Libertas Wealth Management Group Inc

Types of Clients
Libertas offers investment advice primarily to individuals, high net worth individuals, non- profit
foundations and business owners.

Item 6 Portfolio Manager Selection and Evaluation
Portfolio Manager
Adam D. Koos, President manages all Program accounts.

In general, all individuals that render investment advice on behalf of Libertas 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.

Libertas requires that individuals have high standards or morals and ethics and be committed to
providing quality investment advice. Additionally, advisory representatives will be required to obtain
any required regulatory examinations.

Conflicts of Interest
In establishing a Program account, client elects to appoint Charles Schwab & Co., Inc. ("Schwab"), an
unaffiliated SEC-registered broker-dealer and member FINRA/SIPC, as the sole and exclusive
broker/dealer and custodian with respect to processing securities transactions for the Program
account. Libertas does not maintain custody of client assets.

Securities transactions for Program accounts are effected without commissions being charged to
client. While Libertas makes every attempt to obtain the best execution possible, there is no assurance
that it will be obtained. Clients should consider whether or not the appointment of Schwab as the sole
broker/dealer and custodian may or may not result in certain costs or disadvantages to the client as a
result of possibly less favorable executions. In considering whether or not to restrict the execution of
transactions through Schwab, Libertas considered the capabilities of Schwab.

Although clients will not be charged a transaction charge for transactions through Schwab, clients
should be aware that Libertas will be required to pay transaction charges to Schwab. The transaction
charges borne by Libertas vary based on the type of transactions (e.g., mutual fund, equity or fixed
income security) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or
sub-transfer agent fees that are retained by the custodian in amounts sufficient to cover the majority of
trading costs. Clients should understand that the cost to Libertas of transaction charges may be a
factor that Libertas considers when deciding which securities to select and whether or not to place
transactions in a Program account.

No agency-cross transactions or principal transactions are effected by Libertas in Program accounts.

Libertas may aggregate transactions for a client with other clients to improve the quality of execution.
When transactions are so aggregated, the actual prices applicable to the aggregated transactions will
be averaged, and the client will be deemed to have purchased or sold its proportionate share of the
securities involved at the average price obtained.

Libertas participates in the institutional advisor program (the "Program") offered by Schwab to
independent investment advisors, the services of which include custody of securities, trade execution,
clearance and settlement of transactions. Advisor receives some benefits from Schwab through its
participation in the Program.

As disclosed above, Libertas participates in Schwab's institutional customer program and may
recommend Schwab to Clients for custody and brokerage services. There is no direct link between
Libertas's participation in the program and the investment advice it gives to its Clients, although
Libertas receives economic benefits through its participation in the program that are typically not
available to Schwab retail investors. These benefits include the following products and services
(provided without cost or at a discount): receipt of duplicate Client statements and confirmations;
research related products and tools; consulting services; access to a trading desk serving
Libertas participants; access to block trading (which provides the ability to aggregate securities
transactions for execution and then allocate the appropriate shares to Client accounts); the ability to
have advisory fees deducted directly from Client accounts; access to an electronic communications
network for Client order entry and account information; access to mutual funds with no transaction fees
and to certain institutional money managers; and discounts on compliance, marketing, research,
technology, and practice management products or services provided to Libertas by third party vendors.
Schwab may also have paid for business consulting and professional services received by Libertas's
related persons. Some of the products and services made available by Schwab through the program
may benefit Libertas but may not benefit its Client accounts. These products or services may assist
Libertas in managing and administering Client accounts, including accounts not maintained at Schwab.
Other services made available by Schwab are intended to help Libertas manage and further develop
its business enterprise. The benefits received by Libertas or its personnel through participation in the
program do not depend on the amount of brokerage transactions directed to Schwab. As part of its
fiduciary duties to clients, Libertas endeavors at all times to put the interests of its clients first. Clients
should be aware, however, that the receipt of economic benefits by Libertas or its related persons in
and of itself creates a potential conflict of interest and may indirectly influence the Libertas's choice of
Schwab for custody and brokerage services.

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
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