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.
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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;
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• 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.
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Assets Under Management
As of December 31, 2023, MILAGRE manages $83,790,796.01. All assets are managed on a
discretionary basis.