CMC FINANCIAL GROUP, LLC

Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page 7000 Central Parkway, Suite 225 Atlanta, GA 30328 Tel: (678) 690-8800 Fax: (678) 690-8900 Website: www.cmcfg.com March 17, 2025 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of CMC Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (678) 690-8800. 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 CMC Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CMC Financial Group, LLC is 292413. CMC Financial Group, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Form ADV, Part 2A, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (678) 690-8800 or mark@cmcfg.com. Material Changes since the Last Update Since the last Annual Update filed on March 28, 2024, CMC Financial Group, LLC has had the following material changes: • None 2  Form ADV, Part 2A, Item 3 Table of Contents Item 1 Cover Page 1 Item 2 Material Changes 2 Item 3 Table of Contents 3 Item 4 Advisory Business 4 Item 5 Fees and Compensation 6 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 Item 9 Disciplinary Information 12 Item 10 Other Financial Industry Activities and Affiliations 12 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 13 Item 12 Brokerage Practices 14 Item 13 Review of Accounts 15 Item 14 Client Referrals and Other Compensation 16 Item 15 Custody 16 Item 16 Investment Discretion 17 Item 17 Voting Client Securities 17 Item 18 Financial Information 17 3  Form ADV Part 2A, Item 4 Advisory Business A. Description of the Advisory Firm CMC Financial Group, LLC (hereinafter “CMCFG”) is a Registered Investment Adviser based in Atlanta, Georgia, and incorporated under the laws of the State of Georgia. CMCFG is owned by Mark Barry McCarthy and Philip Oraien Catledge. CMCFG is registered with the Securities and Exchange Commission and is subject to its rules and regulations. Incorporated in December 2008, CMCFG previously provided investment advisory and brokerage services as a DBA through another firm, however in March 2018 CMCFG became an independently registered investment adviser with the Securities and Exchange Commission. B. Types of Advisory Services Portfolio Management Services CMCFG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Each client completes a form 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 CMCFG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CMCFG 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 a software generated risk assessment, which is provided to each client. CMCFG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CMCFG’s economic, investment or other financial interests. To meet its fiduciary obligations, CMCFG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CMCFG’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 CMCFG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. CMCFG may recommend clients to third-party investment advisers to manage all or a portion of the client's assets. Before recommending other advisers to clients, CMCFG will ensure those other advisers are properly licensed or registered as an investment adviser. CMCFG conducts due diligence on any third-party investment adviser, which 4  may involve one or more of the following: phone calls, meetings and review of the third- party adviser's performance and investment strategy. CMCFG will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. 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. Retirement Plan Services CMCFG provides retirement plan consulting services to employer sponsored retirement plans. The services may include general advising to the Investment Manager / Sponsor of the Plan on investment options, as well as participant education. Services Limited to Specific Types of Investments CMCFG generally does not limit its investment advice, but most often provides investment advice related 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, although CMCFG primarily recommends ETFs. CMCFG may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CMCFG offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the 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 CMCFG from properly servicing the client account, or if the restrictions would require CMCFG to deviate from its standard suite of services, CMCFG reserves the right to end the relationship. D. Wrap Fee Program CMCFG may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. CMCFG provides discretionary and non- discretionary investment advisory services to its clients through a Wrap Fee Program. Wrap Fee Program accounts recommended by CMCFG are not managed differently from non-Wrap Fee Program accounts. Because brokerage execution costs are included in the client’s overall advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee Program accounts, however fees will not exceed 5  the fee schedule stated in CMCFG’s Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided with CMCFG’s Wrap Fee Brochure. This Brochure is focused on non-Wrap Fee Program accounts. E. Assets Under Management CMCFG has the following assets under management, calculated on December 31, 2024: Discretionary: $81,013,622 Non-discretionary: $28,879,886 Form ADV, Part 2A, Item 5 Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Account Value Maximum Annual Advisory Fee All Assets 2.00% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of CMCFG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 7 days' written notice. Selection of Other Advisers Fees CMCFG may recommend clients to third-party investment advisers. The fees are generally negotiable and will be stated in each Agreement signed by the Client. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $250 and $10,000, depending on the scope and complexity of the requested services. 6  Clients may terminate the agreement without penalty for a full refund of CMCFG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 7 days' written notice. Retirement Plan Consulting Fees CMCFG charges a maximum of 0.60% annually based on the amount of assets in the Plan. B. Payment of Fees Payment of 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. Fees are paid in advance. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected and will be disclosed to the client prior to entering into a relationship with the third-party advisor. Payment of Financial Planning Fees Financial planning fees are paid via check. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan and/or completion of the project. Payment of Retirement Plan Consulting Fees The Plan sponsor compensates CMCFG directly on a quarterly basis. C. Client Responsibility for Third Party Fees In addition to advisory fees paid to CMCFG as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. Some of these fees may be included in Wrap Fee Program accounts as described above in Item 4 – Advisory Services. These fees vary by broker and/or custodian. Clients should ask CMCFG for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. CMCFG does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with CMCFG and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. 7  Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. D. Prepayment of Fees CMCFG collects fees quarterly in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) 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 Neither CMCFG nor its supervised persons accept any compensation for the sale of securities, including asset-based sales charges or service fees from the sale of mutual funds. Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management CMCFG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Form ADV, Part 2A, Item 7 Types of Clients CMCFG generally provides advisory services to the following types of clients: 8  Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Corporations or Business Entities ❖ ❖ ❖ ❖ There is no account minimum for any of CMCFG’s services. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CMCFG’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. CMCFG uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. 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. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies CMCFG uses long term trading and short term trading strategies. 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 9  Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. 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. Quantitative analysis 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. 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. Investment 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. Selection of Other Advisers: Although CMCFG will seek to select only money managers who will invest clients' assets with the highest level of integrity, CMCFG's selection process cannot ensure that money managers will perform as desired and CMCFG will have no control over the day-to-day operations of any of its selected money managers. CMCFG would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks or investment “style drift”. 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 10  performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized 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 other precious metals, (3) a significant change in the attitude of speculators and investors. 11  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. 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. Form ADV, Part 2A, Item 9 Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. 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. Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CMCFG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CMCFG 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. 12  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests The IARS of CMCFG do not have any other outside business activities to report. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CMCFG may recommend clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay CMCFG its standard fee, in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between CMCFG and each third-party advisor. CMCFG will always act in the best interests of the client, including when determining which third- party investment adviser to recommend to clients. CMCFG will ensure that all recommended advisers are licensed, or notice filed in the states in which CMCFG is recommending them to clients. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CMCFG 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. CMCFG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests CMCFG does not recommend that clients buy or sell any security in which a related person to CMCFG or CMCFG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of CMCFG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CMCFG 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. CMCFG will always document any transactions that could be construed as conflicts of interest and will never 13  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 CMCFG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CMCFG 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, CMCFG will never engage in trading that operates to the client’s disadvantage if representatives of CMCFG buy or sell securities at or around the same time as clients. Form ADV, Part 2A, Item 12 Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on CMCFG’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 CMCFG 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 CMCFG's research efforts. CMCFG recommends Trade-PMR Inc., Member FINRA SIPC. 1. Research and Other Soft-Dollar Benefits CMCFG has no formal soft dollars program in which soft dollars are used to pay for third party services. Additionally, CMCFG does not receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals CMCFG 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 CMCFG does not permit clients to direct it to execute transactions through a specified broker-dealer. 14  B. Aggregating (Block) Trading for Multiple Client Accounts If CMCFG 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, CMCFG 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. CMCFG 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). Form ADV, Part 2A, Item 13 Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for CMCFG's advisory services provided on an ongoing basis are reviewed at least monthly by Mark B McCarthy or Philip O. Catledge with regard to clients’ respective investment policies and risk tolerance levels. All accounts at CMCFG are assigned to these reviewers. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Mark B McCarthy or Philip O. Catledge. Financial planning clients may be provided a one-time financial plan concerning their financial situation. After the completion of the project, there are no further reports. Clients may request additional plans or reports for a fee. 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, CMCFG’s services will generally conclude upon delivery of the financial plan and/or conclusion of the project. C. Content and Frequency of Regular Reports Provided to Clients Each client of CMCFG'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. CMCFG will also provide at least quarterly a separate written statement to the client. 15  Each financial planning client may receive the financial plan upon completion, or other project-related documents. Form ADV, Part 2A, 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) CMCFG does not receive any economic benefit, directly or indirectly from any third party for advice rendered to CMCFG clients. B. Compensation to Non – Advisory Personnel for Client Referrals CMCFG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Form ADV, Part 2A, Item 15 Custody CMCFG does not have physical custody of any client funds and/or securities, and does not take custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, by granting CMCFG written authorization to automatically deduct fees from client accounts, CMCFG is deemed to have limited custody. You will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. 16  Form ADV, Part 2A, Item 16 Investment Discretion Before CMCFG can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities CMCFG 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. Form ADV, Part 2A, Item 18 Financial Information A. Balance Sheet CMCFG neither requires nor solicits prepayment of more than $1,200 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 CMCFG nor its management has any financial condition that is likely to reasonably impair CMCFG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years CMCFG has not been the subject of a bankruptcy petition in the last ten years. 17 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure Form ADV, Part 2A, Item 1 Cover Page 7000 Central Parkway, Suite 225 Atlanta, GA 30328 Tel: (678) 690-8800 Fax: (678) 690-8900 Website: www.cmcfg.com March 17, 2025 FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE This brochure provides information about the qualifications and business practices of CMC Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (678) 690-8800. 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 CMC Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CMC Financial Group, LLC is 292413. CMC Financial Group, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Form ADV, Part 2A Appendix 1, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (678) 690-8800 or mark@cmcfg.com. Material Changes since the Last Update Since the last Annual Update filed on March 28,2024, CMC Financial Group, LLC has had the following material changes: • None 2  Form ADV, Part 2A Appendix 1, Item 3 Table of Contents Services, Fees and Compensation……………………………………….…4 Account Requirements and Types of Clients……………………………..6 Portfolio Manager Selection and Evaluation………………………………7 Client Information Provided to Portfolio Managers…………...…….….11 Client Contact with Portfolio Managers…………………………………..11 Additional Information....…………………………………………………….11 3  Form ADV Part 2A Appendix 1, Item 4 Services, Fees and Compensation CMC Financial Group, LLC (hereinafter referred to as "CMCFG") is a Registered Investment Adviser based in Atlanta, GA. CMCFG is owned by Mark Barry McCarthy and Philip Oraien Catledge. CMCFG is registered with the Securities and Exchange Commission and is subject to its rules and regulations. Incorporated in December 2008, CMCFG previously provided investment advisory and brokerage services as a DBA through another firm, however in March 2018 CMCFG became an independently registered investment adviser with the Securities and Exchange Commission. CMC Financial Group, LLC provides investment advice and portfolio management services on a continuing basis, which may include the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. CMCFG also provides financial planning consulting services including risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation and retirement planning. A “wrap fee program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. CMCFG provides discretionary and non-discretionary investment advisory services to some of its clients through a managed account program (“the Wrap Fee Program”). CMCFG will assist clients in determining the suitability of the Wrap Fee Program for the client. In order for CMCFG to provide asset management services, we request you utilize the brokerage and custodial services of TradePMR Inc./Wells Fargo Clearing Services, LLC (“TradePMR”), for which we have an existing relationship. TradePMR and CMC Financial Group, LLC are separate companies and not affiliated. WRAP FEE PROGRAM CMCFG’s Wrap Fee Program is offered as a part of the Asset Management Services described above. CMCFG provides portfolio management services for this program based on the Client’s investment goals and objectives. Managed Accounts are available to primarily individuals and small businesses. 4  Fees and Compensation The following types of fees will be assessed: Asset Management – Fees are charged in advance and are based primarily on asset size and the level of complexity of the services provided. In individual cases, CMCFG has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the market value of the assets on the last business day of the previous quarter. Annual fees will not exceed 2.00%. Consulting services are included in these fees for asset management services with the exception of unique circumstances that may require a separate agreement for financial planning services (description and fees are discussed below). If the situation warrants separate financial planning fees, it will be discussed upfront and a separate agreement will be negotiated. As authorized in the client agreement, the account custodian withdraws CMCFG’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodian in turn remits these fees to CMCFG. The custodial statement includes the amount of any fees paid directly to CMCFG to manage the account. You should review the statement and verify the calculation of fees. Your custodian/broker-dealer does not verify the accuracy of fees calculations. If the account does not contain sufficient funds to pay advisory fees, CMCFG has limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. With the exception of IRA accounts, clients may reimburse the account for advisory fees paid to CMCFG. Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the quarter. Clients may terminate investment advisory services obtained from CMCFG, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with CMCFG. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by CMCFG. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of CMCFG’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable. Financial Planning – Financial planning services are charged in arrears through a fixed fee arrangement as agreed upon between the client and CMCFG. The negotiated fixed rate for creating client financial plans is between $250 and $10,000, depending on the scope and complexity of the requested services. There will never be an instance where $1,200 or more in fees is charged six or more months in advance. Similar financial planning services may be available elsewhere for a lower cost to the client. Financial planning fees are paid via check. 5  Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan and/or completion of the project. Additional Fees and Expenses In addition to advisory fees paid to CMCFG as explained above, clients are charged custodial service, account maintenance, transaction, and other fees associated with maintaining the account, however CMCFG pays some or all of these fees for designated Wrap Accounts. Therefore, these fees are included in the fee schedule above. These fees vary by broker dealer and/or custodian. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with CMCFG and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of CMCFG or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive CMCFG’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. Form ADV, Part 2A Appendix 1, Item 5 Account Requirements and Types of Clients CMCFG offers investment advisory services primarily to individuals and small businesses. There is no minimum account size to open and maintain an advisory account. 6  Form ADV, Part 2A Appendix 1, Item 6 Portfolio Manager Selection and Evaluation CMCFG or a third party money manager may act as the portfolio manager for its Wrap Fee Program accounts. There is no conflict of interest with either arrangement. Advisory Business CMC Financial Group, LLC (hereinafter referred to as "CMCFG") is a Registered Investment Adviser based in Atlanta, GA. Founded in December 2008, CMC Financial Group, LLC provides investment advice and portfolio management services on a continuing basis, which may include the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. CMCFG also provides financial planning consulting services including risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation and retirement planning. CMC Financial Group, LLC provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with CMC Financial Group, LLC. Managed Accounts are available to individuals and small businesses. Asset Management CMC Financial Group, LLC provides discretionary and non-discretionary investment advisory services to some of its clients through various managed account programs. CMC Financial Group, LLC will assist clients in determining the suitability of the Managed Account Programs for the client. The IAR is compensated through a comprehensive single fee and the account may be assessed other charges associated with conducting a brokerage business. The firm and its IAR, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, reviewing the investment 7  objectives and evaluating the investment vehicle selections • Providing Firm Brochure (this document) CMCFG may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. CMCFG provides discretionary investment advisory services to some of its clients through a Wrap Fee Program. CMCFG will assist clients in determining the suitability of the Wrap Fee Program for the client. Wrap Fee Program accounts recommended by CMCFG are not managed differently from non-Wrap Fee Program accounts. Because brokerage execution costs are included in the client’s overall advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule stated in this Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided with this Wrap Fee Brochure. CMCFG has the following assets under management, calculated on December 31, 2024: Discretionary: $81,013,622 Non-discretionary: $28,879,886 Performance-Based Fees and Side by Side Management CMCFG does not charge performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above and are not charged on the basis of performance of your advisory account. Methods of Analysis, Investment Strategies, and Risk of Loss CMCFG’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. CMCFG is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance range of each portfolio and the risk level of each level when the account is opened. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Asset Allocation has the potential of all the risks listed below. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Dollar-Cost Averaging has the potential of all the risks listed below. 8  Technical Analysis – involves studying past price charts, patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Technical Analysis has the potential of all the risks listed below. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Long- Term Purchases have the potential of all the risks listed below. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Short-term Purchases primarily have the potential of Market Risk, Business Risk, and Liquidity Risk as listed below. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. CMCFG’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. CMCFG’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. CMCFG’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. 9  Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. CMCFG has no control over the risks taken by the underlying funds. Voting Client Securities CMCFG does not vote proxies on behalf of Client advisory accounts. At the Client’s request, CMCFG may offer the Client advice regarding corporate actions and the exercise of proxy 10  voting rights. If the Client owns shares of common stock or mutual funds, the Client is responsible for exercising the right to vote as a shareholder. In most cases, the Client will receive proxy materials directly from the account custodian. However, in the event CMCFG receives any written or electronic proxy materials, we would forward them directly to the Client by mail, unless the Client has authorized our firm to contact you by electronic mail, in which case, CMCFG would forward any electronic solicitation to vote proxies. Form ADV, Part 2A Appendix 1, Item 7 Client Information Provided to Portfolio Managers CMCFG may directly provide the portfolio management services for the Wrap Fee Program accounts. As such, CMCFG receives all information provided by the Client. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Form ADV, Part 2A Appendix 1, Item 8 Client Contact with Portfolio Managers There are no restrictions placed on CMCFG’s clients’ ability to contact and consult with their portfolio manager(s). Form ADV, Part 2A Appendix 1, Item 9 Additional Information Disciplinary Information CMCFG or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Other Financial Industry Activities and Affiliations The IARs of CMCFG do not have any other outside business activities to report. The IARs of CMCFG are not currently registered with any broker dealer. Neither CMCFG nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11  CMCFG’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of CMCFG’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with CMCFG are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. CMCFG may buy or sell securities for itself that we also recommend to clients. In addition, the individual IARs may buy or sell the same securities for their personal and family accounts that are bought and sold for your account(s). CMCFG or its IARs may have an interest or position in a certain security, which may also be recommended to the client. As these situations may present a conflict of interest, CMCFG has established the following restrictions in order to ensure its fiduciary responsibilities: A director, officer or employee of the advisor shall not buy or sell a security for their The advisor requires that all employees must act in accordance with all applicable The advisor will monitor any blocking of personal trades with those of clients to ensure 1. personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of CMCFG shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. Federal and State regulations governing registered investment advisors. 4. that clients are not at a disadvantage. CMCFG’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Philip Catledge at (678) 690-8800. CMCFG does not recommend or select other investment advisors to our clients for which we receive compensation, directly or indirectly, from those advisors, nor do we have business relationships with any other investment advisors. Review of Accounts Client accounts are reviewed at least quarterly by Philip Catledge or Mark McCarthy, Principal Executive Officers of the firm. Client accounts are reviewed with regard to their investment policies and risk tolerance levels. All accounts at CMCFG are reviewed by these reviewers. Reviews may also 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). 12  Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Client Referrals and Other Compensation CMCFG does not compensate any individual or firm for client referrals, nor does CMCFG receive compensation for referrals made to other professional service providers. Financial Information CMCFG is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. 13