ANGELUS INVESTMENT CONSULTING, INC.

Angelus Investment Consulting, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Angelus Investment Consulting, Inc.. If you have any questions about the contents of this brochure, please contact us at (305) 928-1551 or by email at: operaciones@angelusinvestment.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Angelus Investment Consulting, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Angelus Investment Consulting, Inc.’s CRD number is: 281413. 999 Ponce de Leon, St. 830 Coral Gables, FL 33134 (305) 928-1551 http://www.angelusinvestment.com operations@angelusinvestment.com Registration does not imply a certain level of skill or training. Version Date: 03/20/2025 i  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment of Angelus Investment Consulting, Inc. on 03/21/2024. Material changes relate to Angelus Investment Consulting, Inc.’s policies, practices or conflicts of interests. i  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ................................................................................................................................................................................................................................... i Item 3: Table of Contents ................................................................................................................................................................................................................ ii Item 4: Advisory Business ................................................................................................................................................................................................................................ 2 A. Description of the Advisory Firm ...................................................................................................................................................................................... 2 B. Types of Advisory Services ................................................................................................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ....................................................................................................................................................... 3 D. Wrap Fee Programs ................................................................................................................................................................................................................................ 3 E. Assets Under Management ................................................................................................................................................................................................... 3 Item 5: Fees and Compensation .................................................................................................................................................................................................... 4 A. Fee Schedule .............................................................................................................................................................................................................................................. 4 B. Payment of Fees ....................................................................................................................................................................................................................... 6 C. Client Responsibility For Third Party Fees .................................................................................................................................................................... 7 D. Prepayment of Fees ................................................................................................................................................................................................................................ 7 E. Outside Compensation For the Sale of Securities to Clients ..................................................................................................................................... 7 Item 6: Performance-Based Fees and Side-By-Side Management .................................................................................................................................................... 8 Item 7: Types of Clients .................................................................................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................................................................................ 8 A. Methods of Analysis and Investment Strategies ................................................................................................................................................. 9 B. Material Risks Involved ............................................................................................................................................................................................................... 9 C. Risks of Specific Securities Utilized ..................................................................................................................................................................................... 11 Item 9: Disciplinary Information ................................................................................................................................................................................................ 12 A. Criminal or Civil Actions ........................................................................................................................................................................................... 12 B. Administrative Proceedings .................................................................................................................................................................................... 13 C. Self-regulatory Organization (SRO) Proceedings ............................................................................................................................................. 13 Item 10: Other Financial Industry Activities and Affiliations ........................................................................................................................................... 13 A. Registration as a Broker/Dealer or Broker/Dealer Representative ...................................................................................................................... 13 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................... 13 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............................................... 13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ...................................... 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................................... 14 A. Code of Ethics ............................................................................................................................................................................................................... 14 B. Recommendations Involving Material Financial Interests ........................................................................................................................... 14 C. Investing Personal Money in the Same Securities as Clients .................................................................................................................................... 14 D. Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................................. 15 ii  Item 12: Brokerage Practices ....................................................................................................................................................................................................................... 15 A. Factors Used to Select Custodians and/or Broker/Dealers ......................................................................................................................... 15 1. Research and Other Soft-Dollar Benefits ....................................................................................................................................................... 15 2. Brokerage for Client Referrals ......................................................................................................................................................................................... 16 3. Clients Directing Which Broker/Dealer/Custodian to Use ..................................................................................................................... 16 B. Aggregating (Block) Trading for Multiple Client Accounts........................................................................................................................... 16 Item 13: Review of Accounts ........................................................................................................................................................................................................ 16 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ....................................................................................... 16 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ...................................................................................................... 17 C. Content and Frequency of Regular Reports Provided to Clients ................................................................................................................ 17 Item 14: Client Referrals and Other Compensation ............................................................................................................................................................. 17 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ....... 17 B. Compensation to Non – Advisory Personnel for Client Referrals .............................................................................................................. 18 Item 15: Custody............................................................................................................................................................................................................................... 18 Item 16: Investment Discretion .................................................................................................................................................................................................................. 18 Item 17: Voting Client Securities (Proxy Voting) ................................................................................................................................................................................. 18 Item 18: Financial Information ................................................................................................................................................................................................................... 19 A. Balance Sheet ............................................................................................................................................................................................................................... 19 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................................... 19 C. Bankruptcy Petitions in Previous Ten Years ..................................................................................................................................................... 19 iii  Item 4: Advisory Business A. Description of the Advisory Firm Angelus Investment Consulting, Inc. (hereinafter “Angelus”) is a Corporation organized in the State of Florida. The firm was formed in May 2015, and the principal owner is Jaime Domenech Macias. B. Types of Advisory Services Portfolio Management Services Angelus offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Angelus creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring Angelus evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Angelus will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Angelus seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Angelus’s economic, investment or other financial interests. To meet its fiduciary obligations, Angelus attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Angelus’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Angelus’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Pension Consulting Services Angelus offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Subadviser Services Angelus may also act as a subadviser to advisers unaffiliated with Angelus. These third-party advisers would outsource portfolio management services to Angelus. This relationship will be memorialized in each contract between Angelus and the third-party advisor. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments Angelus generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. Angelus may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Angelus offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Angelus from properly servicing the client account, or if the restrictions would require Angelus to deviate from its standard suite of services, Angelus reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Angelus does not participate in any wrap fee programs. E. Assets Under Management 3  Angelus has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 99,925,663 $ 84,220,239 December 2024 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $0 - $500,000 2.00% $500,001 - $1,000,000 1.50% $1,000,001 - $10,000,000 1.25% $10,000,001 - And Up 1.00% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of Angelus's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 15 days' written notice. Angelus uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Performance-Based Fees for Portfolio Management Qualified clients will pay an annual fee of 2.00% of assets under management along with a 20.00% performance fee based on capital appreciation. If the client's portfolio rises in value, the client will pay 20.00% on that increase in value, but if the portfolio drops in value, the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark.” The high water mark will be the highest value of the client’s account on the last day of any previous quarter, after accounting for the client’s deposits or withdrawals for each billing period. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. This service may be canceled with 15 days’ notice. 4  Clients must pay the prorated performance-based fees for the billing period in which they terminate the Investment Advisory Contract up to and including the day of termination. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee $0 - $500,000 2.00% $500,001 - $1,000,000 1.50% $1,000,001 - $10,000,000 1.25% $10,000,001 - And Up 1.00% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of Angelus's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Angelus uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Angelus uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Subadviser Services Fees for Quattro Financial Advisors LLC Angelus may also act as a subadviser to unaffiliated third-party advisers and Angelus would receive a share of the fees collected from the third-party adviser’s client. The fees charged are negotiable and will not exceed any limit imposed by any regulatory agency. This relationship will be memorialized in each contract between Angelus and the third-party adviser. Total Assets All Assets Angelus’s Fee 0.50% Third Party’s Fee 0.50% Total Fee 1.00% Fixed Fees The rate for creating client pension consulting plans is between $2,500 and $250,000. The final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. This service may be canceled with 15 days’ notice. 5  Hourly Fees The hourly fee for these services is between $150 and $2,000. The final fee schedule will be attached as Exhibit II of the Investment Advisory Contract. Financial Planning Fees Clients may terminate the agreement without penalty for a full refund of Angelus's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Fixed Fees The negotiated fixed rate for creating client financial plans is between $2,500 and $250,000. Fees are charged 30% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly Fees The negotiated hourly fee for these services is between $150 and $2,000. Fees are charged in arrears upon completion. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a monthly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Performance-Based Portfolio Management Fees Performance-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Asset-Based Pension Consulting Fees Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a monthly basis. Clients may select the method in which they are billed. Fees are paid in arrears. 6  Payment of Fixed or Hourly Pension Consulting Services Fees Fixed pension consulting fees are paid via check. These fees are paid 30% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly pension consulting fees are paid in arrears upon completion. Payment of Financial Planning Fees Financial planning fees are paid via check and wire. Fixed financial planning fees are paid 30% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly financial planning fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Angelus. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees Angelus collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients Angelus or its supervised persons may accept compensation for the sale of securities or other investment products, including asset-based sales charges or services frees from the sale of mutual funds. Jaime Domenech Macias is a registered representative of a broker-dealer. In this role, he may accept compensation for the sale of securities and other products to Angelus clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of securities or other 7  investment products, including asset based sales charges or service fees from the sale of mutual funds to Angelus's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, Angelus will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase Angelus recommended products through other brokers or agents that are not affiliated with Angelus. 3. Commissions are not Angelus's primary source of compensation for advisory services Commissions are not Angelus’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management Angelus manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) and may as well manage accounts that are not billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because Angelus and/or its supervised persons have an incentive to favor accounts for which Angelus receives a performance-based fee. Angelus addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. Angelus seeks best execution and upholds its fiduciary duty for all clients. Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. Item 7: Types of Clients Angelus generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension & Profit Sharing Plans Minimum Account Size 8  There is no account minimum for any of Angelus’s services. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Angelus’s methods of analysis include fundamental analysis, technical analysis, quantitative analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies Angelus uses long term trading, short term trading, short sales, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Angelus may recommend unusually risky investments to clients. For example: high yield bonds, emerging market debt, workout situations. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. 9  Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Angelus's use of short sales, margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not 10  necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Angelus's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or 11  other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. 12  B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative As a registered representative of Insight Securities Inc. Jaime Domenech Macias accepts compensation for the sale of securities. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Angelus nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Jaime Domenech Macias is a registered representative and an investment advisor representative with Insight Securities, Inc and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Angelus always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Angelus in such individual’s capacity as a registered representative. Jaime Domenech Macias is a licensed insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Angelus always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of Angelus in such individual’s outside capacities. 13  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Angelus does not utilize nor select third-party investment advisers. All assets are managed by Angelus management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Angelus has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Angelus's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Client approval will be sought for client investment in such recommendations and, if granted, such approval will be binding. If a principal transaction arises, Angelus will only execute such transaction with the consent of the applicable client. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of a related person, buys from or sells any security to any advisory client. If an agency cross transaction arises, Angelus will only execute such transaction with the consent of the applicable client. An agency cross transaction is generally defined as a transaction where a person acts as investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Angelus may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Angelus to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Angelus will always 14  document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Angelus may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Angelus to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, Angelus will never engage in trading that operates to the client’s disadvantage if representatives of Angelus buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Angelus’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and Angelus may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in Angelus's research efforts. Angelus will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Angelus recommends Insight Securities, Inc with custody of assets at Pershing Advisor Solutions LLC, TD Ameritrade Institutional, a division of TD Ameritrade, Inc. Member FINRA/SIPC and Axos Clearing LLC. 1. Research and Other Soft-Dollar Benefits While Angelus has no formal soft dollars program in which soft dollars are used to pay for third party services, Angelus may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). Angelus may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and Angelus does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. Angelus benefits by not having to produce or pay for the research, products or services, and Angelus will have an 15  incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that Angelus’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals Angelus receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use Angelus may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to Angelus to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless Angelus is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If Angelus buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, Angelus would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. Angelus would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for Angelus's advisory services provided on an ongoing basis are reviewed at least quarterly by Jaime Domenech Macias, President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at Angelus are assigned to this reviewer. 16  All financial planning accounts are reviewed upon financial plan creation and plan delivery by Jaime Domenech Macias, President. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, Angelus’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of Angelus's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Angelus will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Angelus participates in the institutional advisor program (the “Program”) offered by TD Ameritrade. TD Ameritrade offers to independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. Angelus receives some benefits from TD Ameritrade through its participation in the Program. As part of the Program, Angelus may recommend TD Ameritrade to clients for custody and brokerage services. There is no direct link between Angelus’s participation in the Program and the investment advice it gives to its clients, although Angelus receives economic benefits through its participation in the Program that are typically not available to TD Ameritrade 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 Angelus 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 Angelus’s fees deducted directly from client 17  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 Angelus by third party vendors. TD Ameritrade may also pay for business consulting and professional services received by Angelus’s related persons. Some of the products and services made available by TD Ameritrade through the Program may benefit Angelus but may not benefit its client accounts. These products or services may assist Angelus in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help Angelus manage and further develop its business enterprise. The benefits received by Angelus or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, Angelus endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Angelus or its related persons in and of itself creates a conflict of interest and may indirectly influence the Angelus’s choice of TD Ameritrade for custody and brokerage services. B. Compensation to Non – Advisory Personnel for Client Referrals Angelus may retain third parties to act as solicitors/promoters for Angelus’s investment management services. Compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. Angelus will ensure each solicitor/promoter is properly exempt or registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with the Advisers Act, where applicable. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, Angelus will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion Angelus provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Angelus generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. 18  Item 17: Voting Client Securities (Proxy Voting) Angelus will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet Angelus neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Angelus nor its management has any financial condition that is likely to reasonably impair Angelus’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Angelus has not been the subject of a bankruptcy petition in the last ten years. 19