Mascagni Wealth Management Inc

Item 7 – Types of Clients
                                                                                 also incur brokerage costs when purchasing ETFs. Leveraged and
We provide financial planning, financial advisory, and portfolio                 inverse ETFs may not be suitable for all investors and have unique
management services to individuals, high net worth individuals,                  characteristics and risks. Although there are limited occasions
corporate pension and profit-sharing plans, trusts, estates, and                 where a leveraged or inverse ETF may be useful for some types of
charitable organizations. We typically do not impose any minimum                 investors, it is extremely important to understand that, for holding
requirements for financial planning services. For our discretionary              periods longer than a day, these funds may not give you the
wrap fee program, we generally require a minimum of $100,000 of                  returns you may be expecting.
investable assets. See our Wrap Fee Program Brochure for additional          •   Management Risk. The value of your investment will vary with the
details.                                                                         success and failure of our investment strategies, research, analysis
                                                                                 and determination of portfolio securities. If our investment

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    strategies do not produce the expected returns, the value of the        accounts in securities which are recommended to and/or purchased
    investment may decrease.                                                for our clients. The Code of Ethics is designed to assure that the
                                                                            personal securities transactions, activities and interests of our
In addition to general market risks described above, our investment
strategies may be subject to the risk of loss arising from direct or        employees of will not interfere with (i) making decisions in the best
                                                                            interest of advisory clients and (ii) implementing such decisions while,
indirect exposure to a number of types of catastrophic events, such as
global pandemics, natural disasters, acts of terrorism, cyber-attacks,      at the same time, allowing employees to invest for their own accounts.
                                                                            Under the Code certain classes of securities have been designated as
or network outages. The extent and impact of any such event on
investment strategies will depend on many factors, including the            exempt transactions, based upon a determination that these would
                                                                            materially not interfere with the best interest of MASCAGNI WEALTH
duration and scope of the event, the extent of any governmental
restrictions, the effect on the supply chain, overall consumer              MANAGEMENT’s clients. In addition, the Code requires pre-clearance of
                                                                            many transactions, and restricts trading in close proximity to client
confidence, and the extent of the disruption to global and domestic
markets.                                                                    trading activity. Nonetheless, because the Code of Ethics in some
                                                                            circumstances would permit employees to invest in the same
Although we endeavor to select investments that have low fees and           securities as clients, there is a possibility that employees might benefit
expense ratios, in making our investment selections we analyze a            from market activity by a client in a security held by an employee.
number of factors, such as performance, risk, and the benefit of a          Employee trading is continually monitored under the Code of Ethics,
particular investment to the overall portfolio. For example, in some        and to reasonably prevent conflicts of interest between us and our
cases, we may choose to invest your assets in a mutual fund share class     clients. You may request a copy of our Code of Ethics by contacting J.
with a higher expense ratio because of other beneficial factors, such       Randall Mascagni (randy@mascagni.com) or Julie Sanders
as no transaction fees, if we deem it is in your best interests.            (julie@mascagni.com) or any officer of the firm.