Description of Advisory Firm MILAGRE was incorporated under the laws of New York State in January 2020. MILAGRE is wholly owned by Mr. Paul dos Santos, Chief Executive Officer and Chief Compliance Officer. MILAGRE provides fee- based investment advisory services. Description of Advisory Services MILAGRE offers Investment Management Services (“IMS”), and as a component of the Firm’s IMS offering, financial planning is included at no additional charge. Investment Management Services (“IMS”) We provide IMS of client accounts that entails the ongoing supervision of assets. This includes, but is not limited to, monitoring client accounts, making investment recommendations, and executing transactions as recommended. All transactions are executed on a discretionary basis. Please see “Item 16 – Investment Discretion” for more detailed information on the management of client assets on a discretionary basis. Our IMS are designed for high-net worth and non-high net worth individuals, as well as trusts and estates. We define high net-worth clients as individuals with assets of at least $1 million, excluding their primary residence. Generally, IMS requires both a net worth and account size of $50,000 to open an account. However, at its discretion, the Firm may open accounts with both a net worth and account size of less than $100,000. Through this service, We offer a customized investment program for each client that takes various factors into consideration, including, but not limited to, investment objectives, risk tolerance, investment knowledge, net worth, income, liquidity needs, and age. As part of the investment management process, we recommend that clients establish an account at Schwab, member of FINRA/Securities Investor Protection Corporation (“SIPC”). Brokerage, custody, directed trustee, record keeping, plan design support and plan administration are provided by Schwab. Milagre is not affiliated with Schwab or any of its entities. For more information on material conflicts of interest, please refer to the following items: “Item 5 – Fees and Compensation”, “Item 10 – Other Financial Industry Activities and Affiliations”, and “Item 12 – Brokerage Practices”. IMS Tailored to the Individual Needs of Each Client Our IMS are tailored to align with client risk profiles by utilizing various inputs, including, risk questionnaires, to establish investment objectives and to understand risk tolerance. Although rare, clients may impose investment restrictions on the accounts/assets We manage that may include individual security selection or sectors in which to invest or avoid. 5 | P age We generally recommend the following types of securities (although we advise and review securities and products beyond those listed below):
• Mutual Funds
• Exchange-Traded Funds (“ETF”s)
• Equity Securities
• International or Foreign securities
• Fixed Income Securities
• Certificates of Deposit
• US Treasury Securities (i.e., T-Bills, T-Notes, T-Bonds)
• Cash, Cash Equivalents, and Money Market IMS

Encompasses Active Management and Changes to Portfolio Allocations Active management of client accounts/assets may require the Firm to adjust portfolio allocations with some frequency, dependent on various factors which are not limited to market conditions, expectations, risk tolerance, and tax considerations. While We do not attempt to time the ups and downs of financial markets, there may be extended periods of time We hold relatively large percentages of client assets in cash equivalents in an attempt to reduce market exposure. Additional Financial Planning Services As described previously, additional financial planning is a component of the Firm’s IMS offering. Financial planning focuses on the client’s overall financial situation as opposed to the active management of client accounts/assets. Financial planning can be described as helping individuals determine and set long-term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of the financial planning process is to find ways to help the client understand their overall financial situation and assist the client in setting and monitoring financial objectives. Financial plans can be holistic or modular in nature. Topics covered in a financial plan may include, but are not limited to, one or more of the following key areas:
• Information gathering, identifying goals and concerns
• Outside-held asset review (e.g. variable annuity, employer 401(k))
• Financial literacy assessment and education
• Risk assessment and management
• Investment tax review and planning
• Insurance review and planning
• Retirement planning
• Estate planning
• Periodic reviews When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rules provision we must:
• Meet a professional standard of care when making investment recommendations; 6 | P age
• Never put our financial interests ahead of yours when making recommendations;
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. For more information about our conflicts of interest, please review items 5. 10, 11 and 14 or reach out to us using the contact information on the cover page of this brochure. 7 | P age Assets Under Management As of December 31, 2023, MILAGRE manages $83,790,796.01. All assets are managed on a discretionary basis.