Overview
Assets Under Management: $761 million
Headquarters: AUSTIN, TX
High-Net-Worth Clients: 115
Average Client Assets: $5 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (CFM DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $62,500 | 1.25% |
| $10 million | $125,000 | 1.25% |
| $50 million | $625,000 | 1.25% |
| $100 million | $1,250,000 | 1.25% |
Clients
Number of High-Net-Worth Clients: 115
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 80.90
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 656
Discretionary Accounts: 656
Regulatory Filings
CRD Number: 305135
Last Filing Date: 2025-01-31 00:00:00
Website: https://cfmwealth.com
Form ADV Documents
Primary Brochure: CFM DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS (2025-06-02)
View Document Text
CFM Wealth Partners LLC
Form ADV Part 2A – Disclosure Brochure
Effective: June 2, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of CFM Wealth Partners LLC (“CFM” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (512) 366-3925.
CFM is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The information
in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority.
Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about CFM to assist you in determining whether to retain the Advisor.
Additional information about CFM and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 305135.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of CFM. For convenience, the Advisor has combined these documents into a single disclosure
document.
CFM believes that communication and transparency are the foundation of its relationship with Clients and will
continually strive to provide you with complete and accurate information at all times. CFM encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on January 22nd, 2024:
• The Advisor is now owned and operated by Edward A. Moody. Please see Item 4A for more information.
• The Advisor no longer utilizes independent managers. Please see Items 4, 5, and 10 for more
information.
Future Changes
The Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in
regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 305135. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (512) 366-3925.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information .......................................................................................................................................... 4
B. Advisory Services Offered ........................................................................................................................... 4
C. Client Account Management ....................................................................................................................... 5
D. Wrap Fee Programs .................................................................................................................................... 6
E. Assets Under Management ......................................................................................................................... 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services .......................................................................................................................... 6
B. Fee Billing .................................................................................................................................................... 7
C. Other Fees and Expenses ........................................................................................................................... 7
D. Advance Payment of Fees and Termination ............................................................................................... 8
E. Compensation for Sales of Securities ......................................................................................................... 8
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 .......................................................... 9
A. Methods of Analysis .................................................................................................................................... 9
B. Risk of Loss ................................................................................................................................................. 9
Item 9 – Disciplinary Information ....................................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11
A. Code of Ethics ........................................................................................................................................... 11
B. Personal Trading with Material Interest ..................................................................................................... 11
C. Personal Trading in Same Securities as Clients ....................................................................................... 11
D. Personal Trading at Same Time as Client ................................................................................................. 11
Item 12 – Brokerage Practices ............................................................................................................................ 12
A. Recommendation of Custodian[s] ............................................................................................................. 12
B. Aggregating and Allocating Trades ........................................................................................................... 12
Item 13 – Review of Accounts ............................................................................................................................ 13
A. Frequency of Reviews ............................................................................................................................... 13
B. Causes for Reviews ................................................................................................................................... 13
C. Review Reports ......................................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by CFM .............................................................................................................. 13
B. Client Referrals from Promoters ................................................................................................................ 13
Item 15 – Custody ................................................................................................................................................ 13
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ...................................................................................................................... 14
Item 18 – Financial Information .......................................................................................................................... 14
Form ADV 2B – Brochure Supplements ........................................................................................................... 16
Privacy Policy ...................................................................................................................................................... 20
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 3
Item 4 – Advisory Services
A. Firm Information
CFM Wealth Partners LLC (“CFM” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). CFM is organized as a Limited Liability Company (“LLC”) under the laws of
the State of Texas in September 2019. CFM is owned and operated by Edward A. Moody (Co-Founder and
Managing Partner).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by CFM. For information regarding this Disclosure Brochure, please contact Lisa S. Maas
(Chief Operating Officer and Chief Compliance Officer) at (512) 366-3925.
B. Advisory Services Offered
CFM offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. CFM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
CFM provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related
advisory services. CFM works closely with each Client to identify their investment goals and objectives as well as
risk tolerance and financial situation in order to design a portfolio strategy. CFM will then design an investment
strategy that may include the Advisor’s internal investment management and/or internal investment
management.
Internal Management – CFM will then construct an investment portfolio, consisting of mutual funds and/or
exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual
stocks, bonds, margins, or select private investments to meet the needs of its Clients. The Advisor may retain
other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-
related reasons, or other reasons as identified between the Advisor and the Client.
CFM’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. CFM
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CFM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. CFM may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. CFM may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. CFM may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will CFM accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 4
Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a
Client roll over its retirement plan account into an account managed by the Advisor. In such instances, the
Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income
Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the Advisor will earn a
new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over
retirement plan assets to an account managed by the Advisor.
Financial Planning Services
CFM will typically provide a variety of financial planning and consulting services to Clients. Financial planning
services may be included in an overall wealth management engagement or provided separately. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such
financial planning services involve preparing a formal financial plan or rendering a specific financial consultation
based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more
areas of need, including but not limited to, investment planning, retirement planning, personal savings, education
savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to, the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
CFM may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
CFM provides non-discretionary retirement plan advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to
assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Oversight
•
• Ongoing Investment Recommendation and Assistance
These services are provided by CFM serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of CFM’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging CFM to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 5
• Establishing an Investment Strategy – CFM, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – CFM will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – CFM will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – CFM will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CFM does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by CFM.
E. Assets Under Management
As of December 31, 2024, CFM manages $760,860,746 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
agreement. Investment advisory fees are based on the market value of assets under management at the end of the
prior calendar quarter. Investment advisory fees range from 0.75% to 1.25% annually based on several factors,
including: the complexity of the services to be provided, the inclusion of financial planning services, the level of
assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific
reporting requirements, portfolio restrictions and other complexities may be charged a higher fee.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may also have
an arrangement for a fixed fee. The Client’s fees will take into consideration the aggregate assets under
management with the Advisor. All securities held in accounts managed by CFM will be independently valued by the
Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However,
the Advisor shall not receive any portion of these commissions, fees, and costs.
Clients may make additions to and withdrawals from their account[s] at any time, subject to CFM’s right to terminate
an account. Additions may be in cash or securities provided that CFM reserves the right to liquidate any transferred
securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets
on notice to CFM, subject to the usual and customary securities settlement procedures. However, CFM designs its
portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client’s
investment objectives. CFM may consult with its Clients about the options and ramifications of transferring
securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to
transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax
ramifications.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 6
Financial Planning Services
Financial planning may be included in an overall wealth management engagement, pursuant to the terms of the
wealth management agreement. At times, the Advisor may offer financial planning and consulting services as a
separate engagement and fee. In such instances, CFM offers its services either on an hourly basis or a fixed
engagement fee. Hourly engagements range up to $500 per hour. Fixed engagement fees are based on the
expected effort and duration to complete the engagement at the negotiated rate. Fees may be negotiable based on
the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate
for total hours and total costs will be provided to the Client prior to engaging for these services.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.75%. Fees are billed in
advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Retirement
plan advisory fees are based on the market value of assets under management at the end of the prior calendar
quarter. Fees may be negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective quarter-end date. The amount due is calculated by
applying the quarterly rate (annual rate divided by 4) to the total assets under management with CFM at the end of
the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by
the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of
fees. Clients provide written authorization permitting advisory fees to be deducted by CFM to be paid directly from
their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms
provided by the Custodian. Certain Clients may also have arrangements with the Advisor that are invoiced to the
Client or paid from other accounts by the Client.
Financial Planning Services
Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the
financial planning agreement. The balance shall be invoiced upon completion of the agreed-upon deliverable[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than CFM, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fee charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. The fees charged by CFM are separate and
distinct from these custody and execution fees.
In addition, all fees paid to CFM for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described
in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the
funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of CFM,
but would not receive the services provided by CFM which are designed, among other things, to assist the Client
in determining which products or services are most appropriate for each Client’s financial situation and
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 7
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
CFM to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.
D. Advance Payment of Fees and Termination
Investment Management Services
CFM may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur
charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable
by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the
effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor
is non-transferable without the Client’s prior consent.
Financial Planning Services
CFM may require an advance deposit, as described above. Either party may terminate the financial planning
agreement by providing advance written notice to the other party. The Client may also terminate the financial
planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After
the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination
and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours
logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the
percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any
unearned, prepaid financial planning fees from the effective date of termination. The Client’s financial planning
agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
CFM is compensated for its retirement plan advisory services at the beginning of the quarter in which services are
rendered. Either party may request to terminate the retirement plan advisory agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement
within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period,
the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will
be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid retirement plan
advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory
agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
CFM does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
CFM does not charge performance-based fees for its investment advisory services. The fees charged by CFM
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held
by any Client.
CFM does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
CFM offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and retirement plans. CFM requires a minimum relationship size of $3,000,000 to
effectively implement its investment process. This minimum may be waived at the sole discretion of the Advisor.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
CFM primarily employs fundamental and technical analysis methods in developing investment strategies for its
Clients. Research and analysis from CFM are derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations
are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of
Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns
and trends, which may be based on investor sentiment rather than the fundamentals of the company. The
primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the
future. Even if the trend will eventually reoccur, there is no guarantee that CFM will be able to accurately predict
such a reoccurrence.
As noted above, CFM generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. CFM will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, CFM may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. CFM will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 9
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process.
Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will
fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower
rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at
a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk,
i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting
on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of
the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6)
Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the
bond.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if
securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to
a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of
mandatory liquidation of the pledged securities to compensate for the decline in value.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity.
An investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 10
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving CFM or its management persons. CFM
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due
diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s firm name or CRD# 305135.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of CFM is to provide investment advisory services to its Clients. Neither CFM nor its Advisory
Persons are involved in other business endeavors. CFM does not maintain any affiliations with other firms, other
than contracted service providers to assist with the servicing of its Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
CFM has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with CFM (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. CFM
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation
of CFM’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of
interest. To request a copy of the Code, please contact the Advisor at (512) 366-3925.
B. Personal Trading with Material Interest
CFM allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. CFM does not act as a principal in any transactions. In addition, the Advisor does
not act as the general partner of a fund, or advise an investment company. CFM does not have a material
interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
CFM allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by CFM requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While CFM allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no
time will CFM, or any Supervised Person of CFM, transact in any security to the detriment of any Client.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 11
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
CFM does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize CFM to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, CFM does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Where CFM does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and
will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by CFM.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not
engaged. CFM may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, and its reputation and/or the location of
the Custodian’s offices.
CFM will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.
(“Raymond James”), a FINRA-registered broker-dealer and member NYSE / SIPC. Raymond James will serve
as the Client’s “qualified custodian”. CFM maintains an institutional relationship with Raymond James, whereby
the Advisor pays an annual fee to Raymond James in exchange to access the custodial platform, trade, research
and other benefits. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. CFM does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian.
2. Brokerage Referrals - CFM does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where CFM will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of
any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase
of a security into one Client account from another Client’s account[s]). CFM will not be obligated to select
competitive bids on securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. CFM will execute its transactions through the
Custodian as authorized by the Client. CFM may aggregate orders in a block trade or trades when securities are
purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block
trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close
of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other
written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 12
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of CFM and
periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending
on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify CFM if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews
may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
CFM is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
CFM does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. CFM may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients.
Likewise, CFM may receive non-compensated referrals of new Clients from various third-parties.
A. Compensation Received by CFM
CFM has established an institutional relationship with Raymond James to assist the Advisor in managing Client
account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives
access to software and related support without cost because the Advisor renders investment management services
to Clients that maintain assets at Raymond James. The software and related systems support may benefit the
Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
Custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation
of this Custodian over one that does not furnish similar software, systems support, or services.
B. Client Referrals from Promoters
CFM does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”) for
Client referrals
Item 15 – Custody
CFM does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom CFM exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct CFM to utilize that Custodian for securities transactions on their behalf. Clients are
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 13
encouraged to review statements provided by the Custodian and compare to any reports provided by CFM to
ensure accuracy, as the Custodian does not perform this review.
Item 16 – Investment Discretion
CFM typically has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by CFM.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations
to such authority. All discretionary trades made by CFM will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
CFM does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither CFM, nor its management, have any adverse financial situations that would reasonably impair the ability
of CFM to meet all obligations to its Clients. Neither CFM, nor any of its Advisory Persons, have been subject to
a bankruptcy or financial compromise. CFM is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six
months or more in the future.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 14
Form ADV Part 2B – Brochure Supplement
for
Edward A. Moody
Co-Founder and Managing Partner
Effective: June 2, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Edward A. Moody (CRD# 4783505) in addition to the information contained in the CFM Wealth Partners LLC
(“CFM” or the “Advisor”, CRD# 305135) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the CFM Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (512) 366-3925.
Additional information about Mr. Moody is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4783505.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 15
Item 2 – Educational Background and Business Experience
Edward A. Moody, born in 1979, is dedicated to advising Clients of CFM as a Co-Founder and Managing
Partner. Mr. Moody earned a BBA Finance from University of Texas at Austin in 2002. Additional information
regarding Mr. Moody’s employment history is included below.
Employment History:
Co-Founder and Managing Partner, CFM Wealth Partners LLC
Vice President, Stephens, Inc.
Financial Advisor, RBC Capital Markets, LLC
09/2019 to Present
11/2012 to 09/2019
03/2004 to 11/2012
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Moody. Mr. Moody has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Moody.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Moody.
The Advisor encourages you to independently view the background of Mr. Moody on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4783505.
Item 4 – Other Business Activities
Mr. Moody is dedicated to the investment advisory activities of CFM’s Clients. Mr. Moody does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Moody is dedicated to the investment advisory activities of CFM’s Clients. Mr. Moody does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Moody serves as a Co-Founder and Managing Partner of CFM and is supervised by Lisa Maas, the Chief
Compliance Officer. Mrs. Maas can be reached at (512) 366-3925.
CFM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of CFM. Further, CFM is subject to regulatory oversight by various
agencies. These agencies require registration by CFM and its Supervised Persons. As a registered entity, CFM
is subject to examinations by regulators, which may be announced or unannounced. CFM is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 16
Form ADV Part 2B – Brochure Supplement
for
Preeti Narayan, CFP®
Wealth Advisor
Effective: June 2, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Preeti Narayan, CFP®, (CRD# 6941554) in addition to the information contained in the CFM Wealth Partners LLC
(“CFM” or the “Advisor”, CRD# 305135) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the CFM Disclosure Brochure or this Brochure
Supplement, please contact us at (512) 366-3925.
Additional information about Ms. Narayan is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6941554.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 17
Item 2 – Educational Background and Business Experience
Preeti Narayan, CFP®, born in 1994, is dedicated to advising Clients of CFM as a Wealth Advisor. Ms. Narayan
earned a Bachelor of Science in Business Administration from The Ohio State University in 2017. Additional
information regarding Ms. Narayan’s employment history is included below.
Employment History:
Wealth Advisor, CFM Wealth Partners LLC
Manager, Plante Moran Financial Advisors
06/2025 to Present
06/2016 to 04/2025
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
Client, at all times when providing financial advice and financial planning. CFP Board may sanction a
CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 18
professional's services. A Client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the Client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Narayan. Ms. Narayan has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Ms. Narayan.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Narayan.
However, we do encourage you to independently view the background of Ms. Narayan on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6941554.
Item 4 – Other Business Activities
Ms. Narayan is dedicated to the investment advisory activities of CFM’s Clients. Ms. Narayan does not have any
other business activities.
Item 5 – Additional Compensation
Ms. Narayan is dedicated to the investment advisory activities of CFM’s Clients. Ms. Narayan does not receive
any additional forms of compensation.
Item 6 – Supervision
Ms. Narayan serves as a Wealth Advisor of CFM and is supervised by Lisa Maas, the Chief Compliance Officer.
Mrs. Maas can be reached at (512) 366-3925.
CFM has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of CFM. Further, CFM is subject to regulatory oversight by various
agencies. These agencies require registration by CFM and its Supervised Persons. As a registered entity, CFM
is subject to examinations by regulators, which may be announced or unannounced. CFM is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 19
Privacy Policy
Effective: June 2, 2025
Our Commitment to You
CFM Wealth Partners LLC (“CFM” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here
in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. CFM (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or
servicing of our relationship with you.
CFM does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 20
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
CFM does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where CFM or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
CFM does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (512) 366-3925.
CFM Wealth Partners LLC
3500 Jefferson Street, Suite 315, Austin, TX 78731
Phone: (512) 366-3925 | Fax: (512) 827-0033
http://cfmwealth.com
Page 21