentive to recommend the
 Program account over other programs and services. BFCM acts as the portfolio manager for
 the Program and retains the management fee less execution costs. This may create a conflict
 of interest because BFCM may have a disincentive to trade securities in the account to keep
 the execution costs low therefore retaining a larger portion of the management fee.

 Advisory Business
 BFCM offers Clients an asset management account through the Program in which BFCM
 directs and manages Program assets for Client.
 Client provided goals and objectives are documented in individual Client files. Investment
 strategies are created that reflect the stated goals and objective.
 A Client may impose restrictions on a minimum level of cash they want in their account, as
 well as from which account they want their withdrawals to come. Also, a Client may issue
 restrictions on what specific securities or security types they do not want BFCM to buy or
 sell in their account.

BFCM also offers:
ASSET MANAGEMENT
BFCM offers discretionary and non-discretionary asset management services to advisory
Clients. BFCM also offers assets management service through its Wrap Fee Program. Please
see Form ADV2A & 2B – Wrap Brochure Appendix.
BFCM will offer Clients ongoing asset management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors.
   Discretionary
   When the Client provides BFCM discretionary authority the Client will sign a limited
   trading authorization or equivalent. BFCM will have the authority to execute transactions
   in the account without seeking Client approval on each transaction.
   Non-Discretionary
   When the Client elects to use BFCM on a non-discretionary basis, BFCM will determine
   the securities to be bought or sold and the amount of the securities to be bought or sold.
   However, BFCM will obtain prior Client approval on each and every transaction before
   executing any transaction.
When deemed appropriate for the Client, BFCM may hire Sub-Advisors to manage all or a
portion of the assets in the Client account. BFCM has full discretion to hire and fire Sub-
Advisors as they deem suitable. Sub-Advisors will maintain the models or investment
strategies agreed upon between Sub-Advisor and BFCM. Sub-Advisors execute trades on
behalf of BFCM in Client accounts. BFCM will be responsible for the overall direct
relationship with the Client. BFCM retains the authority to terminate the Sub-Advisor
relationship at BFCM’s discretion.
VARIABLE ANNUITY MANAGEMENT
BFCM offers discretionary direct asset management services to advisory Clients on their
variable annuities. BFCM will work with individuals to assemble an appropriate portfolio of
investment options as provided through the insurance company that services the variable
annuity investment. The accounts will be monitored on an annual basis.
ERISA PLAN SERVICES
BFCM provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
BFCM will act as a 3(21) advisor:
Limited Scope ERISA 3(21) Fiduciary. BFCM may serve as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions on a
...