Overview
Assets Under Management: $180 million
Headquarters: ROSWELL, GA
High-Net-Worth Clients: 66
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (COMMONWEALTH FINANCIAL PLANNERS, INC. - PART 2)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
Number of High-Net-Worth Clients: 66
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 82.62
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 311
Discretionary Accounts: 4
Non-Discretionary Accounts: 307
Regulatory Filings
CRD Number: 106831
Last Filing Date: 2024-03-27 00:00:00
Website: https://raymondjames.com
Form ADV Documents
Additional Brochure: COMMONWEALTH FINANCIAL PLANNERS, INC. - PART 2 (2025-10-17)
View Document Text
Form ADV Part 2A: Disclosure Brochure
CommonWealth Financial Planners, Inc.
CRD # 106831
1033 Canton Street
Roswell, GA 30075
Phone: 770-399-6644
Website: www.commonwealthfp.com
October 2025
This brochure provides information about the qualifications and business practices of CommonWealth
Financial Planners, Inc (CWFP). If you have any questions about the contents of this brochure, please
contact us at 770-399-6644. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (SEC) or by any state securities authority.
Additional information about CommonWealth Financial Planners, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov.
CommonWealth Financial Planners, Inc. is a registered investment adviser. Registration with the SEC or
any state securities authority does not imply a certain level of skill or training.
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Item 2 - SUMMARY OF MATERIAL CHANGES
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the
adviser is required to notify you and provide you with a description of the material changes. A copy of the
complete ADV Part 2 is available at www.adviserinfo.sec.gov.
One may also be requested from our office at 770-399-6644.
This Brochure dated September 30, 2025, contains the following material changes since our last annual
amendment dated March 27, 2024:
•
Introduction of the Ambassador Program – CWFP has added Ambassador, a wrap fee program
sponsored by Raymond James & Associates, Inc. (RJA), as an advisory service offering. Under
Ambassador, clients pay a single asset-based fee covering advisory services, certain brokerage
transactions, and custodial services. Clients participating in Ambassador will also receive RJA’s
Wrap Fee Program Brochure.
• Status of IMPAC Accounts – While existing clients may continue to utilize the Investment
Management Program for Advisory Clients (“IMPAC”), CWFP is no longer opening new IMPAC
accounts for new clients.
• Affiliations with Raymond James – CWFP has clarified our affiliation with Raymond James
Financial Services, Inc. (RJFS) and Raymond James & Associates, Inc. (RJA) in connection with
Ambassador. These affiliations create potential conflicts of interest because CWFP may have an
incentive to recommend programs and products available on the Raymond James platform. CWFP
addresses these conflicts through disclosure, supervision, and our fiduciary duty to act in the best
interest of our clients.
• CWFP has clarified our description of client investment restrictions under Item 4 to emphasize that
clients in non-discretionary accounts retain full authority over all investment decisions.
• Review of Accounts – CWFP has clarified our description of review of accounts to include all
investment advisor representatives. All advisory clients receive confirmations and statements
directly from the custodian, however only IMPAC advisory clients are provided with a portfolio
summary on a quarterly basis.
No other material changes have occurred since the last amendment.
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Item 3 - TABLE OF CONTENTS
DESCRIPTION PAGE
Item 1 - COVER PAGE ................................................................................................................................. 1
Item 2 - SUMMARY OF 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 ........................................ 9
Item 7 - TYPES OF CLIENTS ....................................................................................................................... 9
Item 8 - METHODS OF ANALYSIS AND INVESTMENT STRATEGIES AND RISK OF LOSS .................. 9
Item 9 - DISCIPLINARY ACTION ............................................................................................................... 12
Item 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................... 12
Item 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING ............................................................................................................................... 14
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 ...................................................................................................... 16
Item 17 - VOTING CLIENT SECURITIES ................................................................................................... 16
Item 18 - FINANCIAL INFORMATION ........................................................................................................ 16
ADDITIONAL INFORMATION .................................................................................................................... 17
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Item 4 - ADVISORY BUSINESS
Firm Description
CommonWealth Financial Planners, Inc. (CWFP) was founded in 1983 by Norman D. Shirley CFP®. Mr.
Shirley retired from the firm in August of 2019. Michael P. Agurkis CFP® is the principal owner of the firm.
Mr. Agurkis is a Registered Principal and Branch Manager with Raymond James Financial Services, Inc.
(RJFS). RJFS is an affiliate of Raymond James Financial, Inc., and a member of the Financial Industry
Regulatory Authority (FINRA)/Securities Investor Protection Corporation (SIPC).
CWFP provides personalized financial planning and investment management services to individuals,
pension and profit-sharing plans, corporations, and small businesses. CWFP's services are specifically
tailored to the individual needs of its clients. After thorough consultation, client objectives and risk tolerance
are determined, then CWFP advisers provide advisory services which may include, cash flow management,
tax planning, insurance review, investment management, education funding, retirement planning, and
estate planning. CWFP does not act as a custodian of client assets. Should client's financial plan indicate
certain investments be made to satisfy a certain need such as college funding investments, insurance
needs, or other appropriate investment vehicle, CWFP offers non-discretionary investment strategies
through RJFS. Clients may impose reasonable restrictions on investing in certain securities or types of
securities within their accounts. In non-discretionary accounts, clients retain full authority over all investment
decisions, and no transactions are executed without their prior approval. CWFP will provide
recommendations consistent with the client’s investment objectives and any expressed restrictions, but the
final decision to purchase or sell any security rests solely with the client.
The vast majority of CWFP's compensation is earned through its fee-based investment advisory services.
CWFP currently utilizes two types of advisory programs. The first is the Investment Management Program
for Advisory Clients (“IMPAC”); this account established with Raymond James & Associates, Inc. (RJA or
Raymond James), member of the New York Stock Exchange (NYSE)/SIPC, as custodian offers you the
ability to pay an asset based advisory fee and a nominal transaction fee in lieu of a commission for each
transaction. IMPAC remains available for existing clients who already utilize it, however beginning
September 2025, CWFP is not opening new IMPAC accounts for new clients. Existing accounts will
continue to be serviced consistent with their agreements. The second is Ambassador, a wrap fee program
sponsored and administered by Raymond James & Associates, Inc. (RJA). This is an advisory service
offering, where clients pay an asset-based advisory fee that covers advisory services, certain transaction
costs, and custodial and administrative services. Clients receive ongoing advice and monitoring, and will
also receive RJA’s Wrap Fee Program Brochure that describes services, fees, and program features. The
overall cost of participating in a wrap program may be higher or lower than paying for services separately.
CWFP receives a portion of the advisory fee from either program.
From time-to-time CWFP may earn compensation from furnishing advice outside its fee-based investment
supervisory services.
As of December 31, 2024, CWFP’s total non-discretionary assets under management totaled
$197,800,000.
CWFP provides discretionary services to its 401(k) plan clients in partnership with RJA as a 3(38)
investment manager. As of December 31, 2024, total discretionary assets under management totaled
$5,000,000 in this 3(38) program. CWFP provides ERISA fiduciary services to certain retirement plans,
such as 401(k) plans, described within section 3(38) of ERISA. When doing so, CWFP will assume an
investment manager fiduciary role for you as it relates to the sub-advisor selection and the offering of a
varied menu of plan investment options. The sub-advisor will also acknowledge appointment of its fiduciary
obligation as an “Investment Manager”, as contemplated in Section 3(38) of ERISA, and will provide you
with an investment policy statement and make investment decisions.
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Item 5 - FEES AND COMPENSATION
Upon the mutual agreement of CWFP and its client, an advisory agreement is executed by CWFP and its
investment advisory client. The investment advisory client compensates CWFP for investment advisory
services on an annual fee basis. The advisory fee is payable in advance, at the end of each quarter. Client
receives statements, at least quarterly, from RJFS that will reflect the advisory fee paid to CWFP. Client
should verify the accuracy of fees paid.
Annuities that were charged a commission are not included as billable assets in the calculations of advisory
fees for advisory clients, however certain eligible variable annuities that were not charged a commission
will be considered for inclusion in the account value on which the advisory fee is assessed.
Clients may terminate the advisory agreement at any time by written notice. There is no penalty for
terminating your agreement. If the advisory relationship terminates on a date other than the end of the
specified billing period, fees are prorated and an adjustment is made; any prepaid fees are refunded to the
client. Closing an account does not affect the client’s or CWFP’s responsibilities for previously initiated
transactions or for balances due in the account.
Investment Advisory Clients - Ambassador
CWFP offers the Ambassador Program to its clients. The Ambassador program is a wrap fee investment
advisory account offered and administered by Raymond James & Associates ("RJA"). The Asset
Management Services (“AMS”) division of RJA provides a variety of support services to the various wrap-
fee programs including, but not limited to fee-billing, model portfolio implementation, portfolio management,
due diligence, and financial advisor support. CWFP does not sponsor or serve as a portfolio manager to a
wrap fee program. CWFP will manage your account on a nondiscretionary basis according to your objective.
Ambassador offers you the ability to pay an asset-based advisory fee which includes transaction costs
within the advisory fee, in lieu of a commission for each investment transaction within the account. CWFP
receives a portion of the fee. This type of account can be utilized to buy, sell or otherwise trade stocks,
bonds, mutual funds (at net asset value), exchange traded funds, options and preferred stocks. There are
no transaction charges in Ambassador accounts. For further information, refer to the RJA Wrap Fee
Program Brochure.
Asset-based Fee Schedule
The minimum investment is $25,000 for Ambassador accounts.
The annual asset-based fee is paid quarterly in advance. When an account is opened, the asset-based fee
is billed for the remainder of the current billing period and is based on the initial contribution. Thereafter,
the quarterly asset-based fee is paid in advance, is based on the account asset value on the last business
day of the previous calendar quarter and becomes due the following business day. Client authorizes and
directs RJA as Custodian to deduct asset-based fees from the Client's account. Client understands that the
brokerage statement will show the amount of the asset-based fee. We may make accommodation
according to our billing procedures based on your specific request, from time to time under limited
circumstances, subject to our sole discretion.
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Special Billing Procedure for Deposits or Withdrawals of $100,000 or More:
In the first two months of the quarter, we will:
(i) Assess the Fee based on the billable capital addition amount on the date of deposit for the pro rata
number of days remaining in the quarter, or
(ii) Refund the prepaid Fee based on the Account Value on the date of withdrawal of billable cash or
securities for the pro rata number of days remaining in the quarter.
During the last month of the quarter, no additional Fees or adjustments to previously assessed Fees will be
made in connection with deposits or withdrawals that occur during the last month of the quarter unless at
your request, subject to approval by AMS.
For mutual funds that provide RJFS with a 12b-1 fee, that fee is credited to the client account as a fee offset.
Such mutual fund related fees are paid only when provided in the mutual fund's prospectus. As a registered
representative of RJFS, our IARs do not receive any part of these payments. Mutual funds may, from time
to time, direct trades through RJFS as consideration for the broker/dealer processing mutual fund
transactions for you. You may also incur charges for other account services provided by RJA not directly
related to the execution and clearing of transactions. These include: IRA custodial fees, safekeeping fees,
interest charges on margin loans, and fees for legal or courtesy transfers of securities.
The annual advisory fees charged in the Ambassador programs are in addition to the management fees
and operating expenses charged by open-end, closed-end and/or exchange traded funds. If you intend to
hold fund shares for an extended period of time, it may be less expensive for you to purchase fund shares
outside of these programs. You may be able to purchase mutual funds directly from the respective fund
families without incurring our advisory fee.
Shares of certain mutual funds offered in these programs may impose short-term trading charges (typically
1% - 2% of the amount originally invested) for redemptions made within a short period of time. These short-
term charges are imposed by the mutual funds (and not RJFS or AWM) to deter "market timers" who trade
actively in the fund's shares. These charges, operating expenses and management fees may increase the
overall cost to the client by 1%-2% (or more) and are detailed in each fund's prospectus.
Administrative-only Assets
Certain securities may be held in your Ambassador account and designated "Administrative-Only
Investments". There are two primary categories of Administrative-Only Investments: Client-designated and
Raymond James-designated. Client-designated Administrative-Only Investments may be designated by
our firm should we decide not to collect an advisory fee on certain assets, while Raymond James-
designated Administrative-Only Investments are designated by Raymond James in conformance with
internal policy. For example, we may make an arrangement with a client that holds a security that we did
not recommend or the client wishes to hold for an extended period of time and does not wish for us to sell
for the foreseeable future. In such cases we may elect to waive the advisory fee on this security, but allow
it to be held in the client's advisory account – such designations fall into the Client-designated category.
Alternatively, Raymond James may determine that certain securities may be held in an advisory account
but are temporarily not eligible for the advisory fee (such as for mutual funds purchased with a front-end
sales charge through Raymond James within the last two years, new issues and syndicate offerings).
Assets designated by Raymond James as temporarily exempt from the advisory fee fall into the Raymond
James-designated category.
Administrative-Only Investments will not be included in the Account Value when calculating applicable
asset-based advisory fee rates. For example, a client whose Ambassador account holds $750,000 of cash
and securities that includes $150,000 of Administrative-Only Investments will only have the asset-based
fee rate assessed based on the $600,000 Account Value. For clients with multiple fee-based accounts, the
Relationship Value will be used to determine the applicable fee rate that will be assessed. However, clients
should understand that any assets held as Administrative-Only Investments will not be included in the
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Relationship Value. Please see the "Aggregation of Related Fee-Based Account" section for additional
information on how Raymond James combines related accounts for fee billing purposes.
Billing on Cash Balances
Raymond James will assess advisory fees on cash sweep and foreign currency balances ("cash") held in
Ambassador accounts. If the cash balance exceeds 20% of the Account Value as of the last business day
of the quarter ("the valuation date") for three (3) consecutive quarterly valuation dates, the amount in excess
of 20% is excluded from billing. For example, an Ambassador account that held 30% of the Account Value
for three (3) consecutive billing valuation dates (March 31st, June 30th, and September 30th) would have
the amount in excess of 20% excluded from the Account Value in which advisory fees are applied. For
simplicity of illustration, assuming an account was valued at $100,000 for all three (3) quarterly billing
periods, with $30,000 held in cash, the September 30th valuation date would exclude $10,000 of the cash
from the Account Value when assessing the advisory fee.
This fee billing provision (or "Cash Rule") is intended to equitably assess advisory fees to client assets for
which an ongoing advisory service is being provided; the exclusion of excess cash from the advisory fee is
intended to benefit clients holding substantial cash balances (as a percentage of the total individual Account
Value) for an extended period of time. Clients should understand that the portion of the account held in
cash will experience negative performance if the applicable advisory fee charged is higher than the return
received on the cash sweep balance.
The Cash Rule may pose a financial disincentive to a financial advisor as the portion of cash sweep
balances in excess of 20% will be excluded from the asset based fee charged to the account. This may
cause a financial advisor to reallocate a client account from cash to advisory fee eligible investments,
including money market funds, or to recommend against raising cash, in order to avoid the application of
this provision and therefore receive a fee on the full account value. Clients may direct their financial advisor
to raise cash by selling investments or hold a predetermined percentage of their account in cash at any
time. The Cash Rule is applicable only to cash sweep and foreign currency balances and, therefore,
nonsweep money market funds would not result in excess "cash" balances being excluded from the asset
based advisory fee calculation. Within the Ambassador accounts, the Cash Rule applies on an individual
account basis. Your financial advisor may receive more compensation by not applying the Cash Rule at the
household level and instead electing to do so at the account level.
Investment Advisory Clients - Investment Management Program for Advisory Clients (“IMPAC”)
IMPAC is a fee-based account, administered through RJFS, which offers you the ability to pay an advisory
fee on the assets in your account and a nominal $15.00 transaction charge in lieu of a commission for each
transaction, with the exception of certain fund purchases described below. IMPAC is a legacy program that
is no longer offered to prospective clients. IMPAC accounts are billed an asset-based advisory fee quarterly.
The fee is based upon the total asset value of the account at the end of each quarter and is deducted from
the client’s account by the custodian. Fees are negotiable and do not exceed 1.50% annually. Please refer
to your advisory agreement or speak with your advisory representative for questions about your current fee.
When an account is opened and funded, the asset-based fee is billed for the remainder of the current billing
period. Please note that while fees for household accounts are determined separately and incrementally, a
client may request individual totals be aggregated and charged to an alternate advisory account for said
client. CWFP requests all clients allow for the direct deduction of fees, but for those clients that do not,
CWFP will send an invoice directly to the client for CWFP’s advisory fees. This invoice will require payment
within thirty days after the mailing date on the invoice.
Effective October 1, 2018, Raymond James will assess advisory fees on cash sweep balances (“cash”)
held in IMPAC accounts, provided the cash balance does not exceed 20% of the total account value. If the
cash balance is greater than 20% of the account value as of the last business day of the quarter (the
“valuation date”), Raymond James will bill on the full cash balance provided cash did not comprise greater
than 20% of the billable account value for three (3) consecutive quarterly valuation dates. If the cash
balance exceeded 20% of the account value for three (3) consecutive quarterly valuation dates, the amount
in excess of 20% is excluded from billing. For example, an IMPAC account that held 30% of the account
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value in cash for three (3) consecutive billing valuation dates (March 31st, June 30th, and September 30th)
would have the amount in excess of 20% cash excluded from the account value in which advisory fees are
applied. For simplicity of illustration, assuming an account was valued at $100,000 for all three (3) quarterly
billing periods, with $30,000 held in cash, the September 30th valuation date would exclude $10,000 of the
cash from the account value when assessing the advisory fee.
This fee billing provision (or “Cash Rule”) is intended to equitably assess advisory fees to client assets for
which an ongoing advisory service is being provided; the exclusion of excess cash from the advisory fee is
intended to benefit clients holding substantial cash balances (as a percentage of the total individual account
value) for an extended period of time. Clients should understand that the portion of the account held in cash
will experience negative performance if the applicable advisory fee charged is higher than the return
received on the cash sweep balance.
The Cash Rule may pose a financial disincentive to a financial advisor as the portion of cash sweep
balances in excess of 20% will be excluded from the asset based fee charged to the account. This may
cause a financial advisor to reallocate a client account from cash to advisory fee eligible investments,
including money market funds, or to recommend against raising cash, in order to avoid the application of
this provision and therefore receive a fee on the full account value. The Cash Rule is applicable only to
cash sweep balances and, therefore, non-sweep money market mutual funds and certificates of deposit
would not result in excess “cash” balances being excluded from the asset based advisory fee calculation.
RJFS, as introducing broker, shall facilitate the maintenance of custody of securities positions for the
Account through RJA, including holding securities in nominee name and crediting interest and dividends
received on said securities to Client’s Account, and facilitate the clearing of securities transactions through
RJA. Adviser will compensate RJFS and/or RJA (together, as introducing broker and clearing broker,
respectively “Raymond James”) to provide various administrative services.
Select fund companies (“Participating Funds”) have agreed to pay RJFS administrative fees. For certain
mutual fund purchases, RJFS may use such fees to credit back the transaction fee charged to clients’
accounts, as required by applicable law. Select fund companies have agreed to pay marketing service and
support fees to RJFS (“Partner Funds”). “Non-Partner Funds” do not participate in RJFS’s Education and
Marketing Support program. Transaction fees are applied to purchases of Partner and Non-Partner Funds.
The transaction fee for Non-Partner Fund purchases (excluding those Non-Partner Fund purchases made
in certain tax-deferred vehicles, e.g. IRAs, which will be subject to the $15.00 fee noted above) is $40.00.
Please note that funds may change their Participating, Partner or Non-Partner status at any time; you
should consult with your Investment Adviser Representative to verify the funds’ status periodically. You
may request a list of Participating Funds and Partner Funds from your Investment Adviser Representative
or visit:
https://www.raymondjames.com/legal-disclosures/packaged-product-disclosures/mutual-fund-investing-
at-raymond-james/networking-and-service-partners
There are no transaction fees for mutual fund redemptions. Account types exempt from transaction fees
are ERISA accounts (401(k), PSP, MPP), SIMPLE IRA, SARSEP IRA, SEP IRA, 403(b), 457 plans, 529
plans, and DVP accounts.
Client should understand that the adviser will not share in any transaction charges paid by the client to
RJFS. These charges are not commissions but are charged solely to defray the expenses incurred in
facilitating the execution and clearing of clients’ portfolio transactions. More information regarding
brokerage practices can be found in Item 12 - Brokerage Practices of this document.
401(k) Advisory Clients
As 3(38) investment manager of our 401(k) business, we receive an annual advisory fee as agreed upon
by CWFP and each individual plan sponsor. The fee is payable monthly based on the invested assets on
the last business day of the month.
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Financial Planning Clients
There are some clients who only request financial planning advice, including but not limited to, financial
goal setting, education funding, cash flow analysis, insurance needs, and estate planning. An hourly fee is
charged for this type of service and billed upon the completion of the plan. The rate for this service is
currently $175 an hour.
After a financial plan is completed, clients have the option to purchase any investment products
recommended through their own broker or agent who is not affiliated with CWFP.
Item 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
CWFP does not charge performance-based fees (fees based on gains) and so none of CWFP’s clients’
accounts will ever be managed side-by-side any performance-based accounts.
Performance-based fee arrangements involve the payment of fees based on a share of capital gains or
capital appreciation of a client’s account. 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.
For further information regarding compensation, refer to Item 12 - Brokerage Practices and Item 14 - Client
Referrals and other Compensation.
Item 7 - TYPES OF CLIENTS
CWFP serves two types of clients: investment advisory account clients and financial planning clients.
CWFP provides investment advisory services to individuals, pension and profit sharing plans, corporations,
and small businesses. The minimum relationship size for opening and maintaining an investment advisory
account with CWFP is $500,000; however, CWFP has the discretion to revise its minimum based on the
prospective client's situation.
Financial Planning clients may only want financial planning advice regarding retirement and/or education
funding, estate planning, insurance needs or cash flow analysis. An hourly fee is charged for this kind of
service and the client is billed upon completion. The rate for this service is currently $175 an hour. After
the financial plan is completed, clients have the option to purchase any investment products recommended
through their own broker or agent who is not affiliated with CWFP.
Item 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
Investing in securities involves risk of loss that clients should be prepared to bear. CWFP employs various
methods of analysis and investment strategies. These methods of analysis include, but are not limited to
fundamental, charting, technical and cyclical data obtained from financial newspapers and magazines,
inspections of corporate activities, research materials prepared by others, corporate rating services, annual
reports, prospectuses, filings with the SEC and company press releases.
Investment strategies used to implement any investment advice given to clients may include long-term
purchases (securities held for at least a year), short-term purchases (securities sold within a year), margin
instructions, and option writing, including covered options or uncovered options.
Investment strategy is determined for the client based upon the objectives stated during consultations with
CWFP where we review investment objectives, risk tolerance, tax objectives, and liquidity needs before
choosing an investment strategy.
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All investments carry a certain degree of risk and no one particular investment style is suitable for all types
of investors.
Methods of Analysis and Investment Strategies
CWFP may use one or more of the following methods of investment analysis:
Fundamental Analysis involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience and expertise
of the company’s management, and the outlook for the company’s industry. The resulting data is used to
measure the true value of the company’s stock compared to the current market value. The risk of
fundamental analysis is that the information obtained may be incorrect and the analysis may not provide
an accurate estimate of earnings, which may be the basis for an investment’s value. If securities prices
adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance.
Charting Analysis involves the gathering and processing of price and volume information for a particular
security. This price and volume information is analyzed using mathematical equations. The resulting data
is then applied to graphing charts, which is used to predict future price movements based on price patterns
and trends. The risk of market timing based on technical analysis is that charts may not accurately predict
future price movements. Current prices of securities may reflect all information known about the security
and day to day changes in market prices of securities may follow random patterns and may not be
predictable with any reliable degree of accuracy.
Technical analysis involves studying past price patterns and trends in the financial markets to predict the
direction of both the overall market and specific stocks.
Cyclical Analysis is a type of technical analysis that involves evaluating recurring price patterns and trends.
The risk of market timing based on technical analysis is that charts may not accurately predict future price
movements. Current prices of securities may reflect all information known about the security and day to
day changes in market prices of securities may follow random patterns and may not be predictable with
any reliable degree of accuracy.
Sources of information may include Raymond James Research, financial publications, research materials
prepared by others, corporate rating services, annual reports, prospectuses and filings with the SEC.
Since investment goals and financial circumstances change over time, CWFP recommends reviewing the
client’s investment program at least annually. The client may change objectives at any time.
Risk of Loss
All investment programs have certain risks that are borne by the investor. Investors face the following
investment risks:
Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market values to
decline.
Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible
events and conditions. This type of risk is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social conditions may trigger market
events.
Business Risk: These risks are associated with a particular industry or a particular company within an
industry. For example, oil-drilling companies depend on finding oil and then refining it. This is a lengthy
process before they can generate a profit. They carry a higher risk of profitability than an electric company
whose income is from a steady stream of customers who buy electricity no matter what the economy is like.
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Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability,
because the company must meet the terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market
value.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next
year, because purchasing power erodes at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuation in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (for example, interest rate). This primarily relates to fixed income securities.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more
liquid if many traders are interested in a product. For example, Treasury Bills are highly liquid while real
estate properties are not.
If a client is considering small-cap investments or objectives in which a portion or all of the client’s assets
are invested in small-cap investments, they should recognize the securities selected within these
investments may not have the business experience or may have businesses that are still in the early stages
of the business life cycle, may be less liquid, have lower trading volume and greater spreads between the
purchase price and sale price of the securities, and may experience greater volatility than securities with
larger market capitalizations. The securities selected for small-cap disciplines will typically be more
speculative in nature and thus have greater potential for the loss of principal.
If a client is considering an international or global investment discipline, in which a portion or all of their
assets are invested in international securities, the client should recognize that investing in international
securities markets involves additional risks not associated with domestic securities. Exchange rate
fluctuations, currency controls, political and economic stability, and great volatility are risks commonly
associated with international investing.
Clients considering a fixed income investment generally want consistent returns with low risk, and their
tolerance for risk/volatility will accept only infrequent, minimal losses. Because of the less volatile nature
of fixed income investment disciplines, a fixed income investor may have a shorter investment time horizon.
If a client is considering investments that are primarily high-yield fixed income, collateralized mortgage
obligations (CMOs), asset-backed and/or convertible securities, the client should be aware that additional
risks exist with these types of investments. These securities may be rated below investment grade or not
rated, which reflects the greater possibility that the financial condition of the issuer, or adverse changes in
economic conditions, may impair the ability of the issuer to pay income and principal.
Periods of rising interest rates or economic downturns may cause highly leveraged issuers to experience
financial stress, and therefore markets for their securities may become more volatile. AAA-implied rated
CMOs will have more volatility than AAA-rated Treasuries or corporate bonds during periods of rising
interest rates because of negative convexity - slowing prepayments causing increased duration, or
extension risk. CMOs may not be appropriate for some investors, especially if timing of return of principal
is a primary concern. The yield and average life of a CMO will fluctuate, depending on the actual
prepayment experiences and changes in current interest rates. For example, a rise in interest rates may
cause the duration and average life of a CMO to greatly increase and cause a loss of value.
A short sale is a sell transaction by a person who believes the price of a security will decline in value, though
that person does not own the security at the time of the sale. The securities are borrowed on the client’s
behalf. Securities sold short must be repurchased at a later date. The value of the shares borrowed and
sold short are deposited with the security lender, and must be executed in a margin account. The shares
may be called back by the lender at any time. If the borrowed shares are recalled and cannot be replaced,
the position may be closed without prior notice. Clients are responsible for any dividend payments as long
11
as the short position remains open in their account. Eventually the short sale must be covered by buying
the same amount of borrowed shares for return to the lender. If the shares are able to be repurchased at
a lower price than they were sold for, the profit is the price difference between the initial short sale and
repurchase - not including the charges and/or interest for maintenance of the short position and taxes.
However, if the value of the security increases after the initiation of the short sale, the loss is the price
difference between the repurchase and initial short sale - again, not including the charges and/or interest
for maintenance of the short position and taxes.
Novice investors are advised to avoid short sales because this potentially may result in unlimited losses.
For example, the share price of a security can only fall to zero (i.e. limited profit), but there is no limit to the
amount it can rise (i.e. unlimited loss). Stock exchange and federal regulations govern and limit the
conditions under which a short sale may be made on a national securities exchange.
When clients purchase securities, they may pay for the securities in full or may borrow part of the purchase
price. CWFP clients that choose to borrow funds for purchases must open a margin account with RJFS.
However, approval for a margin account is based on RJFS’s analysis of, among other things, the client’s
creditworthiness and the suitability of margin use by the client.
It is important that the client fully understand the risks involved in trading securities on margin before
engaging in this activity. Upon approval, where applicable, client will receive a Truth In Lending Statement
from RJFS disclosing such risks, as well as explaining the details and conditions under which interest will
be charged, the method of computing interest and the conditions under which additional collateral may be
required. Client should understand that the extension of credit by RJFS to clients will appear as a debit
balance on brokerage statements.
An Option is a contract that gives the client the right, but not the obligation, to buy or sell a security at a
specific price (strike price) on or before a certain date (expiration date). An Option, the same as a stock or
bond, is a security and a binding contract. The two types of options available are “calls” and “puts”. A call
option gives the holder the right to buy a security at a certain price within a specific period of time. Buyers
of call options believe that the stock will increase substantially before the option expires, and thereby allow
them the option of buying the security at a price below the current market. A put option gives the holder
the right to sell a security at a certain price within a specific period of time. Buyers of put options believe
that the price of the stock will fall before the option expires, and thereby allow them the option of selling the
security at a price above the current market. People who buy options are called holders and those who
sell options are called writers.
Options involve unique and potentially significant risks and are not suitable for everyone. Option trading
can be speculative in nature and may carry substantial risk of loss. Prior to accepting an account for options
activity, the client will be given the Option Disclosure Document titled “Characteristics and Risks of
Standardized Options” and the client must also complete and submit an Option Agreement and Suitability
Form for review and approval prior to transacting option trades.
Item 9 - DISCIPLINARY ACTION
CWFP has not experienced any legal or disciplinary action. Please see Item 11 - Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
The information in this report is not the only resource you can consult. You can access additional information
about our firm on the SEC’s website, located at www.adviserinfo.sec.gov, as well as FINRA’s website, at
www.finra.org/brokercheck.
Item 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Michael P. Agurkis is a licensed independent insurance agent in Florida, Georgia, Mississippi, North
Carolina, Pennsylvania, and South Carolina. Mr. Agurkis is appointed with numerous insurance companies
12
and receives commission from insurance companies for products purchased through them. When
recommendations or sales are made, a conflict of interest exists as Mr. Agurkis receives commission for
any insurance product purchased through them, which creates an incentive to recommend such products.
However, clients always have the option of purchasing recommended products through their own insurance
agent who is not affiliated with CWFP. Commissionable insurance products are not included as billable
assets in the calculations of advisory fees for advisory clients.
Insurance products are purchased through the Raymond James Insurance Group - a wholly owned
subsidiary of Raymond James Financial, Inc. which acts as a general insurance agent in connection with
the sale of disability, life, and long-term care insurance as well as fixed and variable annuities to individual,
institutional, and corporate clients.
Michael P. Agurkis who provides financial planning advice on behalf of CWFP is a registered representative
of RJFS, a securities broker-dealer, member FINRA/SIPC. In some circumstances, registered
representatives recommend investment products in their capacity as a registered representative. Mr.
Agurkis receives commission-based compensation in connection with the purchase and sale of securities
in a brokerage capacity. Commissions earned by Mr. Agurkis in his capacity as a registered representative
are separate from and may be in addition to financial planning fees. This practice presents a conflict of
interest because persons providing financial planning advice on behalf of CWFP who are registered
representatives have an incentive to effect securities transactions for the purpose of generating
commissions. You are under no obligation, contractually or otherwise, to purchase securities products
through any person affiliated with CWFP.
Securities-Based Lending
In certain circumstances, the client may wish to enter into a loan agreement with Raymond James Bank
N.A. (“RJ Bank”), a wholly-owned subsidiary of Raymond James Financial, Inc. and an affiliate of RJFS
and RJA, and utilize the assets in the client’s investment advisory or other custodial account(s) as collateral
for the loan (also known as “pledging”). In these situations, the loan cannot be used to acquire additional
securities. The client is responsible for independently evaluating whether: (i) the loan is appropriate for their
needs; (ii) the terms on which RJ Bank is willing to lend are acceptable; and (iii) the loan will have adverse
tax, investment, accounting or other implications for the client and the account.
At the client’s election and RJ Bank’s acceptance, securities in the client’s custodial account may be used
as collateral for these loans. RJ Bank may use valuations different than those reflected on brokerage or
other performance statements or for other purposes. As a result, collateral values that RJ Bank provides
may be materially different than the fair value of or other pricing provided by Raymond James on these
securities. Unless otherwise specified, products purchased from or held at Raymond James are not insured
by the FDIC, are not deposits or other obligations of RJ Bank, are not guaranteed by RJ Bank, and are
subject to investment risks, including possible loss of the principal invested.
The fees related to a securities-based loan, are separate from the advisory fees charged to a client’s
account(s). Additionally, RJ Bank compensates Raymond James for the financial advisor’s referral and for
other services performed by Raymond James’ margin department such as, but not limited to, the monitoring
of margin levels, calls, and liquidations as needed. The additional compensation received by Raymond
James, typically shared with the financial advisor, results in a conflict of interest. Clients should explore this
subject thoroughly.
See Item 4 - Advisory Business “Firm Description” and Item 5 - Fees and Compensation for more
information.
13
Item 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
CWFP has a duty of utmost good faith to act solely in the best interest of each of its clients. Clients entrust
CWFP with their funds, which in turn places a high standard on CWFP's conduct and integrity. CWFP's
fiduciary duty compels all employees to act with the utmost integrity. Listed below is CWFP’s Core Code of
Ethics Principles:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
The interest of clients will be placed ahead of the firm's or any employee's own investment
interests.
Employees will strive to avoid any actual or perceived conflict of interest with clients.
Employees will not take inappropriate advantage of their position with the firm.
Employees are expected to act in the best interest of each of our clients.
Employees are expected to comply with federal securities laws.
Employees are expected to exercise diligence and care in maintaining and protecting client's
nonpublic confidential information.
Employees are given a copy of the CWFP Code of Ethics and are required to acknowledge
receipt of and review the Code of Ethics annually.
A copy of CWFP’s Code of Ethics is available to clients upon request.
Employees on occasion (directly for their individual or family accounts) may own, buy and/or sell securities
which CWFP recommends to its clients. In these instances, the client’s accounts are given priority. CWFP
maintains procedures in compliance with the Insider Trading and Securities Fraud Enforcement Act of 1988.
CWFP monitors the personal securities transactions of its representatives and employees.
Item 12 - BROKERAGE PRACTICES
All advisory clients are required to utilize RJA for custody arrangements with RJFS acting as the introducing
broker-dealer. Both RJA and RJFS are wholly owned affiliates of Raymond James Financial, Inc. Michael
P. Agurkis as an Investment Adviser Representative (IAR) with CWFP is a Registered Principal with RJFS,
a registered broker-dealer with the FINRA and member of SIPC and recommends RJFS to advisory clients
for brokerage services. Registered representatives of RJFS are subject to FINRA Conduct Rule 3280 that
restricts them from conducting securities transactions away from RJFS. Therefore, clients are advised that
such IARs are limited to conducting securities transactions through RJFS.
Brokerage transactions are placed only through RJFS. There is an inherent potential conflict of interest in
this arrangement in that CWFP through its IARs who are registered representatives of RJFS may share in
a percentage of the brokerage commissions; however, commission charges paid by clients are not higher
as a result.
Commission charges may vary depending on a number of factors, including but not limited to the type of
security, purchase or sale, secondary market price, volume of trading, and traded or listed exchange. It
may be the case that RJFS charges a higher or lower fee than another broker charges for a particular type
of service, such as transaction fees. CWFP believes that commissions charged by RJFS are competitive
with other full-service broker-dealers and that they are fair and reasonable. Commissions charged by RJFS,
while generally competitive, are not necessarily the lowest in the industry.
Clients may utilize the broker-dealer of their choice and have no obligation to purchase or sell securities
through RJFS. However, if the client does not use RJFS, the IARs will reserve the right not to accept the
account. As a registered FINRA broker-dealer, RJFS routes order flow through its affiliated broker-dealer
RJA. RJA is both a member of the NYSE and a member of the SIPC.
Clients agree to pay RJFS for transaction execution and clearing services based upon a flat fee per
transaction based on the type of security involved. A commission may be charged on the other types of
14
investments that are not being charged an advisory fee. Please refer to Item 5 - Fees and Compensation
for more information.
Clients may also incur charges for other services provided by RJFS, through RJA, not directly related to
the advisory, execution and clearing services provided including, but not limited to, IRA custodial fees,
safekeeping fees, charges/interest for maintenance of margin and/or short positions, and fees for legal or
courtesy transfers of securities.
In certain situations (such as when open-end mutual fund shares are initially transferred to Raymond James
from another firm), the mutual fund share classes that Raymond James makes available to clients on its
platform may, in addition to assessing management fees charge a distribution fee pursuant to Rule 12(b)-
1 under the Investment Company Act of 1940, also known as trails. 12b-1 fees are included in the
calculation of the annual operating expenses of a mutual fund and are disclosed in the fund prospectus.
Where 12b-1 share classes are used, 12b-1 fees are credited bi-monthly to the client’s accounts, after they
are received by Raymond James. However, 12b-1 fees received by Raymond James on share classes that are
not eligible for the advisory fee, such as class C shares designated as Administrative-Only Investments, will not
be credited to the client’s account as described above, but instead will be retained by CWFP.
All mutual funds incur expenses for portfolio management services and fund administrative services. These
internal fees are disclosed in the mutual fund prospectus. The advisory fee charged pursuant to this
agreement will be in addition to mutual fund internal expenses. A portion of the annual advisory fee charged
by the adviser is paid to RJFS for administration of the account.
CWFP will rely on RJFS for the execution of transactions. As such, clients may not receive the lowest price
possible if they were to have their trades placed with another broker. CWFP does not participate in block
trading.
Client should understand that CWFP will not share in any transaction charges paid by the client to RJFS.
These charges are not commissions but are charged solely to defray the expenses incurred in facilitating
the execution and clearing of client’s portfolio transactions. In certain circumstances the actual expense
incurred by RJFS for any given transaction may be less than or greater than the stipulated charge paid by
the client.
Item 13 - REVIEW OF ACCOUNTS
CWFP provides investment advisory services, manages investment advisory accounts, and provides
financial planning advice to its clients. Further information can be found under Item 4 - Advisory Business
“Firm Description.”
Advisory accounts are monitored on a continuous basis. Reviews are conducted on at least an annual basis,
depending upon client requests or the size of a client’s relationship, and in all cases are handled by
investment adviser representatives. A change in personal goals and objectives by the client or significant
change in the market conditions will dictate more frequent reviews. Client may request more frequent
meetings or reviews.
Written financial plans are prepared for planning clients and, upon request, CWFP provides analysis and
annual updates and recommendations for any areas of change. The plan will vary in content according to
the individual client needs. A review and update of client's financial plan is recommended at least annually
or more often given changes in the client's goals, priorities, or financial condition. Reviews and updates
are recommended to the client but conducted upon their request. Recommendations are based on the
information provided by the client and the current economic conditions. Reviews are done by CWFP
investment adviser representatives. CWFP's policy is to attempt to obtain a complete picture of the client's
situation and goals prior to making recommendations.
IMPAC advisory clients are provided with a portfolio summary on a quarterly basis. All advisory clients
receive monthly and/or quarterly account statements from RJFS. Financial planning clients who have
purchased securities through Mr. Agurkis receive account statements directly from the product sponsor at
15
least annually. CWFP recommends clients review their statements carefully and contact CWFP to speak
with Mr. Agurkis regarding any statement discrepancies. Phone number and physical address can be found
under Form ADV Brochure Supplement for Michael P. Agurkis.
Item 14 - CLIENT REFERRALS AND OTHER COMPENSATION
CWFP or its IARs do not have arrangements, oral or in writing, where it is paid cash by or receives some
economic benefit such as commissions, equipment or non-research services from a non-client in
connection with giving advice to their clients. Additionally, CWFP or its IARs are not compensated, nor do
they compensate others, for client referrals. Please refer to Item 5 - Fees and Compensation and Item 12
- Brokerage Practices for further information on compensation.
Item 15 - CUSTODY
We do not have custody (as defined under the Advisers Act) when we provide financial planning and
investment consulting services to you.
For Advisory clients, RJA generally maintains custody of your securities and other assets. For IRA accounts,
Raymond James Trust of New Hampshire is custodian and RJA is sub-custodian. When acting as custodian,
RJA will deliver, not less than quarterly, an account statement to you detailing your account’s securities
holdings, cash balances, dividend and interest receipts, account purchases and sales, contributions and
distributions from the account, and the realized and unrealized gains or losses associated with securities
transactions effected in your account.
RJFS is a registered broker/dealer and is a wholly-owned subsidiary of Raymond James Financial, Inc.
(RJF), a publicly held corporation based in Saint Petersburg, Florida. Michael P. Agurkis is an IAR with
CWFP and a Registered Principal with RJFS, and may recommend RJFS to advisory clients for brokerage
services.
Further information can be found under Item 13 - Review of Accounts.
Item 16 - INVESTMENT DISCRETION
CWFP does not accept discretionary authority to manage securities accounts on behalf of clients with the
exception of 3(38) advisory 401(k) plan clients as detailed under Item 4 - Advisory Business.
Item 17 - VOTING CLIENT SECURITIES
CWFP does not have authority to vote client securities. Clients receive their proxies or other solicitations
directly from their custodian or a transfer agent. CWFP will discuss any proxies they receive with its clients,
should they have questions about the proxy they receive. However, clients retain the right to vote all proxies
solicited for the securities held in their account. Neither CWFP nor RJFS will take any action with respect
to the voting of proxies for clients.
Item 18 - FINANCIAL INFORMATION
CWFP does not require or solicit prepayment of fees for six months or more in advance. There is a
prepayment fee maximum of $1,200.
16
ADDITIONAL INFORMATION
Privacy Policy:
Our Promise to You
As a client of COMMONWEALTH FINANCIAL PLANNERS, INC., you share both personal and financial
information with us. Your privacy is important, and we are dedicated to safeguarding your personal and
financial information.
Information Provided by Clients
In the normal course of doing business, we typically obtain the following non-public personal information
about our clients:
▪ Personal information regarding our clients’ identity such as name, address, and social security
number;
Information regarding securities transactions effected by us; and
▪
▪ Client financial information such as net worth, assets, income, bank account information, and
account balances.
How We Manage and Protect Your Personal Information
We do not sell information about current or former clients to third parties, nor is it our practice to disclose
such information to third parties unless requested to do so by a client or client representative or, if
necessary, in order to process a transaction, service an account, or as permitted by law. Additionally, we
may share information with outside companies that perform administrative services for us. However, our
contractual arrangements with these service providers require them to treat your information as
confidential.
To protect your personal information, we maintain physical, electronic and procedural safeguards. Our
Privacy Policy restricts the use of client information and requires that it be held in strict confidence.
Client Notifications
We are required by law to annually provide a notice describing our privacy policy. In addition, we will
inform you promptly if there are changes to our policy.
17
Form ADV Part 2B: Brochure Supplement
MICHAEL P. AGURKIS, CFP®
CRD # 4969895
CommonWealth Financial Planners, Inc.
CRD # 106831
1033 Canton Street
Roswell, GA 30075
Phone: 770-399-6644
Website: www.commonwealthfp.com
October 2025
This brochure supplement provides information about Michael P. Agurkis (the adviser) that supplements
CommonWealth Financial Planners, Inc.’s brochure. You should have received a copy of that brochure.
Please contact our office at 770-399-6644 if you did not receive CommonWealth Financial Planners, Inc.’s
brochure or if you have any questions about the contents of this supplement.
information about Michael P. Agurkis
is available on
the SEC's website at
Additional
www.adviserinfo.sec.gov.
18
Item 2 - Educational Background and Business Experience
MICHAEL P. AGURKIS, CFP®
Year of Birth: 1982
Educational Background:
• 2005 University of Georgia’s Terry College of Business, Bachelor of Banking and Finance
Business Background:
• Michael joined CommonWealth Financial Planners, Inc. (CWFP) in 2006 where he served as
office manager until 2008. Michael became a registered representative in 2006 with Raymond
James Financial Services, Inc. (RJFS), member FINRA/SIPC and continues in this capacity
today. After completing his CFP training in 2008 he was promoted to Vice-President of CWFP. In
2019, Michael became President of CWFP and Registered Principal and Branch Manager with
RJFS.
Exams, Licenses & Other Professional Designations:
The adviser obtained his CERTIFIED FINANCIAL PLANNER™, designation in 2008.
FINRA Licenses held:
• SIE, Securities Industry Essentials Examination
• Series 7, General Securities Representative Examination
• Series 9/10, General Securities Sales Supervisor Examinations
• Series 66, Uniform Combined State Law Examination
The adviser is a licensed independent insurance agent in the states of Florida, Georgia, Mississippi, North
Carolina, Pennsylvania, and South Carolina.
CERTIFIED FINANCIAL PLANNER® professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc.
has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state
law or regulation requires financial planners to hold the CFP® certification. You may find more information
about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and
complete CFP Board-approved coursework at a college or university through a CFP Board
Registered Program. The coursework covers the financial planning subject areas CFP Board has
determined are necessary for the competent and professional delivery of financial planning services,
as well as a comprehensive financial plan development capstone course. A candidate may satisfy
some of the coursework requirement through other qualifying credentials. CFP Board implemented
the bachelor’s degree or higher requirement in 2007 and the financial planning development
capstone course requirement in March 2012. Therefore, a CFP® professional who first became
certified before those dates may not have earned a bachelor’s or higher degree or completed a
financial planning development capstone course.
19
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is
designed to assess an individual’s ability to integrate and apply a broad base of financial planning
knowledge in the context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards
for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
to remain certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment
to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests
of the client, at all times when providing financial advice and financial planning. CFP Board may
sanction a CFP® professional who does not abide by this commitment, but CFP Board does not
guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain
a written engagement that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 - Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Agurkis. Mr. Agurkis has
never been involved in any regulatory, civil, or criminal action. There have been no lawsuits, arbitration
claims, or administrative proceedings against Mr. Agurkis.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices.
As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mr.
Agurkis. However, we do encourage you to independently view the background of Mr. Agurkis on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name
or his Individual CRD# 4969895.
Item 4 - Other Business Activities
The adviser is licensed as an insurance agent. In this capacity, he can effect transactions in insurance
products for his clients and earn commissions for these activities. The fees you pay our firm for advisory
services are separate and distinct from the commissions earned by the adviser for insurance related
activities. This presents a conflict of interest because the adviser may have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than solely based on your
needs. However, you are under no obligation, contractually or otherwise, to purchase insurance products
through any person affiliated with our firm.
The adviser is a Registered Principal of RJFS, and in this capacity typically is paid commissions on
securities transactions. All commissions are disclosed to clients. The fees you pay our firm for advisory
services are separate and distinct from commissions and fees earned by the adviser for brokerage related
activities. This presents a conflict of interest because the adviser may have an incentive to recommend
20
advisory accounts and/or brokerage accounts which directly impact the adviser’s compensation. However,
you are under no obligation, contractually or otherwise, to purchase securities in a brokerage account
through any person affiliated with our firm.
If you act upon the adviser’s advice and choose to use one of Raymond James's affiliates as a money
manager, custodian or to purchase securities or insurance, the adviser will likely receive compensation in
the form of commissions or fees from the affiliate.
Additionally, if you purchase a mutual fund containing a 12b-1 fee, the adviser may receive such fee. As
part of its fiduciary duties to clients, Raymond James and CWFP endeavors always to put the interests of
its investment advisory clients first. Clients should be aware, however, that the receipt of economic benefits
by Raymond James and the adviser in and of itself creates a potential conflict of interest.
Item 5 - Additional Compensation
In addition to the fee-based compensation this adviser receives for providing advisory services, the adviser
may earn commissions for transactional business in accordance with RJFS's published commission
schedule. At the conclusion of each year, qualifying advisers are awarded membership in the RJFS's
recognition clubs. Qualification for recognition clubs is based upon a combination of the adviser's annual
production (both advisory and transactional), total client assets under administration, and the professional
certifications acquired through educational programs.
Item 6 - Supervision
The adviser is the president and principal owner of CWFP. He is solely responsible for all his activities
and advice and he can be reached at 770-399-6644.
21
Form ADV Part 2B: Brochure Supplement
KELLY M. GRAFF, CFP®
CRD # 6180823
CommonWealth Financial Planners, Inc.
CRD # 106831
1033 Canton Street
Roswell, GA 30075
Phone: 770-399-6644
Website: www.commonwealthfp.com
October 2025
This brochure supplement provides information about Kelly M. Graff (the adviser) that supplements
CommonWealth Financial Planners, Inc.’s brochure. You should have received a copy of that brochure.
Please contact our office at 770-399-6644 if you did not receive CommonWealth Financial Planners, Inc.’s
brochure or if you have any questions about the contents of this supplement.
Additional information about Kelly M. Graff is available on the SEC's website at www.adviserinfo.sec.gov.
22
Item 2 - Educational Background and Business Experience
KELLY M. GRAFF, CFP®
Year of Birth: 1989
Educational Background:
• 2012 Kennesaw State University, Bachelor of Science in Biology
Business Background:
Joined CommonWealth Financial Planners, Inc. (CWFP) in 2013.
•
• Currently a Client Service Director of CommonWealth Financial Planners, Inc.
Exams, Licenses & Other Professional Designations:
The adviser obtained her CERTIFIED FINANCIAL PLANNER™, designation in 2018.
No FINRA Licenses held.
CERTIFIED FINANCIAL PLANNER® professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER®
professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc.
has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state
law or regulation requires financial planners to hold the CFP® certification. You may find more information
about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and
complete CFP Board-approved coursework at a college or university through a CFP Board
Registered Program. The coursework covers the financial planning subject areas CFP Board has
determined are necessary for the competent and professional delivery of financial planning services,
as well as a comprehensive financial plan development capstone course. A candidate may satisfy
some of the coursework requirement through other qualifying credentials. CFP Board implemented
the bachelor’s degree or higher requirement in 2007 and the financial planning development
capstone course requirement in March 2012. Therefore, a CFP® professional who first became
certified before those dates may not have earned a bachelor’s or higher degree or completed a
financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is
designed to assess an individual’s ability to integrate and apply a broad base of financial planning
knowledge in the context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
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Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards
for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
to remain certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment
to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests
of the client, at all times when providing financial advice and financial planning. CFP Board may
sanction a CFP® professional who does not abide by this commitment, but CFP Board does not
guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain
a written engagement that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3 - Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mrs. Graff. Mrs. Graff has never
been involved in any regulatory, civil, or criminal action. There have been no lawsuits, arbitration claims, or
administrative proceedings against Mrs. Graff.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices.
As previously noted, there are no legal, civil, or disciplinary events to disclose regarding Mrs. Graff.
However, we do encourage you to independently view the background of Mrs. Graff on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her
Individual CRD# 6180823.
Item 4 - Other Business Activities
There are no other business activities.
Item 5 - Additional Compensation
The adviser does not receive additional compensation.
Item 6 - Supervision
The adviser does not have a supervisory role at CWFP. Michael P. Agurkis is her supervisor and he can
be reached at 770-399-6644.
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