Immaculate Wealth Management LLC

Types of Clients
 Advisor generally provides investment advice primarily to individuals, high net worth
 individuals and corporations.

               Item 6: Portfolio Manager Selection and Evaluation
Portfolio Manager
 Mark E. Rauguth, Managing Member, will manage all Program accounts.
 In general, all individuals that render investment advice on behalf of Advisor are required
 to have a college degree and/or five (5) years of equivalent industry experience. In
 addition, all Advisory representatives must have obtained all required licenses or a
 professional designation.
 Each individual will be reviewed and considered on a case-by-case basis by an executive
 member of Advisor. Advisor requires that individuals have high standards or morals and
 ethics and be committed to providing quality investment advice.

Conflicts of Interest
 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.
 Advisor 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 Advisor would receive if the
 client participated in other programs or paid separately for investment advice, brokerage
 and other client services. Therefore, Advisor may have a financial incentive to recommend
 the Program account over other programs and services.

                               Immaculate Wealth Management, LLC

Advisory Business
 Advisor offers clients an asset management account through the Program in which
 Advisor directs and manages Program assets for client.
 The goals and objectives for each client are documented in our client files. Investment
 strategies are created that reflect the stated goals and objective. Clients may impose
 restrictions on investing in certain securities or types of securities.

Sharing of Capital Gains
 Fees are not based on a share of the capital gains or capital appreciation of managed
 securities.
 Advisor does not use a performance-based fee structure because of the potential conflict
 of interest. Performance-based compensation may create an incentive for the advisor to
 recommend an investment that may carry a higher degree of risk to the client.