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Dear Potential Client, Our industry has problems. We are not always proud of it. We personally know a lot of honest, hardworking people who try hard to do their best for their clients. We have also come across (and read about) industry players who make used car salesmen look like Mother Theresa. Our industry is complex: You have investment advisers (us), brokers, financial planners, insurance salesmen, broker dealers, hedge funds, mutual funds, funds of funds, investment consultants – it’s a hodge-podge. To make things worse, the industry provides complicated products. And if that was not enough, compensation, and thus the incentives of some of the participants, are not very clear. Do they invest you in a particular mutual fund because it pays them more than the other one? Was it appropriate for you or just beneficial to their bank account? So how about us? We don’t believe honesty can be legislated, but full-disclosure of incentives (i.e. sources of compensation) can be. Here is the disclosure of our conflicts of interest: We have not found any, yet. But we are still looking, and if we discover any you’ll be the first to know. We make money in only one way. The only compensation we receive directly or indirectly for the privilege of managing your account is the management fee. We receive no other compensation – none! Brokerage firms don’t pay us any kickbacks. They don’t pay us any soft dollars – money generated from trading commissions that could be used for research. We pay for all our outside research from our pockets. We don’t buy mutual funds for clients; but even if we did, they still wouldn’t pay us anything to invest in them. Incentives are very important - as long as they’re the right ones. When we analyze stocks, we spend a lot of time looking at management incentives. We love companies whose management owns a lot of stock in the business it runs (for instance, Softbank’s CEO, Masayoshi Son, owns more than 20% of Softbank). We know 2

that significant insider ownership will not protect us from human misjudgment, but it will shield us from even more dangerous indifference, which in the corporate world is usually expressed as capital misallocation (bad, expensive, dilutive acquisitions, for instance). Therefore, we built IMA so our incentives are directly aligned with you. Our management fee – its dollar amount – will vary with the size of your account. We get richer and poorer with you. Wall Street is famous for manufacturing products they’d like you to buy but that they wouldn’t consume themselves. We don’t do that. We strongly believe in what we do and follow this philosophy: If a particular stock is good for our clients, it should be good for us. So we eat our own cooking. Vitaliy’s personal and family accounts (wife and three kids) are managed by IMA. Stocks that are bought or sold in your accounts are automatically bought or sold for Vitaliy’s son, Jonah, his daughters, Hannah and Mia Sarah, his wife, Rachel, and Vitaliy himself. Mike Conn and his family mostly own the same stocks as his clients. We never buy or sell stocks in our personal accounts ahead of our clients – that would be illegal and simply unethical and wrong. We believe strongly that trust is built on communication and transparency. We put an enormous amount of energy and time into bringing our clients as close to our thinking as humanly possible in our quarterly letters, where we walk our clients through whys of our decisions (buys and sells) and indecisions during the quarter. We aspired to build an investment service that we would love being clients of and we are proud of the result. The document in front of you will give you an in-depth look into IMA, our values, our client experience, and our investment process. We tried to answer any questions you might have, but if you have something left unanswered, we’d love for you to get in touch. Call us at 303-796-8333 or email us at contact@imausa.com and we’ll get back to you within one business day.

Sincerely, Michael Conn, CFA Vitaliy Katsenelson, CFA

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Why We Built IMA Our Core Values
No conflicts of interest Our only source of income is our fully disclosed management fee. We built IMA so that our profits would be correlate to change in your wealth, ensuring we always make investment choices that are only in your best interests Our managers own the same stocks Our CEO Vitaliy Katsenelson’s entire family investments are handled by IMA, including those of his three kids. That’s because we firmly believe that IMA’s methodology is the only sane way of investing in today’s economy. No second-rate investments If we can’t find a high-quality company (in the US or internationally) that fulfills our rigorous valuation criteria and is incredibly cheap, we will simply hold more cash. No hands behind our backs If we find a stock that we think would be great for your portfolio, why reject it simply because it doesn’t fit in a particular box? We set no restrictions on style, size, or geography. It’s hard enough to find good stocks as it is. No chasing fads We protect your portfolio by sticking to rational research-based decisions. With clear, strict guidelines for the kinds of businesses we’ll invest in and specific sell criteria, we won’t buy or sell simply because everyone else is buying or selling – unless our research concludes that it’s good for your portfolio.

How We Built IMA
No bureaucracy There’s no “slow committee” in our decision-making process. If a great opportunity presents itself and we’re confident in our research, we won’t miss it just because we’re waiting for the go-ahead from some board. We won’t do dumb things with your money We have no institutional pressure to own a stock to hug a benchmark or just because our competitors bought it. We invest in businesses we think are good for your portfolio. Period. International research network We have spent several decades nurturing an international network of professional investors who help us find new opportunities or gain insights into our existing holdings. That means each of our investment decisions has been peer-reviewed for quality and safety.

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Why You’ll Love Being Our Client
No more investing in hot dogs What are those things really made of? We’re not really sure. But unlike other firms, we’ll explain exactly what’s in your portfolio and why it’s there. Extremely Transparent We pour our heart into our quarterly letters so that you see our reasoning behind any purchase, sale, or hold in your portfolio. You can also see each position and cost basis on the custodian’s website (reported daily). Still have questions? We can answer them by phone or email. Customized Portfolios Just because we bought a security a year ago doesn’t mean it’s a good purchase for you right now. We don’t railroad new clients into stocks we currently own, unless we still think they’re a good deal for you. And since you own your own cost basis, you won’t be paying taxes on gains enjoyed by previous investors. Have other concerns? We can skip purchases of stocks you don’t want to buy, such as defense or tobacco. We can also make sure you make capital gains or losses for tax purposes. Just let us know what you need. Just a Phone Call Away Any questions, comments, or concerns about your portfolio? We won’t make you wade through an automated phone system or talk to people who don’t know anything about investing. Our clients have direct access to IMA’s decision makers by phone or email when they want to talk about their portfolios.

The All-Terrain Portfolio You Need for Any Economy...
Our mission is to make sure your portfolio can grow while riding out whatever financial terrain lies ahead –including the worst. To do this, we built IMA on value investing principles outlined by Benjamin Graham and popularized by Warren Buffett. Of course, we added a twist of our own. ...Built on the 6 Commandments of Value Investing (+1 of Our Own) I Treat stocks as businesses, not widgets We don’t trade -- we invest. Traders have the short-term in mind, so they treat stocks more like widgets than actual businesses.

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