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ITEM 1
Cover Page
Form ADV Part 2A
Firm Brochure
February 18, 2026
This Brochure provides information
about the qualifications and
business practices of CMG Wealth
Management. If you have any
questions about the contents of
this Brochure, please contact us at
(469) 729-7084, or via email at
sengels@cmgwm.com. 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.
CMG Wealth Management is a
registered investment advisory
firm. Registration of an investment
advisory firm does not imply a
particular level of skill or training.
Additional information about CMG
Wealth Management is also
available on the SEC’s website at
www.adviserinfo.sec.gov.
CMG Wealth Management
IARD#307513
2500 Dallas Parkway Suite 400
Plano, TX 75093
(469) 729-7084
sengels@cmgwm.com
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 our Firm Brochure. This Item discusses only specific material changes made
to this Brochure and provides our clients with a summary of such changes.
Material Changes since the Last Update
Since our last filing on January 30, 2025, there were material changes made to the brochure.
Item 4: Advisory Business
Item 5: Fees and Compensation
•
•
Full Brochure and Additional Information
Full Brochure and additional information about CMG Wealth Management are available via the SEC’s
website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with us who are registered or are required to be registered as investment adviser
representatives (“IAR”).
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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 ............................................................................................... 5
ITEM 6
Performance-Based Fees and Side-By-Side Management ................................................. 7
ITEM 7
Types of Clients ........................................................................................................... 7
ITEM 8
Methods of Analysis, Investment Strategies, and Risk of Loss ........................................... 7
ITEM 9
Disciplinary Information ............................................................................................... 9
ITEM 10 Other Financial Activities and Affiliations ........................................................................ 9
ITEM 11
Code of Ethics, Participation in Client Transactions and Personal Trading ........................... 9
ITEM 12
Brokerage Practices ................................................................................................... 10
ITEM 13
Review of Accounts .................................................................................................... 12
ITEM 14
Client Referrals and Other Compensation ..................................................................... 13
ITEM 15
Custody .................................................................................................................... 13
ITEM 16
Investment Discretion ................................................................................................ 13
ITEM 17
Voting Client Securities .............................................................................................. 14
ITEM 18
Financial Information ................................................................................................. 14
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ITEM 4 Advisory Business
FIRM INFORMATION
CMG Global Holdings, LLC dba Course Made Good Wealth Management dba CMG Wealth Management
(“CMG,” “we,” “us,” “our”), formed in June 2018, is a registered investment advisory firm located in Plano,
Texas.
PRINCIPAL OWNERS
CMG is owned and controlled by its Managing Members Stephen M. Engels and James P. Pacholek.
Stephen M. Engels is the Chief Compliance Officer.
INVESTMENT ADVISORY SERVICES
Asset Management Services:
We provide asset management services in which we manage your custodial accounts and provide you
with continuous and ongoing supervision of your custodial accounts on both a discretionary and non-
discretionary basis. Our services provide additional investment opportunities among stocks, bonds,
mutual funds, exchange-traded funds (ETFs), Real Estate Investment Trusts (REITs), options, and
additional securities.
Retirement Plan Consulting
We provide advisory services to plan participants of employer-sponsored 401(k) plans, in addition to
supporting affiliated companies through other non-advisory services to retirement plans for small
business entities. Such advisory services can include advice/education, monitoring performance, annual
meetings for direct participants.
We do not assist the plan sponsor in choosing in the assets held in the plan. We can, however, assist the
participants with selection and/or de-selection and replacement of individual investment options
pursuant to their individual investment criteria.
Due Diligence services for General Partners
We can generate a one-time due diligence report on private investments, such as private partnerships.
These reports will address the value, risks, and overall viability of potential investment. We will address
financial information, market and future growth potential, potential legal and regulatory risks,
management structure, and tax responsibilities of the investment and investor. These reports are
impersonal: i.e. they will not be customized to individual investors.
CLIENT INVESTMENT OBJECTIVES/RESTRICTIONS
CMG offers the same suite of services to all our clients. However, specific recommendations and their
implementation are dependent upon the individual client’s suitability form, which outlines a client’s
current financial situation such as income, net worth, and risk tolerance levels. This information is
essential in the development of a client-specific plan in the selection of investments that matches
restrictions, needs, and targets. On a case by case basis, our clients may impose restrictions on investing
in certain securities or types of securities in accordance with their values or beliefs. However, if the
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restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us
to deviate from our standard suite of services, we reserve the right to end the relationship. We may
request additional information and documentation, such as current investments, tax returns, insurance
policies, and estate plan. We will discuss your investment objectives, needs, and goals, but you must
inform us of any changes. Unless directed by you, we do not independently verify any information
provided to us by you or your attorney, accountant, or other professionals.
WRAP FEE PROGRAMS
CMG does not participate in, recommend, or offer wrap fee programs.
ASSETS UNDER MANAGEMENT
As of December 31, 2025, CMG managed $350,319,462 on a discretionary basis and $29,054,078 on a
non-discretionary basis.
ITEM 5
Fees and Compensation
ANNUAL FEES FOR ADVISORY SERVICES
CMG is compensated for providing asset management services by charging a negotiable fee based on the
total assets under management. The fees and billing will be pre-determined in writing in the Investment
Advisory Agreement executed by you and CMG.
The below ranges are the standard fee ranges that are typically charged.
Asset Management Fee Schedule
All Assets
0.25% - 1.25%
FEE BILLING & PAYMENT
Our assets under management fees are annual fees and may be negotiable. Asset management fees are
paid quarterly in advance. Payments are due on the first day of the calendar quarter and are based on
the account’s asset value as of the last business day of the prior calendar quarter multiplied by the
applicable annual rate and divided by four (4). The fee for the subsequent quarter is billed and payable
within ten (10) days after the end of the prior quarter. We will deduct our asset management fee only
when in receipt of your written authorization by executing an investment advisory agreement permitting
the fees to be paid directly from your account. The qualified custodian will deliver an account statement
to you at least quarterly, which will show all disbursements from your account. We urge you to review all
statements for accuracy.
Retirement planning consulting services are compensated from the plan sponsor annually the amount of
50bps (0.50%). This fee is paid to us quarterly from ERISA budget.
For the creation of due diligence reports, CMG will charge a one-time fee based on the schedule below.
Due-diligence report fees are paid via check or by direct invoicing via an electronic payment processor.
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One-Time Report AUM
Fee Schedule
Assets under $100,000
$100,001 to $200,000
$200,001 to $300,000
$300,001 to $400,000
$400,001 to $500,000
$500,001 and up
$ 500
$1,500
$2,500
$3,500
$4,500
$5,000
You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.).
These fees are separate and distinct from the fees and expenses charged by CMG.
TERMINATION OF AGREEMENT
Either party may terminate the investment advisory agreement by providing 30-day advance written
notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any
earned, unpaid fees will be due and payable up to and including the effective date of termination.
Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48
hours prior to you entering into any written or oral advisory contract with us, then you have the right to
terminate the contract without penalty within five (5) business days after entering into the contract.
OTHER EXPENSES AND FEES
The fees discussed above include payment solely for the investment advisory services provided by us and
are separate from certain fees or charges that are imposed by third parties in connection with investments
made on your behalf for your account. Third-party fees may include markdowns, markups, brokerage
commissions, other transaction costs, and/or custodial fees.
All fees paid to us for asset management services are separate from the expenses charged by exchange-
traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay
management fees for the funds, other fund expenses, account administration, and a possible distribution
fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services.
However, you would not receive our services to assist you in determining which products or services are
most suitable for your financial situation and objectives. You should review both the fees we charge and
the fees charged by the fund(s) to understand the total fees to be paid fully.
OTHER COMPENSATION
Certain of our associated persons are also licensed, insurance agents. In this capacity, the IARs may
recommend insurance, advisory, or other products, and receive normal insurance commissions if products
are purchased through the IAR(s) in this capacity. Thus, a conflict of interest exists between the interests
of these individuals and those of the advisory clients, creating an incentive for the IAR(s) to recommend
products based on the compensation received, rather than on a client’s needs. However, clients are under
no obligation to act upon any of these recommendations. Although our recommendations may include
products offered by third parties, these recommendations are not limited to such products as all financial
planning advice provided is of a generic nature. Clients have the option to purchase insurance products
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recommended by the IAR through other agents not affiliated with our firm. Please refer to Item 10 of this
Brochure for a more detailed explanation of how our firm handles and mitigates these conflicts of interest.
ITEM 6
Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees, which are fees based on a share of capital gains on or
capital appreciation of your assets.
ITEM 7
Types of Clients
We provide our investment advisory services to:
- Individuals
- High Net Worth Individuals
- Non-Profit Organizations
- Corporations
- Other business entities
We do not have a minimum account size for our asset management services.
ITEM 8 Methods of Analysis, Investment Strategies, and Risk of
Loss
METHODS OF ANALYSIS
We use various methods of analysis and investment strategies, including the following:
Fundamental Analysis – We evaluate economic and financial factors to determine if a security may be
underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to
determine its intrinsic value by examining related financial, economic, and other qualitative and
quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the
security's value, from macroeconomic factors (like the overall economy and industry conditions) to
individually specific factors (like the financial situation and management of companies). The overall
objective of performing the fundamental analysis is to determine a value that an investor can use to
determine what sort of position to take with that security. This method of security analysis is contrary to
technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although
most analysts use fundamental analysis to value stocks, this method of valuation can be used for just
about any type of security.
Technical Analysis – This method involves the evaluation of securities by performing an analysis of statical
information that is generated by market activity, such as past prices and volume. Technical analysis does
not attempt to measure a security's intrinsic value but instead, use charts and other tools to determine
the patterns that can suggest future activity. Technical analysts believe that the historical performance of
stocks and markets are indications of future performance.
Modern Portfolio Theory - Modern portfolio theory (MPT) is a risk-averse theory that involves the
construction of portfolios to maximize and optimize expected return based on a given level of market risk,
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emphasizing that risk is an inherent part of higher reward. According to the theory, it's possible to
construct an "efficient frontier" of optimal portfolios offering the maximum possible expected return for
a given level of risk.
INVESTMENT STRATEGIES
When formulating investment advice or managing client assets, we will use the following investment
strategies. There are inherent risks associated with each of these strategies.
Long-Term Strategy - A long-term strategy may not take advantage of short-term gains or may experience
more volatility over the life of the portfolio.
Short-Term Strategy - A short-term strategy may incur more trading and brokerage costs and runs the
risk that certain anticipated market movements do not occur, resulting in the client holding a security for
longer than intended.
Your accounts are managed separately with your underlying investment strategies, restrictions, or
investment limitations defined within the investment management agreement.
POTENTIAL RISKS
Investing involves different levels of risk that can result in loss of any profits and/or principal you have not
realized. We manage your account in a manner consistent with your pre-determined risk tolerance and
suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in securities
involves the risk of loss clients should be prepared to bear.
Investing involves the assumption of risk, including:
Financial Risk: This is the risk that the companies we recommend to you perform poorly, which affect the
price of your investment.
Market Risk: This is the risk that the stock market will decline, decreasing the value of the securities we
recommend to you with it.
Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns
associated with the stock.
Political and Governmental Risk: This is the risk that the value of your investment will is affected by the
introduction of new laws or regulations.
Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if
interest rates rise.
Call Risk: This is the risk that your investment will be called or purchased back from you when conditions
are favorable to the bond issuer and unfavorable to you.
Default Risk: This is the risk that the issuer is unable to pay the contractual interest or principal on the
investment promptly or at all.
Manager Risk: This is the risk that an actively managed mutual fund’s investment adviser will fail to
execute the fund’s stated investment strategy.
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Industry Risk: This is the risk that a group of stocks in a single industry will decline in price due to adverse
developments in that industry, decreasing the value of mutual funds that are significantly invested in that
industry.
ITEM 9 Disciplinary Information
As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events
related to past or present investment clients. There has been no disciplinary, legal, or regulatory events
related to us or any of our management persons.
ITEM 10 Other Financial Activities and Affiliations
FINANCIAL INDUSTRY ACTIVITIES
Stephen Engels and James Pacholek are both registered representatives with Purshe Kaplan Sterling
Investments, a member of FINRA/SIPC. They both are licensed to sell securities. As registered
representatives of an unaffiliated broker-dealer, They may earn additional compensation in the form of
commissions for the sale of general securities products such as stocks, bonds, mutual funds, exchange-
traded funds, and a variable annuity to investment advisory clients. As such, your IAR may suggest that
you implement investment advice by purchasing securities products through a commission-based account
introduced through our unaffiliated broker-dealer in addition to an investment advisory account. In the
event that you elect to purchase these products through our unaffiliated broker-dealer, your investment
adviser, in the capacity as a registered representative, and our unaffiliated broker-dealer will receive the
standard and customary commission compensation in connection with the particular product purchased.
Neither CMG nor its management persons are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or commodity trading advisor.
AFFILIATIONS
Certain associates of the firm are also insurance agents licensed to sell insurance products. A conflict of
interest exists in that these services pay a commission, which conflicts with the IAR’s fiduciary duties. CMG
does not require its IARs to encourage clients to implement investment advice through our insurance
product recommendations. Clients have the right to implement insurance product recommendations
through the insurance agency and agent of their choice. We require that all IARs disclose this conflict of
interest when such recommendations are made. We also require IARs to disclose that the client has the
right to purchase recommended products from individuals not affiliated with us.
SELECTION OF OTHER INVESTMENT ADVISERS
We do not recommend or select other investment advisers for our clients.
ITEM 11 Code of Ethics, Participation in Client Transactions and
Personal Trading
CODE OF ETHICS
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CMG has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must
act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an
investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely
in the best interest of each of our clients at all times. CMG has a fiduciary duty to all clients. This fiduciary
duty is considered the core underlying principle of our code of ethics, which also covers our insider trading
and personal securities transactions policies and procedures. We require all of our supervised persons to
conduct business with the highest level of ethical standards and to comply with all federal and state
securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised
persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics.
Our Code of Ethics is available to clients and prospective clients upon request.
RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST
Neither we nor any related person recommend to clients or buys or sells for clients’ accounts, securities
in which we or a related person has a material financial interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
There may be instances where an IAR will recommend to investment advisory clients or prospective clients
the purchase or sale of securities in which an IAR, its affiliates, or other clients may also have a position
or interest. Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution
costs equally. Completed trade orders will be allocated according to the instructions from the initial trade
order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in
the trade order.
PERSONAL TRADING
Employees are permitted to have personal securities accounts as long as personal investing practices are
in line with fiduciary standards and regulatory requirements, and do not conflict with their duty to CMG
and our clients. CMG monitors and controls personal trading through pre-approval of all personal
securities transactions or blackout periods imposed upon employees trading in the same securities as
CMG. We forbid any officer or employee, either personally or on behalf of others, to trade on material,
nonpublic information, or to communicate such information to others in violation of the law.
ITEM 12 Brokerage Practices
CMG currently has arrangements with Charles Schwab & Co, Inc. (“Schwab”). Schwab is the unaffiliated
qualified custodian, whereby CMG would suggest you custody your accounts. Schwab is an independent
SEC-registered broker-dealer and a member of FINRA and SIPC.
As a fiduciary, we are obligated to seek out the best execution of client transactions for that accounts that
we manage. In general, the execution of securities transactions is at a total cost to process each
transaction and are the most favorable under the circumstances. However, we do not limit the best
execution to the lowest available price. Additional factors are taken into consideration when determining
the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review
consists of reviewing the commission and fee structures of various broker-dealers, research platforms,
and execution services. Accordingly, while we consider competitive rates, we do not necessarily obtain
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the lowest possible commission rates for account transactions. Therefore, the overall services provided
by unaffiliated broker-dealers and qualified custodians are evaluated to determine the best execution.
You may pay trade execution charges and higher commissions through the trading platforms approved by
us than through platforms that have not been approved by us.
RESEARCH AND OTHER SOFT DOLLAR BENEFITS
Products & Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent
investment advisory firms like ours. They provide our clients and us with access to its institutional
brokerage – trading, custody, reporting, and related services – many of which are not typically available
to Schwab retail customers. Schwab also makes available various support services. Some of those services
help us manage or administer our clients’ accounts while others help us manage and grow our business.
Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as
we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab.
Services that Benefit Client
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access, or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Schwab also makes available to us other products and services that benefit us but may not directly benefit
the client or their account(s). These products and services assist us in managing and administering our
clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may
use this research to service all or some substantial number of our clients’ accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
•
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
• provides pricing and other market data;
•
facilitates payment of our fees from our clients’ accounts; and
•
assists with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• educational conferences and events
•
technology, compliance, legal, and business consulting;
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• publications and conferences on practice management and business succession; and
•
access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab may also discount or waive its fees for some of these services or pay
all or a part of a third party’s fees.
Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s
experience, help reach their goals, and put their interests before that of our firm or its associated persons.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals from broker-dealers.
DIRECTED BROKERAGE
We do not recommend, request, require, or permit clients to direct us to executed transactions through
a specific broker-dealer other than those we recommend.
TRADE AGGREGATION
We attempt to allocate trade executions in the most equitable manner possible, taking into consideration
current asset allocation and availability of funds using price averaging, proration, and consistently non-
arbitrary methods of allocation. We may aggregate orders in order to obtain best execution, to negotiate
more favorable commission rates, or to allocate equitably among our clients’ differences in prices and
commission or other transaction costs. In aggregated orders, transactions will be price-averaged and
allocated among our clients in proportion to the purchase and sale orders placed for each client account
on any given day.
ITEM 13 Review of Accounts
PERIODIC REVIEWS
We review asset management accounts as frequently as requested by our clients but no less than
annually. These accounts will be reviewed by Stephen M. Engels. Accounts are reviewed to evaluate asset
allocation, investment strategy and objectives, cash balance, and performance as well as the general
economic outlook and current investment trends.
REVIEW TRIGGERS
We conduct periodic reviews to evaluate the current market, economic and political events and how these
may affect client accounts. Additional reviews may be triggered by these events or by events in the client’s
financial or personal status.
REGULAR REPORTS
Asset management clients will receive advisory account statements no less than quarterly. These
statements show asset value by cash balances, security, unit cost, total cost, current per share values, etc.
Clients are urged to review the quarterly statements provided by us with those provided by their
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custodian and notify us of any differences. Clients are encouraged to phone or email us as often as they
deem necessary to receive information regarding the investment tactics and strategies being followed.
ITEM 14 Client Referrals and Other Compensation
Please see Item 12 Brokerage Practices for information regarding the benefits we receive from our
custodian.
We do not pay, nor do we receive compensation to refer clients to third parties.
ITEM 15 Custody
We are deemed to have custody of client funds and securities due to our ability to deduct management
fees from clients’ accounts. We will not take physical custody of clients’ funds and will not assign or
transfer trading authorization to another advisor. Clients will receive account statements from the
qualified custodian(s) holding their funds and securities at least quarterly. The custodian’s account
statements will indicate the amount of our advisory fees deducted from the clients’ account(s) each billing
period. The client should carefully review these statements for accuracy. Item 5 – Fees and Compensation
has additional information regarding our ability to deduct management fees from clients’ accounts.
ITEM 16
Investment Discretion
DISCRETIONARY AUTHORITY FOR TRADING
If you are participating in our asset management services, upon receiving your written authorization via
our executed investment advisory agreement, we will maintain trading authorization over your
designated account and may also implement trades on a discretionary basis.
When discretionary authority is granted, we will have the limited authority to determine the type of
securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or
exchanged for your portfolio without obtaining your consent for each transaction.
If you do not grant this limited investment discretion, your IAR will be required to contact you and get
affirmation regarding our investment recommendations, such as the security being recommended, the
number of shares, whether the security should be bought or sold before implementing changes in your
account.
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your accounts
are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a
response to our request immediately, the timing of trade implementation may lead to an adverse impact
where we may not achieve the optimal trading price.
On a case by case basis, you may place reasonable restrictions on the types of investments that may be
purchased or sold in your account so long as the restrictions are explicitly set forth or included as an
attachment to the investment advisory agreement.
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ITEM 17 Voting Client Securities
We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account.
The responsibility for voting your securities places increased liability to us and does not add enough value
to the services provided to you to justify the additional compliance and regulatory costs associated with
voting your securities.
Therefore, you are responsible for voting all proxies for securities held in accounts managed by us.
Typically, our qualified custodian will forward you your proxy information. Although we do not vote your
proxies, you can contact us if you have a question about a particular proxy.
ITEM 18 Financial Information
We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a
financial condition that is reasonably likely to impair our ability to meet contractual commitments to our
clients.
We are currently not in, nor have been historically in a financially precarious situation or the subject of a
bankruptcy petition.
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