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Item 1 – Cover Page
PMG Wealth Management, Inc
FORM ADV Part 2A – Firm Brochure
Date of Brochure: October 2025
____________________________________________________________________________________
The purpose of this brochure is to provide information to you on our firm, PMG Wealth Management,
(referred to as we, us and PMG throughout this disclosure brochure). This provides a deeper dive into the
services we provide allowing you to be informed on how we can assist your situation. If you have any
questions about the contents of this disclosure brochure, please contact us at the number above.
This information in this disclosure brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about PMG Wealth Management, Inc. is also available on the Internet at
www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for PMG Wealth
Management, Inc. or our firm’s CRD number 285899.
*Registration as an investment adviser does not imply a certain level of skill or training.
PMG Wealth Management, Inc.
60 Landover Parkway, Suite D
Hawthorn Woods, IL 60047
847-550-6100
www.pmgwealth.com
PMG Wealth Management
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Form ADV Part 2A, Rev. 10/2025
Item 2 – Material Changes
PMG has updated this brochure according to regulatory requirements and rules. The following material
changes have been made to this brochure since our last update in February 2025:
•
In September 2025 the firm updated the information provided concerning our Financial Planning
services and our minimum account requirements. Please refer to Item 4 – Advisory Business
and Item 7 – Types of Clients for more specific information.
Pursuant to regulations, we will ensure that you receive a summary of any material changes to this and
subsequent Disclosure Brochures within 120 days after our fiscal year ends. Our fiscal year ends on
December 31 so you will receive the summary of material changes no later than April 30 each year. At
that time we will also offer a copy of the most current Disclosure Brochure. We may also provide other
ongoing disclosure information about material changes as necessary.
.
PMG Wealth Management
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Form ADV Part 2A, Rev. 10/2025
Item 3 – Table of Contents
Item 1 – Cover Page ..................................................................................................................................... 1
Item 4 – Advisory Business ........................................................................................................................... 4
Description of Advisory Services .............................................................................................................. 4
Participation in Wrap Fee Programs ....................................................................................................... 12
Tailored Advisory Services to Individual Needs of Clients ...................................................................... 13
Client Assets Managed by PMG ............................................................................................................. 13
Item 5 – Fees and Compensation ............................................................................................................... 13
Direct Bill Retirement Plan Advisory Services ........................................................................................ 15
Financial Planning & Consulting Services .............................................................................................. 15
Third-Party Money Managers.................................................................................................................. 17
Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 18
Item 7 – Types of Clients ............................................................................................................................ 18
Minimum Investment Amounts Required ................................................................................................ 18
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 19
Methods of Analysis ................................................................................................................................ 19
Risk of Loss ............................................................................................................................................. 22
Item 9 – Disciplinary Information ................................................................................................................. 23
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 23
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 25
Code of Ethics Summary ........................................................................................................................ 25
Affiliate and Employee Personal Securities Transactions Disclosure .................................................... 25
Item 12 – Brokerage Practices .................................................................................................................... 26
Directed Brokerage ................................................................................................................................. 27
Handling Trade Errors ............................................................................................................................. 28
Block Trading Policy ................................................................................................................................ 28
Agency Cross Transactions .................................................................................................................... 29
Item 13 – Review of Accounts..................................................................................................................... 29
Account Reviews and Reviewers ............................................................................................................ 29
Statements and Reports ......................................................................................................................... 29
Item 14 – Client Referrals and Other Compensation .................................................................................. 30
Item 15 – Custody ....................................................................................................................................... 30
Item 16 – Investment Discretion ................................................................................................................. 30
Item 17 – Voting Client Securities ............................................................................................................... 31
Item 18 – Financial Information ................................................................................................................... 32
Business Continuity Plan ............................................................................................................................ 32
Customer Privacy Policy Notice .............................................................................................................. 33
FORM ADV PART 2B BROCHURE SUPPLEMENT - Phillip Guerrero...................................................... 34
FORM ADV PART 2B BROCHURE SUPPLEMENT - Daniel R. Dame ..................................................... 39
FORM ADV PART 2B BROCHURE SUPPLEMENT – George Maroudas ................................................. 42
FORM ADV PART 2B BROCHURE SUPPLEMENT – Ryan Zentz ........................................................... 45
PMG Wealth Management
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Form ADV Part 2A, Rev. 10/2025
Item 4 – Advisory Business
Firm Information
PMG Wealth Management is a registered investment adviser based in Hawthorn Woods, Illinois. The firm
is registered with the U.S. Securities and Exchange Commission and is a S-corporation formed under the
laws of the State of Illinois. PMG is also approved to do business in other states as required by
regulation. The firm was originally incorporated in 2007 as an S-Corp under the laws of the state of
Illinois. Advisory services have been offered through individuals registered as investment advisor
representatives of LPL Financial and its corporate RIA since 2007. In 2017, PMG formed its own RIA and
since then all advisory services have been offered through PMG. Our custodian continues to be LPL
Financial.
The investment advisory services of PMG are provided to you through an appropriately licensed and
qualified individual who is an investment adviser representative of PMG (referred to as your investment
adviser representative throughout this brochure).
PMG is a registered investment advisor (RIA) with offices in Hawthorn Woods, IL and Cape Coral, FL,
and maintains state registrations in other states as required by regulation, such as Florida and California.
Your investment adviser representative is limited to providing the services and charging investment
advisory fees in accordance with the descriptions detailed in this brochure. However, the exact services
you receive and the fees you will be charged will be specified in your advisory services agreement.
PMG is solely owned by Phillip Guerrero, CFP®.
Description of Advisory Services
PMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, and
business owners (each referred to as a “Client”).
PMG serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith to each Client while seeking to
minimize and disclose any conflicts of interest. For more information regarding the Code of Ethics, please
see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Please understand that a written agreement, which details the exact terms of the service, must be signed
by you and PMG before we can provide you the services described below.
Investment Management Services
PMG offers customized investment management services, which involves PMG providing you with
continuous and ongoing supervision over your specified accounts. The majority of our portfolios are
managed directly in house, custom built to your specific situation, and held in custody at LPL Financial.
We may recommend the use of outside professional managers from time to time or decide to hold a
client’s previous outside professionally managed account upon the time services begin. PMG works
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Form ADV Part 2A, Rev. 10/2025
closely with each client to identify their investment goals and objectives as well as risk tolerance and
financial situation to build an overall strategy.
Our investment management services are provided on a discretionary basis. You must provide us with
written authority to use discretion, as this is part of the account opening procedure. Any discretion is
limited to investment authority only. With this authority our advisors make all decisions to buy, sell,
exchange, or hold the specific securities within the portfolio. This also includes the use of cash as an
asset class and, from time to time, will raise and lower cash levels depending on risk concerns with the
markets. It is not our typical investment strategy to attempt to time the market, but we may increase cash
holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market
behavior. We may modify our investment strategy to accommodate special situations such as low basis
stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax
situations.
PMG has no authority to transfer monies to other accounts, has no access to your funds, other than the
ability to debit the account for agreed upon management fees.
All clients who utilize PMG’s advisory services must sign an “Advisory Agreement” along with any
applicable custodian or outside manager platform forms as applicable. You must appoint our firm as your
investment adviser of record on specified accounts (collectively, the “Account”). The Account consists
only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians
maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership
(e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction
confirmations) of the Account.
The Account is managed by us based on a number of factors including your financial situation,
investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding
buying, selling, reinvesting or holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and investment
objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk
tolerance or investment objective and whether you wish to impose or modify existing investment
restrictions; however we will contact you at least annually to discuss any changes or updates regarding
your financial situation, risk tolerance or investment objectives. We are always reasonably available to
consult with you relative to the status of your Account. You have the ability to impose reasonable
restrictions on the management of your accounts, including the ability to instruct us not to purchase
certain securities.
It is important that you understand that we manage investments for other clients and may give them
advice or take actions for them or for our personal accounts that is different from the advice we provide to
you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other
investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We
strive to allocate investment opportunities believed to be appropriate for your account(s) and other
accounts advised by our firm among such accounts equitably and consistent with the best interests of all
accounts involved. However, there can be no assurance that a particular investment opportunity that
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comes to our attention will be allocated in any particular manner. If we obtain material, non-public
information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any client or use it for any client’s benefit.
Financial Planning & Consulting Services
PMG typically offers financial planning services into its Advisory Services structure, which can involve
preparing a written financial plan covering specific or multiple topics. This may or may not be included
depending on each specific clients’ situation. During the initial planning process, PMG will disclose what
Planning & Consulting would be either included or separate from the relationship. PMG has a separate
Financial Planning Agreement that is required only when clients are being charged for those Planning
Services.
PMG’s advisory process typically will address the following topics: Investment Management Planning,
Retirement Income Planning, Tax Planning and Mitigation, Cash Flow and Liquidity, Wealth Protection
and Legacy Planning, Portfolio Review, and Asset Allocation. When providing financial planning and
consulting services, the role of your investment adviser representative is to find ways to help you
understand your overall financial situation and help you set financial objectives.
We also offer separate consultations in order to discuss financial planning issues when you do not need a
written financial plan. Some are one-time consultations, which cover mutually agreed upon areas of
concern related to investments or financial planning. These may be recommended by us. We also offer
“as-needed” consultations, which are in response to a particular investment or financial planning issue
raised or requested by you. Under an “as-needed” consultation, it will be incumbent upon you to identify
those particular issues for which you are seeking our advice or consultation on
Depending on your situation, Financial Planning and Consulting Services may be more comprehensive in
nature and other times it may be better addressed in a modular format. The planning areas listed below
can be part of a larger comprehensive plan or individually addressed as needed.
• Cash Flow and Liquidity: We will conduct a review of your gross/net incomes and expenses to
determine your cash flow situation. This enables us to project your surplus or deficit each month
and provide advice on tackling your priorities. Advice could include which debts to pay of first,
which order, and where to save any surplus. We are big believers in creating an emergency
savings fund and will double check that this amount is appropriate for your situation.
•
Investment Planning: PMG will make recommendations in this area based on the review of a
client’s overall investment objective, return requirements, risk tolerance, time horizon, liquidity
needs, tax preference and other unique circumstances. Any change in your personal
circumstance in between reviews should be conveyed to PMG so we can make any adjustments
as needed. Investment planning can take anywhere between six to forty hours depending upon
the client’s profile and circumstances
• Retirement Income Planning: PMG determines retirement income goals and gathers
information about potential sources of retirement. PMG creates a unified and comprehensive
retirement plan covering assets, income needs, budgeting (as needed), cash flow review and
strategy, income, taxation, inheritance, and risk management. A long-term asset management
plan is structured considering economic environment and inflationary conditions, tax minimization
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Form ADV Part 2A, Rev. 10/2025
strategy, uncertainty and market volatility. Retirement planning services include research,
financial modeling and mathematical simulation to identify adequacy of client’s investment and
savings to attain retirement readiness, and to clarify strategic choices and actions. Retirement
planning can take anywhere between ten to fifty hours depending upon the client’s profile and
circumstances.
• Tax Planning: This can be done in house or in partnership with outside third party tax /
accounting advisor(s) to align financial goals with tax efficiency planning. Tax planning would
encompass many different aspects e.g. selection of investment options and types of retirement
plans, timing of income and capital growth as well as tax lot selection for investment transactions
within client’s portfolio. Tax planning services would include recommendations on tax reduction
strategies based on income, expenses, individual needs and goals. PMG often requests copies of
past tax returns to help evaluate scenarios for client situations. As needed, PMG is available to
work with your existing tax / accounting advisor(s) or can recommend one if you are looking for a
new relationship. PMG does not share any fees with any outside CPA’s / accounting advisor(s).
Fee arrangements with outside professionals are described in the section ‘Other Fee Terms for
Financial Planning, Institutional Advisory & Consulting Services’. Tax planning can take anywhere
between five to forty hours depending upon the client’s profile and circumstances.
• Wealth Transfer, Legacy, and Estate Planning: PMG will often make recommendations to
improve overall client legacy situation and potentially multi-generational structure via various
strategies with goal to either pass on assets in a timely or smooth manner, protect assets from
being unjustly taken, or to maximize potential longevity for future generations. This may include
the need for referrals to local estate attorneys or the use of software for estate document
coordination. PMG does not share any fees with any outside professionals. Estate Planning can
take anywhere between five to forty hours depending on circumstances.
ESTATE PLANNING DISCLOSURE
PMG Wealth Management, a SEC registered investment advisor may offer assistance to clients
in the coordination of their estate planning documents. Document coordination is done through a
partnership with Wealth.com, a third-party firm who is independent of PMG. Should this
agreement be used for document coordination, the undersigned understands and acknowledges
that PMG is not a legal/attorney practice and does not offer legal services or advice. All questions
regarding your estate plan, options, or alternatives should be addressed with the representatives
of Wealth.com or another licensed attorney. The Client further understands and agrees that all
fees paid to PMG are for planning time, document coordination, notary services, education, and
consultative estate planning support with Wealth.com and do not represent legal fees.
Wealth.com may have additional services for a flat fee that the Client may decide to purchase
separate from this agreement. Those services are handled directly through the Wealth.com
portal. The amount paid to PMG will be representative of PMG time involved and represented
below via “as needed” planning services.
• Portfolio Review and Asset Allocation: PMG researches clients’ existing portfolios and
underlying investments to determine the asset class mix, return profile and risk characteristics.
PMG will also compare existing holdings to the clients risk objectives based on the client profile to
ensure that the two match. PMG also analyzes return, risk and modern portfolio statistics and
runs mathematical simulation, wherever necessary, to identify the adequacy of the portfolio
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Form ADV Part 2A, Rev. 10/2025
against client’s investment objectives and risk tolerance. Portfolio Review and asset allocation
can take anywhere between ten to fifty hours depending upon the client’s profile and
circumstances.
Our financial planning and consulting services do not involve implementing any transaction on your behalf
or the active and ongoing monitoring or management of your investments or accounts without written
authority. You have the sole responsibility for determining whether to implement our financial planning
and consulting recommendations. To the extent that you would like to implement any of our investment
recommendations through PMG or retain PMG to actively monitor and manage your investments or to
assist monitoring any written plan you must execute a separate written agreement with PMG for our Asset
Management Services, or the separate Financial Planning Agreement.
Referral of Third-Party Money Managers
Occasionally PMG offers advisory services by referring clients to a third-party money manager offering
asset management and other investment advisory services. The third-party managers are responsible for
continuously monitoring client accounts and making trades in client accounts when necessary. As a
result of the referral, we are paid a portion of the fee charged and collected by the third-party money
managers in the form of solicitor fees. Each solicitation arrangement is performed pursuant to a written
solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules
and regulations.
Under this program, we assist you with identifying your risk tolerance and investment objectives. We
recommend third-party money managers in relation to your stated investment objectives and risk
tolerance, and you may select a recommended third-party money manager or model portfolio based upon
your needs. You must enter into an agreement directly with the third-party money manager who provides
your designated account with asset management services.
We are available to answer questions that you may have regarding your account and act as the
communication conduit between you and the third-party money manager. The third-party money
manager may take discretionary authority to determine the securities to be purchased and sold for your
account. We do not have any trading authority with respect to your designated account managed by the
third-party money manager.
Although we review the performance of numerous third-party investment adviser firms, we enter into only
a select number of relationships with third-party investment adviser firms. PMG will only enter in to
agreements with other investment advisory firms that are properly registered in the state of client
residence. All of the third-party firms we use have also agreed to pay us a portion of the overall fee
charged to our clients. Therefore, PMG has a conflict of interest in that it will only recommend third-party
investment advisors that will agree to compensate us for referrals of our clients.
Clients are advised that there may be other third-party managed programs not recommended by our firm,
that are suitable for the client and that may be more or less costly than arrangements recommended by
our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a
third-party investment adviser recommended by our firm. Further, no guarantees of performance can
ever be offered by our firm (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk
of Loss for more details.)
PMG Wealth Management
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Retirement Plan Services
PMG offers retirement plan services to retirement plan sponsors and to individual participants in
retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include,
but are not limited to, the following services:
Fiduciary Consulting Services
PMG provides the following Fiduciary Retirement Plan Consulting Services:
•
Investment Policy Statement Preparation. PMG will help you develop an investment policy
statement. The investment policy statement establishes the investment policies and objectives
for the Plan. You will have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. PMG will provide you with general, non-discretionary
investment advice regarding assets classes and investment options, consistent with your Plan’s
investment policy statement.
•
Investment Selection Services. PMG will provide you with recommendations of investment
options consistent with ERISA section 404(c).
•
Investment Due Diligence Review. PMG will provide you with periodic due diligence reviews of
the Plan’s reports, investment options and recommendations.
•
Investment Monitoring. PMG will assist in monitoring investment options by preparing periodic
investment reports that document investment performance, consistency of fund management and
conformation to the guidelines set forth in the investment policy statement and PMG will make
recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. PMG will provide you with non-discretionary investment
advice to assist you with the development of qualified default investment alternative(s) (“QDIA”),
as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically
enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole
responsibility to provide all notices to participants required under ERISA section 404(c)(5).
•
Individualized Participant Advice. Upon request, PMG will provide one-on-one advice to Plan
participants regarding their individual situations.
For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be
submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting
Services, the retirement plan sponsor client or the plan participant who elects to implement any
recommendations made by us is solely responsible for implementing all transactions.
Fiduciary Consulting Services are not management services, and PMG does not serve as administrator or
trustee of the plan. PMG does not act as custodian for any client account or have access to client funds
or securities (with the exception of, some accounts, having written authorization from the client to deduct
our fees).
PMG acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a
“fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act
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Form ADV Part 2A, Rev. 10/2025
of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. PMG will act in a
manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and
circumstances, such services cause PMG to be a fiduciary as a matter of law. However, in providing the
Fiduciary Consulting Services, PMG (a) has no responsibility and will not (i) exercise any discretionary
authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any
authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii)
have any discretionary authority or discretionary responsibility in the administration of Client’s retirement
plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as
defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any
plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA.
Non-Fiduciary Services
Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and
required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-
fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not
acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The
exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan
Agreement.
PMG provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. PMG will provide education services to Plan participants about general
investment principles and the investment alternatives available under the Plan. PMG’s
assistance in participant investment education will be consistent with and within the scope of DOL
Interpretive Bulletin 96-1. Education presentations will not take into account the individual
circumstances of each participant and individual recommendations will not be provided unless
otherwise agreed upon. Plan participants are responsible for implementing transactions in their
own accounts.
• Participant Enrollment. PMG will assist you with group enrollment meetings designed to increase
retirement plan participation among employees and investment and financial understanding by
the employees.
• Qualified Plan Development. PMG will assist you with the establishment of a qualified plan by
working with you and a selected Third Party Administrator. If you have not already selected a
Third Party Administrator, we shall assist you with the review and selection of a Third Party
Administrator for the Plan.
• Due Diligence Review. PMG will provide you with periodic due diligence reviews of your Plan’s
fees and expenses and your Plan’s service providers.
• Fiduciary File Set-up. PMG will help you establish a “fiduciary file” for the Plan which contains
trust documents, custodial/brokerage statements, investment performance reports, services
agreements with investment management vendors, the investment policy statement, investment
committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money
managers and monitoring procedures for funds and/or money managers.
• Benchmarking. PMG will provide you benchmarking services and will provide analysis
concerning the operations of the Plan.
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Securities and other types of investments all bear different types and levels of risk. Those risks are
typically discussed with clients in defining the investment policies and objectives that will guide
investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan
services, we can discuss those investments and investment strategies that we believe may tend to
reduce these risks for a particular client’s circumstances and plan participants.
Clients and plan participants must realize that obtaining higher rates of return on investments entails
accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the
balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is
still the clients’ responsibility to ask questions if the client does not fully understand the risks associated
with any investment. All plan participants are strongly encouraged to read prospectuses, when
applicable, and ask questions prior to investing.
We strive to render our best judgment for clients. Still, PMG cannot assure that investments will be
profitable or assure that no losses will occur in their portfolios. Past performance is an important
consideration with respect to any investment or investment advisor, but it is not necessarily an accurate
predictor of future performance.
PMG will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any
change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-
2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are
informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond
our control, in which case the information will be disclose as soon as practicable).
In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30)
days following receipt of a written request from the responsible plan fiduciary or Plan Administrator
(unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case
the information will be disclosed as soon as practicable) all information related to the Qualified Retirement
Plan Agreement and any compensation or fees received in connection with the Agreement that is
required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the
regulations, forms and schedules issued thereunder.
If we make an unintentional error or omission in disclosing the information required under ERISA
Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as
practicable, but no later than thirty (30) days from the date on which we learns of such error or omission.
Retirement Plan Rollover Recommendations
When PMG provides investment advice about your retirement plan account or individual retirement
account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan
account, roll over such investment/proceeds from the retirement plan account to a IRA or make a
distribution from the retirement plan account, we acknowledge that PMG is a “fiduciary” within the
meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue
Code (“IRC”) as applicable, which are laws governing retirement accounts. The way PMG makes money
creates conflicts with your interests so PMG operates under a special rule that requires PMG to act in
your best interest and not put our interest ahead of you.
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Under this special rule’s provisions, PMG must as a fiduciary to a retirement plan account or IRA under
ERISA/IRC:
•
•
•
•
•
•
Meet a professional standard of care when making investment recommendations (give
prudent advice);
Never put the financial interests of PMG ahead of you when making recommendations
(give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that PMG gives advice that is in your
best interest;
Charge no more than is reasonable for the services of PMG; and
Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account to an
individual retirement account managed by PMG, please know that PMG and our investment adviser
representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account at the
retirement plan to a IRA managed by PMG. We will earn fewer investment advisory fees if you do not roll
over the funds in the retirement plan to an IRA managed by PMG.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover of
funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that
you open an IRA account to be managed by our firm can be based on our economic incentive and not
based exclusively on whether or not moving the IRA to our management program is in your overall best
interest. We have taken steps to manage this conflict of interest. we have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to a retirement
plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary
status described below, (ii) not recommend investments which result in PMG receiving unreasonable
compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose
compensation received by PMG and our supervised persons and any material conflicts of interest related
to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any
materially misleading statements regarding such rollover.
When providing advice to a retirement plan account or IRA, our investment advisor representatives will
act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent
person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of
a like character and with like aims, based on the investment objectives, risk, tolerance, financial
circumstances, and a client’s needs, without regard to the financial or other interests of PMG or our
affiliated personnel.
Participation in Wrap Fee Programs
PMG currently only offers services through traditional non-wrap fee asset management programs.
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Tailored Advisory Services to Individual Needs of Clients
PMG’s advisory services, financial planning services, and consulting services are always provided based
on your individual needs. This means, for example, that when we provide asset management services,
you are given the ability to impose restrictions on the accounts we manage for you, including specific
investment selections and sectors. Our services are done with you on a one-on-one basis through
interviews and questionnaires to determine your investment objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
Client Assets Managed by PMG
As of December 31, 2024, PMG manages $164,749,480 of client assets, all on a discretionary basis.
Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides additional
details regarding our firm’s services along with descriptions of each service’s fees and compensation
arrangements. It should be noted that lower fees for comparable service may be available from other
sources. The exact fees and other terms will be outlined in the agreement between you and PMG.
PMG allows your investment adviser representative to set fees within ranges provided by PMG. As a
result, your investment adviser representative may charge more or less for the same service than another
investment adviser representative of PMG.
Fees for Advisory Services
Investment Management Services
Fees charged for our investment management services are charged based on a percentage of assets
under management, billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous
billing period. PMG does not process the deduction of the advisory fees from client’s managed accounts,
LPL Financial is responsible for calculating and debiting all fees from your accounts. You must provide
our custodian, LPL with written authorization to debit advisory fees from your accounts and pay the fees
to PMG. Fees are based on the account's asset value as of the last business day of the prior calendar
quarter. Fees for accounts opened at any time other than the beginning of a quarter is prorated based on
the number of days remaining in the initial quarter. The prorated fee for the initial billing period is billed in
arrears at the same time as the next full billing period’s fee is billed.
The asset management services continue in effect until terminated by either party (i.e., PMG or you) by
providing written notice of termination to the other party. Any prepaid, unearned fees will be promptly
refunded by PMG to you. Fee refunds will be determined on a pro rata basis using the number of days
services are actually provided during the final period.
Fees charged for our asset management services are negotiable based on the type of client, the
complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual
funds), the potential for additional account deposits, the relationship of the client with the investment
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Form ADV Part 2A, Rev. 10/2025
adviser representative, and the total amount of assets under management for the client. As such it may
differ from the fee schedule listed below.
Prior to engaging PMG to provide investment management services, you are required to enter into a
formal investment advisory agreement with us setting forth the terms and conditions, including the
amount of investment advisory fees, under which we manage your assets and also a separate
custodial/clearing agreement with LPL.
Assets Under Management
Up to $99,999
$100,000 – $249,999
$250,000 – $499,999
$500,000 – $749,999
$750,000 – $1,249,999
$1,250,000 – $1,999,999
Over $2,000,000
Annual Fees
1.45%
1.30%
1.20%
1.00%
0.95%
0.90%
Negotiable
You can only open a traditional non-wrap managed account. With a traditional managed account you are
responsible for any transaction charges LPL may have to offset the costs of trading. PMG is not
compensated on any of these charges. These costs are set out in the LPL Strategic Wealth Management
platform brokerage account and application agreement.
Industry Standards view advisory fees in excess of 3% as excessive; PMG asset management fees will
not exceed industry standards.
You may incur certain charges imposed by third parties other than PMG in connection with investments
made through the account including, but not limited to, 12b-1 fees and surrender charges, confirmation
fees, and IRA and qualified retirement plan fees. Our management are separate and distinct from the
fees and expenses charged by investment company securities that may be recommended to you. A
description of these fees and expenses are available in each investment company security’s prospectus.
The advisory accounts may cost you more or less than if the assets were held in a traditional brokerage
account. In a brokerage account, you are charged commissions for each transaction, and the
representative has no duty to provide ongoing advice with respect to the account. If you plan to follow a
buy and hold investment strategy for the account or do not wish to purchase ongoing investment advice
or management services, you should consider opening a brokerage account rather than an advisory
account.
Either party may terminate the agreement for services at any time. If services are terminated within five
business days of executing the agreement, services are terminated without penalty and a full refund of all
fees paid in advance is provided. If services are terminated after the initial five day period, we provide
you with a prorated refund of fees paid in advance. The refund is based on the number of days service is
actually provided during the final billing period. Termination is effective from the time the other party
receives written notification or such other time as may be mutually agreed upon, subject to the settlement
of transactions in progress and the final refund of advisory fees. There is no penalty charge on
termination.
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Direct Bill Retirement Plan Advisory Services
Fees for 3(21) retirement plan advisory services are charged on a flat fee basis. Flat fees generally range
from $300-$3,500, pursuant to the terms listed in the Financial Planning and Consulting Agreement. Fees
charged for our direct bill retirement asset management services (retirement accounts held outside of LPL
Financial, LLC) are typically billed in advance (at the start of the billing period) on a quarterly calendar
basis. In rare circumstances they may be billed in arrears. Fees are prorated (based on the number of
days service is provided during the initial billing period) for your account opened at any time other than
the beginning of the billing period. If asset management services are commenced in the middle of a
billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next
full billing period’s fee is billed.
The asset management services continue in effect until terminated by either party (i.e., PMG or you) by
providing written notice of termination to the other party. Any prepaid, unearned fees will be promptly
refunded by PMG to you. Fee refunds will be determined on a pro rata basis using the number of days
services are actually provided during the final period.
For PMG’s Direct Bill Retirement Plan Services you will pay our firm upon receipt of a billing notice sent
directly to you. Fees for our services will be due immediately upon receipt of the billing notice.
PMG does not receive any portion of such commissions or fees from you or the qualified custodian. In
addition, you may incur certain charges imposed by third parties other than PMG in connection with
investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1
fees and surrender charges, and charges imposed by the qualified custodian(s) of your account.
Management fees charged by PMG are separate and distinct from the fees and expenses charged by
investment company securities that may be recommended to you. A description of these fees and
expenses are available in each investment company security’s prospectus.
Financial Planning & Consulting Services
Fees charged for our financial planning and consulting services are negotiable based upon the services
requested, the complexity of the client's situation, the composition of the client's account, other advisory
services provided and the relationship of the client and the investment adviser representative.
PMG provides financial planning services under an hourly fee arrangement. An hourly fee of up to $500
per hour (depending on the complexity of the client’s situation) is charged by PMG for financial planning
services provided under this arrangement. The hourly fee to be charged to the client will be specified in
the Financial Planning & Consulting Agreement executed before services can begin. Before commencing
financial planning services, PMG provides an estimate of the approximate hours needed to complete the
requested financial planning services. If PMG anticipates exceeding the estimated amount of hours
required, PMG will contact you to receive authorization to provide additional services. The standard
billing dates and events of PMG are the following: (1) the first business day of each month; (2) the date
when incurred hourly fees and expenses will cause the retainer balance to be depleted to zero; (3) the
date or thereafter that PMG substantially provides the agreed upon services; and (4) the date the
engagement is terminated by either you or PMG. Upon presentment of the invoice to you, PMG will
deduct the hourly fees due PMG against your current retainer balance and you are required to pay
immediately PMG any outstanding balance of hourly fees due.
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The financial planning services terminate upon delivery of the written financial plan or upon either party
providing the other party with written notice of termination.
You may terminate the financial planning services within five (5) business days of entering into an
agreement with PMG without penalty or fees due. If you terminate the financial planning services after
entering into an agreement with us, you will be responsible for immediate payment of any financial
planning services performed by PMG prior to the receipt by PMG of your notice of termination. For
financial planning services performed by PMG under an hourly arrangement, you will pay PMG for any
hourly fees incurred at the rates described above.
Other Fee Terms for Financial Planning & Consulting Services
Any investment advisory fees owed for the financial planning services referenced above may be paid by
submitting payment directly to the firm (for example, by check).
You should notify PMG within ten (10) days of receipt of an invoice if you have questions about or dispute
any billing entry.
To the extent PMG engages an outside professional (i.e. attorney, independent investment adviser or
accountant) while providing financial planning and consulting services to you, PMG will be responsible for
the payment of the fees for the services of such an outside professional, and you will not be required to
reimburse PMG for such payments. To the extent that you personally engage such an outside
professional, you will be responsible for the payment of the fees for the services of such an outside
professional, and PMG will not be required to reimburse Client for such payments. Fees for the services
of an outside professional (i.e. attorney, independent investment adviser or accountant) will be in addition
to and separate from the fees charged by PMG, and you will be responsible for the payment of the fees
for the services of such an outside professional. In no event will the services of an outside professional
be engaged without your express approval.
All fees paid to PMG for services are separate and distinct from the commissions, fees and expenses
charged by insurance companies associated with any disability insurance, life insurance and annuities
subsequently acquired by you. If you sell or liquidate certain existing securities positions to acquire any
insurance or annuity, you may also pay a commission and/or deferred sales charges in addition to the
financial planning and consulting fees paid to PMG and any commissions, fees and expenses charged by
the insurance company for subsequently acquired insurance and/or annuities.
If you elect to have your investment adviser representative, in his or her separate capacity as an
insurance agent, implement the recommendations of PMG, your investment adviser representative at his
or her discretion may waive or reduce the investment advisory fee or financial planning and consulting fee
charged for those services by a portion of the amount of the commissions received by your investment
adviser representative as an insurance agent. Any reduction of the investment advisory fee will not
exceed 100% of the insurance commission received.
All fees paid to PMG for advisory services are separate and distinct from the fees and expenses charged
by mutual funds to their shareholders. These fees and expenses are described in each mutual fund’s
prospectus. These fees will generally include a management fee, other fund expenses and a possible
distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge.
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If you retain PMG to implement the recommendations provided under this service, PMG may recommend
load or no-load mutual funds that charge you 12(b)-1 fees. Your investment adviser representative may
receive a portion of these 12(b)-1 fees in his or her separate capacity as a registered representative of a
securities broker-dealer. The receipt of 12(b)-1 fees could represent an incentive for PMG or your
investment adviser representative to recommend mutual funds with 12(b)-1 fees or higher 12(b)-1 fees
over mutual funds with no 12(b)-1 fees or lower 12(b)-1 fees and therefore creates a conflict of interest. In
general PMG utilizes load waived funds foregoing any up-front commission. Clients are under no
obligation to purchase investment products through persons affiliated with PMG Wealth Management and
are free to choose any broker dealer they may want.
All fees paid to PMG for financial planning and consulting services are separate and distinct from the
commissions charged by a broker-dealer or asset management fees charged by an investment adviser to
implement such recommendations. Investment Advisor representatives of PMG Wealth Management may
receive 50% or more of their total compensation from the sales of investment products.
If you elect to have your investment adviser representative, in his or her separate capacity as a registered
representative, implement the recommendations of PMG, your investment adviser representative at his or
her discretion may waive or reduce the investment advisory fee charged by the amount of the
commissions received as a registered representative. Any reduction of the investment advisory fee will
not exceed 100% of the commission received as a registered representative.
If you elect to implement the recommendations of PMG through our other investment advisory programs,
PMG may waive or reduce a portion of the investment advisory fees for such investment advisory
program(s). Any reduction will be at the discretion of your investment adviser representative and
disclosed to you prior to contracting for additional investment advisory services.
It should be noted that lower fees for comparable services may be available from other sources.
Third-Party Money Managers
Third-party managers generally have account minimum requirements that will vary among third-party
money managers. Account minimums are generally higher on fixed income accounts than for equity
based accounts. A complete description of the third-party money manager’s services, fee schedules and
account minimums will be disclosed in the third-party money manager’s disclosure brochure which will be
provided to you prior to or at the time an agreement for services is executed and the account is
established.
The actual fee charged to you will vary depending on the third-party money manager. All fees are
calculated and collected by the third-party money manager who will be responsible for delivering our
portion of the fee paid by you to us.
Under this program, you may incur additional charges including but not limited to, mutual fund sales
loads, 12b-1 fees and surrender charges and IRA and qualified retirement plan fees.
We have a conflict of interest by only offering those third-party money managers that have agreed to pay
a portion of their advisory fee to us and have met the conditions of our due diligence review. There may
be other third-party money managers that may be suitable for you that may be more or less costly. No
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Form ADV Part 2A, Rev. 10/2025
guarantees can be made that your financial goals or objectives will be achieved. Further, no guarantees
of performance can be offered.
Item 6 – Performance-Based Fees and Side-By-Side Management
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we
do not charge or accept performance-based fees.
Item 7 – Types of Clients
PMG generally provides investment advice to the following types of clients:
Individuals
•
• High net worth individuals
• Pension and profit sharing plans
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed above
You are required to execute a written agreement with PMG specifying the particular advisory services in
order to establish a client arrangement with PMG.
Minimum Investment Amounts Required
PMG typically requires a minimum investment amount of $100,000 in order to open an account
dependent upon the investment strategy selected, however this minimum can be waived based on
referrals from existing clients to younger family members/friends who may be starting out with less assets.
PMG reserves the right to waive any account minimums. Please refer to Item 8 - Methods of Analysis,
Investment Strategies and Risk of Loss for more specific information. To reach these account
minimums, clients are allowed to aggregate all household accounts.
The minimum fee generally charged for financial planning services provided on an hourly basis is $500.
The minimum hourly fee generally charged for consulting services is $300.
Third-party money managers may have minimum account and minimum fee requirements in order to
participate in their programs. Each-third party money manager will disclose its minimum account size and
fees in its Form ADV Part 2A Disclosure Brochure.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
PMG uses the following methods of analysis in formulating investment advice:
Charting - This is a set of techniques used in technical analysis in which charts are used to plot
price movements, volume, settlement prices, open interest, and other indicators, in order to
anticipate future price movements. Users of these techniques, called chartists, believe that past
trends in these indicators can be used to extrapolate future trends.
Charting is likely the most subjective analysis of all investment methods since it relies on proper
interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data
can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart
patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern
that has not shown itself yet.
Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic
value by examining related economic, financial and other qualitative and quantitative factors.
Fundamental analysts attempt to study everything that can affect the security's value, including
macroeconomic factors (like the overall economy and industry conditions) and individually
specific factors (like the financial condition and management of a company). The end goal of
performing fundamental analysis is to produce a value that an investor can compare with the
security's current price in hopes of figuring out what sort of position to take with that security
(underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the
opposite of technical analysis. Fundamental analysis is about 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.
The risk associated with fundamental analysis is that it is somewhat subjective. While a
quantitative approach is possible, fundamental analysis usually entails a qualitative assessment
of how market forces interact with one another in their impact on the investment in question. It is
possible for those market forces to point in different directions, thus necessitating an
interpretation of which forces will be dominant. This interpretation may be wrong, and could
therefore lead to an unfavorable investment decision.
Technical – This is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a
security's intrinsic value, but instead use charts and other tools to identify patterns that can
suggest future activity. Technical analysts believe that the historical performance of stocks and
markets are indications of future performance.
Technical analysis is even more subjective than fundamental analysis in that it relies on proper
interpretation of a given security's price and trading volume data. A decision might be made
based on a historical move in a certain direction that was accompanied by heavy volume;
however, that heavy volume may only be heavy relative to past volume for the security in
question, but not compared to the future trading volume. Therefore, there is the risk of a trading
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decision being made incorrectly, since future trading volume is an unknown. Technical analysis
is also done through observation of various market sentiment readings, many of which are
quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a
given security, and a contrarian investor utilizes such sentiment advantageously. When most
traders are bullish, then there are very few traders left in a position to buy the security in question,
so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then
there are very few traders left in a position to sell the security in question, so it becomes
advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical
measures is that a very bullish reading can always become more bullish, resulting in lost
opportunity if the money manager chooses to act upon the bullish signal by selling out of a
position. The reverse is also true in that a bearish reading of sentiment can always become more
bearish, which may result in a premature purchase of a security.
There are risks involved in using any analysis method.
To conduct analysis, PMG gathers information from research materials prepared by others, inspection of
corporate activities, corporate rating services, charting and timing services, annual reports, prospectuses
and filings with the SEC, financial newspapers and magazines, and company press releases.
Investment Strategies
PMG uses the following investment strategies when managing client assets and/or providing investment
advice:
• PMG’s Advance and Protect Strategy: Flagship strategy which includes the use of cash as a
specific asset class and will increase or decrease such cash based on the advisor’s evaluation of
the market and current risk management. This strategy utilizes a global macro approach and
would be considered a “go anywhere” type strategy. This portfolio may include the use of
exchange-traded funds (ETFs), mutual funds, individual stocks, individual bonds, and cash. The
use of technical analysis is used to assist with the management of this strategy.
o Account Minimum: $100,000
• PMG’s Advance and Protect “Plus” Strategy: Expands on the original Advance and Protect
strategy above by including a 20% sleeve of individual equities. This is a newer strategy, but has
been used as part of the Custom Portfolio Strategy for some time and works better with a higher
minimum due to the 20% equity sleeve.
o Account Minimum $250,000
• PMG’s Conservative Dividend Growth Strategy: One of the flagship strategies created for clients
looking for conservative dividend growth who are also interested in the characteristics of the
Advance & Protect strategy which adds the risk management protection based on longer term
market trends. The protection triggers on this strategy may be longer term as compared to the
original Advance & Protect Strategy.
o Account Minimum: $100,000
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• PMG’s Jump Start Strategy: This strategy was created for clients who may be starting out or
working with a smaller part of a larger portfolio. This strategy follows the same risk management
process of Advance & Protect using ETF’s and Mutual Funds only. This strategy has a smaller
amount of holdings.
o Account Minimum: $10,000
• PMG’s Moderate Growth and Income Strategy is a newer model which combines strategic
allocation along with technical analysis. This model takes on a more traditional long term
allocation approach and expands on the size of the Jump Start Strategy.
o Account Minimum: $50,000
• PMG’s Fully Customized Portfolio Strategy: This strategy is completely custom to you based on
your overall situation. It may include portions of other PMG strategies as core portions of the
account. In addition, PMG will build satellite positions that will better help you achieve your
specific situation. Examples of why one may choose this strategy include risk-based decisions,
income needs for retirement, fixed income only portfolios, longer term growth objectives, tax
planning issues, or trading objectives with a particular sector.
o Account Minimum: No minimum due to potential cash flow needs. Typical portfolios begin
with over $250,000.
• PMG’s Allocation Strategies: For longer term investors looking to blend equities and fixed income
into one portfolio. Equity and fixed income weightings will be based on intermediate outlooks
taking on a more strategic longer-term approach. Allocations can vary and range from Equity to
Bond Ratio’s of 80/20, 70/30, 60/40, and 50/50.
o Account Minimum: $100,000
• PMG’s Allocation “Plus” Strategy: Built for larger accounts who can further diversify amongst
asset classes and sectors. Following an agreed upon allocation weighting, this portfolio can also
include up to 50% individual equites depending on market conditions. This model will typically
have between 15 and 20 holdings, made up of ETF’s (Exchange Traded Funds), Mutual Funds,
and individual equities.
o Account Minimum: $500,000 Recommended
The PMG Investment Strategies are generally implemented by using the following trading philosophies:
Long term purchases. Investments held at least a year.
Short term purchases. Investments sold within a year.
Frequent trading. This strategy refers to the practice of selling investments within 30 days of
purchase.
Primarily Recommend One Type of Security
We do not primarily recommend one type of security to clients. Instead, we recommend any product that
may be suitable for each client relative to that client’s specific circumstances and needs.
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Risk of Loss
Past performance is not indicative of future results. Therefore, you should never assume that future
performance of any specific investment or investment strategy will be profitable. Investing in securities
(including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different
types of investments there may be varying degrees of risk. You should be prepared to bear investment
loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There
are certain additional risks associated with investing in securities through our investment management
program, as described below:
• Market Risk – Either the stock market as a whole, or the value of an individual company,
goes down resulting in a decrease in the value of client investments. This is also referred
to as systemic risk.
• Equity (stock) market risk – Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and
perceptions of their issuers change. If you held common stock, or common stock
equivalents, of any given issuer, you would generally be exposed to greater risk than if
you held preferred stocks and debt obligations of the issuer.
• Company Risk. When investing in stock positions, there is always a certain level of
company or industry specific risk that is inherent in each investment. This is also referred
to as unsystematic risk and can be reduced through appropriate diversification. There is
the risk that the company will perform poorly or have its value reduced based on factors
specific to the company or its industry. For example, if a company’s employees go on
strike or the company receives unfavorable media attention for its actions, the value of
the company may be reduced.
• Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default
on the bond and be unable to make payments. Further, individuals who depend on set
amounts of periodically paid income face the risk that inflation will erode their spending
power. Fixed-income investors receive set, regular payments that face the same inflation
risk.
• Options Risk. Options on securities may be subject to greater fluctuations in value than
an investment in the underlying securities. Purchasing and writing put and call options
are highly specialized activities and entail greater than ordinary investment risks.
• ETF and Mutual Fund Risk – When investing in a an ETF or mutual fund, you will bear
additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating
expenses, including the potential duplication of management fees. The risk of owning an
ETF or mutual fund generally reflects the risks of owning the underlying securities the
ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs.
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Form ADV Part 2A, Rev. 10/2025
• Management Risk – Your investment with our firm varies with the success and failure of
our investment strategies, research, analysis and determination of portfolio securities. If
our investment strategies do not produce the expected returns, the value of the
investment will decrease.
Item 9 – Disciplinary Information
Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that
are material to a client’s or prospective client’s evaluation of our business or integrity.
Item 10 – Other Financial Industry Activities and Affiliations
PMG is not and does not have a related person that is currently or have a pending application to become
a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment
company or other pooled investment vehicle (including a mutual fund, closed-end investment company,
unit investment trust, private investment company or "hedge fund," and offshore fund), another
investment adviser or financial planner, a futures commission merchant, commodity pool operator, or
commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law
firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a
sponsor or syndicator of limited partnerships.
We are an independent registered investment registered adviser and only provide investment advisory
services. We are not engaged in any other business activities and offer no other services except those
described in this Disclosure Brochure. However, while we do not sell products or services other than
investment advice, our representatives may sell other products or provide services outside of their role as
investment adviser representatives with us.
Registered Representative of a Broker-Dealer
Our representatives are also registered representatives of LPL Financial, a securities broker-dealer. You
may work with your investment adviser representative in his or her separate capacity as a registered
representative of LPL Financial.
As a result of this relationship, LPL Financial may have access to certain confidential information (e.g.,
financial information, investment objectives, transactions and holdings) about clients of PMG, even if a
client does not establish any account through LPL Financial. If you would like a copy of the privacy policy
of LPL Financial, please contact your investment adviser representative.
When acting in his or her separate capacity as a registered representative, your investment adviser
representative may sell, for commissions, general securities products such as stocks, bonds, mutual
funds, exchange-traded funds, and variable annuity and variable life products to you. As such, your
investment adviser representative may suggest that you implement investment advice by purchasing
securities products through a commission-based brokerage account in addition to or in lieu of a fee-based
investment-advisory account. This receipt of commissions creates an incentive to recommend those
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Form ADV Part 2A, Rev. 10/2025
products for which your investment adviser representative will receive a commission in his or her separate
capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the
advice rendered to you could be biased. This conflict of interest is addressed by only recommending
investments that are suitable for each client and disclosing the fact that clients are free to utilize any
broker dealer of their choosing to purchase any recommended investments.
You are under no obligation to use the services of our representatives in this separate capacity or to use
LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you
select our representatives to implement securities transactions in their separate capacity as registered
representatives, they must use LPL Financial. Prior to effecting any such transactions, you are required
to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial
may be higher or lower than those charged by other broker/dealers. In addition, the registered
representatives may also receive additional ongoing 12b-1 fees for mutual fund purchases from the
mutual fund company during the period that you maintain the mutual fund investment.
Third-Party Money Managers
PMG has developed programs, previously described in Item 5 of this disclosure brochure, designed to
allow us to recommend and select third-party money managers for you. PMG will only enter in to
agreements with other investment advisory firms that are properly registered in the state of client
residence. Once you select the third-party money manager to manage all or a portion of your assets, the
third-party money manager will pay us a portion of the fees you are charged. We have a conflict of
interest by only offering those third-party money managers that have agreed to pay a portion of their
advisory fee to us and have met the conditions of our due diligence review. This conflict of interest is
addressed by only recommending investments that are suitable for each client. There may be other third-
party money managers that may be suitable for you that may be more or less costly. Please refer to
Items 4 and 5 for full details regarding the programs, fees, conflicts of interest and materials
arrangements when PMG selects other investment advisers.
Dually Registered as an Investment Adviser Representative
To ensure the efficient transition of client accounts the representatives of PMG will temporarily remain
licensed as investment adviser representatives with LPL Financial, LLC. PMG and LPL Financial, LLC
are not affiliated. Through LPL Financial, LLC, the representatives provide asset management services
as well as referrals to sub-advisors. They earn advisory fees when providing these services through LPL
Financial, LLC. Therefore, you could receive advisory services from one individual acting as an
investment adviser representative on behalf of two separate registered investment advisors. If the
representatives of PMG provide services to you, you will be given the disclosure brochure of LPL
Financial, LLC describing the services provided, fees charged and other information. You are
encouraged to read and review the disclosure brochures for both PMG and LPL Financial, LLC and direct
questions to your representative.
This dual registration status is temporary in nature and was established solely to provide continuity in the
services we are able to provide to our clients. Once all client assets have been transferred under the
management of PMG or no later than after 90 days (whichever comes first) the dual registration status will
be terminated by LPL Financial. Clients being transferred under PMG will be provided with an explanation
of the benefits or potential disadvantages of moving to PMG and always have the option of making the
decision to work with another investment advisory firm.
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Insurance Agent
You may work with your investment adviser representative in his or her separate capacity as an
insurance agent. When acting in his or her separate capacity as an insurance agent, the investment
adviser representative may sell, for commissions, general disability insurance, life insurance, annuities,
and other insurance products to you. As such, your investment adviser representative in his or her
separate capacity as an insurance agent, may suggest that you implement recommendations of PMG by
purchasing disability insurance, life insurance, annuities, or other insurance products. This receipt of
commissions creates an incentive for the representative to recommend those products for which your
investment adviser representative will receive a commission in his or her separate capacity as an
insurance agent. Consequently, the advice rendered to you could be biased. You are under no
obligation to implement any insurance or annuity transaction through your investment adviser
representative.
Item 11 – Code of Ethics, Participation in Client Transactions and
Personal Trading
Code of Ethics Summary
An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. PMG has
established a Code of Ethics to comply with the requirements of the securities laws and regulations that
reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires
compliance with federal securities laws. PMG’s Code of Ethics covers all individuals that are classified
as “supervised persons”. All employees, officers, directors and investment adviser representatives are
classified as supervised persons. PMG requires its supervised persons to consistently act in your best
interest in all advisory activities. PMG imposes certain requirements on its affiliates and supervised
persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct
required is higher than ordinarily required and encountered in commercial business.
This section is intended to provide a summary description of the Code of Ethics of PMG. If you wish to
review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your
request, we will promptly provide a copy of the Code of Ethics to you.
Affiliate and Employee Personal Securities Transactions Disclosure
PMG or associated persons of the firm may buy or sell for their personal accounts, investment products
identical to those recommended to clients. This creates a potential conflict of interest. It is the express
policy of PMG that all persons associated in any manner with our firm must place clients’ interests ahead
of their own when implementing personal investments. PMG and its associated persons will not buy or
sell securities for their personal account(s) where their decision is derived, in whole or in part, by
information obtained as a result of employment or association with our firm unless the information is also
available to the investing public upon reasonable inquiry.
We are now and will continue to be in compliance with applicable state and federal rules and regulations.
To prevent conflicts of interest, we have developed written supervisory procedures that include personal
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investment and trading policies for our representatives, employees and their immediate family members
(collectively, associated persons):
• Associated persons cannot prefer their own interests to that of the client.
• Associated persons are prohibited from trading or recommending clients purchase investments in
which you or a related person has a material financial interest. However the firm may recommend
the purchase of no-load mutual funds that pay 12(B) 1 trail commissions. The possible receipt of
these payments presents a conflict of interest which is address by only recommending funds that
are in the best interest of our clients.
• Associated persons cannot purchase or sell any security for their personal accounts prior to
implementing transactions for client accounts.
• Associated persons cannot buy or sell securities for their personal accounts when those
decisions are based on information obtained as a result of their employment, unless that
information is also available to the investing public upon reasonable inquiry.
• Associated persons are prohibited from purchasing or selling securities of companies in which
any client is deemed an “insider”.
• Associated persons are discouraged from conducting frequent personal trading.
• Associated persons are generally prohibited from serving as board members of publicly traded
companies unless an exception has been granted to the Chief Compliance Officer of PMG.
Any associated person not observing our policies is subject to sanctions up to and including termination.
Item 12 – Brokerage Practices
Clients are under no obligation to act on the recommendations of PMG. If the firm assists in the
implementation of any recommendations, we primarily recommend the use of LPL Financial, LLC as the
account custodian and we are responsible to ensure that the client receives the best execution possible.
Best execution does not necessarily mean that clients receive the lowest possible commission costs but
that the qualitative execution is best. In other words, all conditions considered, the transaction execution
is in your best interest. When considering best execution, we look at a number of factors besides prices
and rates including, but not limited to:
• Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution,
responsiveness, integration with our existing systems, ease of monitoring investments)
• Products and services offered (e.g., investment programs, back office services, technology,
regulatory compliance assistance, research and analytic services)
• Financial strength, stability and responsibility
• Reputation and integrity
• Ability to maintain confidentiality
We exercise reasonable due diligence to make certain that best execution is obtained for all clients when
implementing any transaction by considering the back office services, technology and pricing of services
offered. PMG does not receive client referrals from any Broker Dealer.
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Directed Brokerage
Clients should understand that not all investment advisors require the use of a particular broker/dealer or
custodian. Some investment advisors allow their clients to select whichever broker/dealer the client
decides. By requiring clients to use a particular broker/dealer, PMG may not achieve the most favorable
execution of client transactions and the practice requiring the use of specific broker/dealers may cost
clients more money than if the client used a different broker/dealer or custodian. However, for
compliance and operational efficiencies, PMG has decided to require our clients to use broker/dealers
and other qualified custodians determined by PMG.
Broker/Dealer Affiliation (LPL Financial)
If you wish to implement our advice you are free to select any broker you wish. If you wish to have our
representatives implement the advice in their separate capacity as registered representatives, LPL is
used. Our representatives are registered representatives of LPL and we are required to use the services
of LPL when acting in this capacity. LPL has a wide range of approved securities products for which it
performs due diligence prior to selection. LPL’s registered representatives are required to adhere to
these products when implementing securities transactions through LPL. Commissions charged for these
products may be higher or lower than commissions clients may be able to obtain if transactions were
implemented through another broker/dealer.
Because our representatives are also registered representatives of LPL, LPL provides compliance
support to them. LPL also provides our representatives, and therefore us, with back-office operational,
technology and other administrative support.
If you wish to implement our advice through any of the programs described in this Disclosure Brochure,
LPL will be used as the broker/dealer and/or custodian. LPL will be the primary broker/dealer and
custodian recommended due to the relationship our representatives have with LPL. We recommend
broker/dealers and custodians that we feel provide services in a manner and at a cost that will allow us to
meet our duty of best execution. However, we may be limited in the broker/dealer or custodians that we
are allowed to use due to our representatives’ relationship with LPL.
LPL may limit or restrict the broker/dealer or custodial platforms for its registered representatives that are
also independently licensed due to its duty to supervise the transactions implemented by these
individuals. In addition, LPL limits the universe of available mutual funds available to advisors utilizing tier
platform, the available mutual funds on the LPL platform may not be the least expensive share class
available to clients, and clients may be able to get a less expensive mutual fund share classes by utilizing
an investment adviser that is not limited in its investment selection.
While there is no direct linkage between the investment advice given to you and our recommendation of
LPL, economic benefits may be provided to us by LPL that are not provided if you select another
broker/dealer or account custodian. These benefits may include:
• Negotiated costs for transaction implementation
• A dedicated trade desk that services LPL Financial participants exclusively
• A dedicated service group and an account services manager dedicated to our accounts
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• Access to a real-time order matching system
• Electronic download of trades, balances and position information
• Access, for a fee, to an electronic interface with the account custodian’s software
• Duplicate and batched client statements, confirmations and year-end reports
Please also see Item 5, Fees and Compensation, for additional information about advisory services and
implementing recommendations.
Soft Dollar Benefits
An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser
receives research or other products and services in exchange for client securities transactions or
maintaining an account balance with the broker-dealer.
PMG does not have a soft dollar agreement with a broker-dealer or a third-party.
Handling Trade Errors
PMG has implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of PMG to correct
trade errors in a manner that is in the best interest of the client. In cases where the client causes the
trade error, the client is responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client is made
whole and any loss resulting from the trade error is absorbed by PMG if the error is caused by PMG. If
the error is caused by the broker-dealer, the broker-dealer is responsible for handling the trade error. If
an investment gain results from the correcting trade, the gain remains in the client’s account unless the
same error involved other client account(s) that should also receive the gains. It is not permissible for all
clients to retain the gain. PMG may also confer with a client to determine if the client should forego the
gain (e.g., due to tax reasons).
PMG will never benefit or profit from trade errors.
Block Trading Policy
We may elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading or block trading and is used by our firm
when PMG believes such action may prove advantageous to clients. If and when we aggregate client
orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the
process of aggregating client orders is done in order to achieve better execution, to negotiate more
favorable commission rates or to allocate orders among clients on a more equitable basis in order to
avoid differences in prices and transaction fees or other transaction costs that might be obtained when
orders are placed independently.
PMG uses the pro rata allocation method for transaction allocation.
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Under this procedure, pro rata trade allocation means an allocation of the trade at issue among applicable
advisory clients in amounts that are proportional to the participating advisory client’s intended investable
assets. PMG will calculate the pro rata share of each transaction included in a block order and assigns
the appropriate number of shares of each allocated transaction executed for the client’s account.
If and when we determine to aggregate client orders for the purchase or sale of securities, including
securities in which PMG or our associated persons may invest, we will do so in accordance with the
parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated
persons receive any additional compensation as a result of block trades.
Agency Cross Transactions
Our associated persons are prohibited from engaging in agency cross transactions, meaning we cannot
act as brokers for both the sale and purchase of a single security between two different clients and cannot
receive compensation in the form of an agency cross commission or principal mark-up for the trades.
Item 13 – Review of Accounts
Account Reviews and Reviewers
Managed accounts are reviewed at least quarterly. While the calendar is the main triggering factor,
reviews can also be conducted at your request. Account reviews will include investment strategy and
objectives review and making a change if strategy and objectives have changed. Reviews are conducted
by Phillip Guerrero, with reviews performed in accordance with your investment goals and objectives.
Accounts established and maintained with other third-party money managers are reviewed at least
quarterly, usually when statements and/or reports are received from the money manager.
Our financial planning services terminate upon the presentation of the written plan. Our financial planning
and consulting services do not include monitoring the investments of your account(s), and therefore, there
is no ongoing review of your account(s) under such services.
Statements and Reports
For our asset management services, you are provided with transaction confirmation notices and regular
quarterly account statements in writing directly from the qualified custodian.
Account managed by outside money managers will receive reports directly from the outside money
manager as disclosed in their ADV Part 2A Brochure. Reports may be written of electronic.
Financial planning clients do not receive any report other than the written plan originally contracted for
and provided by PMG.
You are encouraged to always compare any reports or statements provided by us, a sub-adviser or third-
party money manager against the account statements delivered from the qualified custodian. When you
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have questions about your account statement, you should contact our firm and the qualified custodian
preparing the statement.
Item 14 – Client Referrals and Other Compensation
PMG does not directly or indirectly compensate any person for client referrals.
The only compensation received from advisory services is the fees charged for providing investment
advisory services as described in Item 5 of this Disclosure Brochure. PMG receives no other forms of
compensation in connection with providing investment advice.
As referenced in Item 4, Advisory Services, Item 5, Fees and Compensation and Item 10, Other Financial
Industry Activities and Affiliations PMG may refer clients to other investment advisory firms and receive a
portion of the advisory fees charged. Please see Item 5, Fees and Compensation, Item 10, Other
Financial Industry Activities and Affiliations and Item 12, Brokerage Practices, for additional discussion
concerning other compensation and the conflicts of interest created.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or control
over client funds and/or securities. In other words, custody is not limited to physically holding client funds
and securities. If an investment adviser has the ability to access or control client funds or securities, the
investment adviser is deemed to have custody and must ensure proper procedures are implemented.
Since LPL Financial is responsible for calculating and deducting the advisory fee from client accounts
PMG is not considered to have custody.
Client will receive account statements directly from the qualified custodian to each client, or the client’s
independent representative, at least quarterly. Clients should carefully review those statements and are
urged to compare the statements against correspondence or reports received from PMG Wealth. When
clients have questions about their account statements, they should contact PMG Wealth or the qualified
custodian preparing the statement.
Item 16 – Investment Discretion
When providing asset management services, PMG maintains trading authorization over your Account and
can provide management services on a discretionary basis. When discretionary authority is granted, we
will have the authority to determine the type of securities and the amount of securities that can be bought
or sold for your portfolio without obtaining your consent for each transaction.
If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact
you prior to implementing changes in your account. Therefore, you will be contacted and required to
accept or reject our investment recommendations including:
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• The security being recommended
• The number of shares or units
• Whether to buy or sell
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, you need to know that if we are not able to reach
you or you are slow to respond to our request, it can have an adverse impact on the timing of trade
implementations and we may not achieve the optimal trading price.
You will have the ability to place reasonable restrictions on the types of investments that may be
purchased in your Account. You may also place reasonable limitations on the discretionary power
granted to PMG so long as the limitations are specifically set forth or included as an attachment to the
client agreement.
Client will grant PMG discretionary authority (without first consulting with Client) to establish and/or
terminate a relationship with a Sub-Adviser for purposes of managing the Account or a portion of the
Account determined by PMG. Client will also grant the Sub-Adviser selected by PMG with the
discretionary authority (in the sole discretion of the Sub-Adviser without first consulting with Client) to
make all decisions to buy, sell or hold securities, cash or other investments for such portion of the
Account managed by the Sub-Adviser. Client will also grant the Sub-Adviser selected by PMG with the
power and authority to carry out these decisions by giving instructions, on behalf of Client, to brokers and
dealers and the qualified custodian(s) of the Account. Client authorizes PMG to provide a copy of this
Agreement to the qualified custodian or any broker or dealer, through which transactions will be
implemented on behalf of Client, as evidence of Sub-Adviser’s authority under this Agreement.
Item 17 – Voting Client Securities
Proxy Voting
PMG does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities
for voting client securities does not add enough value to the services provided to you to justify the
additional compliance and regulatory costs associated with voting client securities. Therefore, it is your
responsibility to vote all proxies for securities held in Account.
You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with
the proxies. You are encouraged to read through the information provided with the proxy-voting
documents and make a determination based on the information provided.
With respect to assets managed by a third-party money manager, we will not vote the proxies associated
with these assets. You will need to refer to each third-party money manager’s disclosure brochure to
determine whether the third-party money manager will vote proxies on your behalf. You may request a
complete copy of third-party money manager’s proxy voting policies and procedures as well as
information on how your proxies were voted by contacting the third-party money manager or by
contacting PMG at the address or phone number indicated on Page 1 of this disclosure document.
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Item 18 – Financial Information
This Item 18 is not applicable to this brochure. PMG does not require or solicit prepayment of more than
$500 in fees per client, six months or more in advance. Therefore, we are not required to include a
balance sheet for the 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 clients. Finally, PMG has not
been the subject of a bankruptcy petition at any time.
Business Continuity Plan
PMG has a business continuity and contingency plan in place designed to respond to significant business
disruptions. These disruptions can be both internal and external. Internal disruptions will impact our
ability to communicate and do business, such as a fire in the office building. External disruptions will
prevent the operation of the securities markets or the operations of a number of firms, such as
earthquakes, wildfires, hurricanes, terrorist attack or other wide-scale, regional disruptions.
Our continuity and contingency plan has been developed to safeguard employees’ lives and firm property,
to allow a method of making financial and operational assessments, to quickly recover and resume
business operations, to protect books and records, and to allow clients to continue transacting business.
The plan includes the following:
• Alternate locations to conduct business;
• Hard and electronic back-ups of records;
• Alternative means of communications with employees, clients, critical business constituents
and regulators; and
• Details on the firms’ employee succession plan
Our business continuity and contingency plan is reviewed and updated on a regular basis to ensure that
the policies in place are sufficient and operational.
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Customer Privacy Policy Notice
Commitment to Your Private Information: PMG Wealth Management has a long standing policy of
protecting the confidentiality and security information we collect about our clients. We do not, and will
not, share nonpublic personal information about you (“Information”) with outside third parties without your
consent, except for the specific purposes described below. This notice has been provided to you to
describe the Information we may gather and the situations under which we may need to share it.
Why We Collect and How We Use Information. We limit the collection and use of Information within
our firm to only those individuals associated or employed with us that must have Information to provide
financial services to you. Such services include maintaining your accounts, processing transaction
requests, providing financial planning, financial consultation, and other services described in our Form
ADV.
How We Gather Information. We get most Information directly from you when you provide us with
information from any of the following sources:
• Applications or forms (for example: name, address, social security number, birth date, assets,
income, financial history)
• Transactional activity in your account (for example: trading history and account balances)
•
Information services and consumer reporting sources (for example: to verify your identity or to
assess your credit history)
• Other sources with your consent (for example: your insurance professional, attorney, or
accountant)
How We Protect Information. Our employees and affiliated persons are required to protect the
confidentiality of Information and to comply with our stated policies. They may access Information only
when there is an acceptable reason to do so, such as to service your account or provide you with
financial services. Employees who violate our Privacy Policy are subject to disciplinary action, up to and
including termination from employment with us. We also maintain physical, electronic, and procedural
safeguards to protect information, which comply with applicable SEC, state, and federal laws.
Sharing Information with Other Companies Permitted Under Law. We do not disclose Information
obtained in the course of our practice except as required or permitted under law. Permitted disclosures
include, for instance, providing information to unrelated third parties who need to know such Information
in order to assist use with the providing services to you. Unrelated third parties may include
broker/dealers, mutual fund companies, insurance companies, and the custodian with which your assets
are held. In such situations, we stress the confidential nature of information being shared.
Former Customers. Even if we cease to provide you with financial products or services, our Privacy
Policy will continue to apply to you and we will continue to treat your nonpublic information with strict
confidentiality.
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FORM ADV PART 2B BROCHURE SUPPLEMENT - Phillip Guerrero
Item 1 – Cover Page
Phillip Guerrero
PMG Wealth Management, Inc.
60 Landover Parkway, Suite D
Hawthorn Woods, IL 60047
847-550-6100
www.pmgwealth.com
Date of Supplement: September 2025
This brochure supplement provides information about Phillip Guerrero that supplements the PMG
Management, Inc. (“PMG”) disclosure brochure. You should have received a copy of that
brochure. Please contact Phillip Guerrero at 847-550-6100 or at phil@pmgwealth.com if you did
not receive PMG’s brochure or if you have any questions about the contents of this supplement.
Additional information about Phillip Guerrero is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Phillip Guerrero
Born 1975, CRD # 2896913
Post-Secondary Educational Background:
Illinois State University, BSBA - Finance: 1997
Business Background:
PMG Wealth Management Inc., Investment Advisor Representative, 01/2017 to Present;
PMG Wealth Management, President, 10/2007 to Present
LPL Financial, LLC, Registered Representative, 10/2007 to Present
A.G. Edwards & Sons, Financial Consultant, 01/1997 to 10/2007
Professional Designations
Certified Financial Planner (CFP)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by
Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries
for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice;
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and (3) ethical requirements that govern professional engagements with clients. Currently, more than
62,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
• Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent from a
foreign university). CFP Board’s financial planning subject areas include insurance planning and
risk management, employee benefits planning, investment planning, income tax planning,
retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or
the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
CFP Acknowledgment: (ADVISOR) acknowledges his responsibility as a CFP® Certificant to adhere to
the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you
become aware that (ADVISOR)’s conduct may violate the Standards of Professional Conduct, you may
file a complaint with the CFP Board at www.CFP.net/complaint.
Code of Ethics for CFP
The following disclosure has been included in the COE section of the 2A.
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In addition to abiding by our Code of Ethics, some of our representatives are Certified Financial
Planners™ (CFP®) and also abide by the Code of Ethics and Responsibility Code of the Certified
Financial Planner™ Board of Standards, Inc. The Code of Ethics and Responsibility Code
requires CFP® designees to not only comply with all applicable laws and regulations but to also
act in an ethical and professional responsible manner in all professional services and
activities. The principles guiding CFP® designees are:
•
Integrity
• Objectivity
• Competence (in providing services and maintaining knowledge and skills to do so)
• Fairness (to clients, principals, partners and employers and disclosing any conflicts of
interest in providing services)
• Confidentiality (keeping all client information confidential without the specific client
consent unless in response to legal process or in defense of charges of wrongdoing or
civil dispute)
• Professionalism
• Diligence
You can obtain a copy of the Code of Ethics and Responsibility Code by requesting a copy from
one of our representatives.
Item 3 – Disciplinary Information
Phillip Guerrero has no legal or disciplinary events to report.
Item 4 – Other Business Activities
Registered Representative of a Broker-Dealer
Phillip Guerrero is separately licensed as a registered representative with LPL Financial, LLC, a
registered securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA) and
the Securities Investors Protection Corporation (SIPC). When acting in his separate capacity as a
registered representative of LPL Financial, LLC, Phillip Guerrero may sell, for commissions, general
securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity
and variable life products to advisory clients. As such, Phillip Guerrero may suggest that advisory clients
implement investment advice by purchasing securities products through a commission-based LPL
Financial, LLC account in addition to a PMG advisory account.
The receipt of commissions creates an incentive for Phillip Guerrero to recommend those products for
which he will receive a commission. Consequently, the objectivity of the advice rendered to clients could
be biased. Phillip Guerrero controls for this potential conflict of interest by discussing with clients the
advantages and disadvantages of establishing a fee-based account through PMG versus establishing a
commission-based account through LPL Financial, LLC. PMG does not require its advisor
representatives to encourage clients to implement investment advice through LPL Financial, LLC.
Phillip Guerrero does not earn commissions in fee-based accounts.
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Phillip Guerrero will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s
prospectus. 12b-1 fees come from fund assets, therefore, indirectly from client assets. The receipt of
such fees could represent an incentive for Phillip Guerrero to recommend funds with 12b-1 fees over
funds that have no fees or lower fees. Typically, Phillip Guerrero will receive 12b-1 fees only in
commission-based brokerage accounts. However, such fees can be earned in fee-based accounts
managed by Phillip Guerrero if 12b-1 fee paying mutual funds are held in the managed account. For
ERISA accounts, there is an offset for any amount of 12b-1 fees. In such a situation, Phillip Guerrero
discusses with clients the selection of a 12b-1 or other trail paying mutual funds. LPL Financial, LLC
maintains records of all 12b-1 fee payments to Phillip Guerrero which may be viewed by clients upon
request.
Clients are never obligated or required to establish accounts through PMG or LPL Financial, LLC.
However, if a client does not choose to accept Phillip Guerrero’s advice or decides not to establish an
account through LPL Financial, LLC, Phillip Guerrero may not be able to provide management and
advisory services to the client. Clients should understand that, due to certain regulatory constraints,
Phillip Guerrero, in his capacity as an LPL Financial, LLC. Phillip Guerrero must place all purchases and
sales of securities products in commission-based brokerage accounts through LPL Financial, LLC or its
other approved institutions.
Insurance Agent
Phillip Guerrero is independently licensed to sell insurance and annuity products through various
insurance companies. When acting in this capacity, Phillip Guerrero will receive commissions for selling
insurance and annuity products.
Phillip Guerrero may also receive other incentive awards for the recommendation/sale of annuities and
other insurance products. The receipt of compensation and other incentive benefits may affect the
judgment of Phillip Guerrero when recommending products to its clients. While Phillip Guerrero
endeavors at all times to put the interest of his clients first as a part of PMG’s overall fiduciary duty to
clients, clients should be aware that the receipt of commissions and additional compensation itself
creates a conflict of interest, and may affect Phillip Guerrero’s decision making process when making
recommendations.
Clients are never obligated or required to purchase insurance products from or through Phillip Guerrero
and may choose any independent insurance agent and insurance company to purchase insurance
products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal
commissions from the sale.
Notary Public
Mr. Guerrero is also a Notary Public with the state of Illinois.
Item 5 – Additional Compensation
In addition to the description of additional compensation provided in Item 4, Phillip Guerrero can receive
additional benefits.
PMG Wealth Management
Page 37
Form ADV Part 2A, Rev. 10/2025
Certain product sponsors may provide Phillip Guerrero with other economic benefits from LPL Financial
as a result of his recommendation or sale of the product sponsors’ investments. The economic benefits
received by Phillip Guerrero from product sponsors can include but are not limited to, financial assistance
or the sponsorship of conferences and educational sessions, marketing support, incentive awards,
payment of travel expenses, and tools to assist Phillip Guerrero in providing various services to clients.
This potential additional compensation creates a conflict of interest. PMG and Phillip Guerrero endeavor
at all times to put the interest of its clients ahead of its own or those of its officers, directors, or
representatives (“affiliated persons”), these arrangements could affect the judgment of Phillip Guerrero
when recommending investment products. These situations present a conflict of interest that may affect
the judgment of affiliated persons including Phillip Guerrero.
Item 6 – Supervision
Phillip Guerrero is the Chief Compliance Officer of PMG. He is responsible for overseeing and enforcing
the firm’s compliance programs that have been established to monitor and supervise the activities and
services provided by the firm and its representatives. Phillip Guerrero can be contacted at 847-550-6100.
PMG Wealth Management
Page 38
Form ADV Part 2A, Rev. 10/2025
FORM ADV PART 2B BROCHURE SUPPLEMENT - Daniel R. Dame
Item 1 – Cover Page
Daniel R. Dame
PMG Wealth Management, Inc.
3720 SW 11th Court
Cape Coral, FL 33914
239-257-1803
www.pmgwealth.com
Date of Supplement: September 2025
This brochure supplement provides information about Daniel R. Dame that supplements the PMG
Management, Inc. (“PMG”) disclosure brochure. You should have received a copy of that
brochure. Please contact Phillip Guerrero at 847-550-6100 or at phil@pmgwealth.com if you did
not receive PMG’s brochure or if you have any questions about the contents of this supplement.
Additional information about Daniel R. Dame is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Daniel R. Dame
Born 1947; CRD # 1206871
Post-Secondary Educational Background:
Taylor University, Bachelor’s Degree – Business Administration: 1969
Business Background:
PMG Wealth Management Inc., Investment Advisor Representative, 01/2017 to Present;
LPL Financial, LLC. Registered Representative, 10/2009 to Present
Dame Financial Services, President, 12/2009 to Present
Mutual Service Corp, Registered Representative, 02/2009 to 09/2009
MetLife Securities, Inc. Registered Representative, 08/1999 to 02/2009
Item 3 – Disciplinary Information
In March 2017 Daniel R. Dame entered a Consent Order with the state of Florida to settle a regulatory
matter that alleged that he conducted investment advisory services from a location within the state of
Florida without being lawfully registered in Florida from September 1, 2015, through December 2016. In
the settlement Mr. Dame agreed to the entry of a Cease and Desist order and a monetary penalty.
PMG Wealth Management
Page 39
Form ADV Part 2A, Rev. 10/2025
Ultimately Mr. Dame’s broker dealer, LPL Financial, paid the penalty as its registration department failed
to notify Florida after Mr. Dame’s request to update his licenses. Once all was corrected Mr. Dame was
successfully approved in the state of Florida.
Item 4 – Other Business Activities
Registered Representative of a Broker-Dealer
Daniel R. Dame is separately licensed as a registered representative with LPL Financial, LLC, a
registered securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA) and
the Securities Investors Protection Corporation (SIPC). When acting in his separate capacity as a
registered representative of LPL Financial, LLC, Daniel R. Dame may sell, for commissions, general
securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity
and variable life products to advisory clients. As such, Daniel R. Dame may suggest that advisory clients
implement investment advice by purchasing securities products through a commission-based LPL
Financial, LLC account in addition to a PMG advisory account.
The receipt of commissions creates an incentive for Daniel R. Dame to recommend those products for
which he will receive a commission. Consequently, the objectivity of the advice rendered to clients could
be biased. Daniel R. Dame controls for this potential conflict of interest by discussing with clients the
advantages and disadvantages of establishing a fee-based account through PMG versus establishing a
commission-based account through LPL Financial, LLC. PMG does not require its advisor
representatives to encourage clients to implement investment advice through LPL Financial, LLC.
Daniel R. Dame does not earn commissions in fee-based accounts.
Daniel R. Dame will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s
prospectus. 12b-1 fees come from fund assets, therefore, indirectly from client assets. The receipt of
such fees could represent an incentive for Daniel R. Dame to recommend funds with 12b-1 fees over
funds that have no fees or lower fees. Typically, Daniel R. Dame will receive 12b-1 fees only in
commission-based brokerage accounts. However, such fees can be earned in fee-based accounts
managed by Daniel R. Dame if 12b-1 fee paying mutual funds are held in the managed account. For
ERISA accounts, there is an offset for any amount of 12b-1 fees. In such a situation, Daniel R. Dame
discusses with clients the selection of a 12b-1 or other trail paying mutual funds. LPL Financial, LLC
maintains records of all 12b-1 fee payments to Daniel R. Dame which may be viewed by clients upon
request.
Clients are never obligated or required to establish accounts through PMG or LPL Financial, LLC.
However, if a client does not choose to accept Daniel R. Dame’s advice or decides not to establish an
account through LPL Financial, LLC, Daniel R. Dame may not be able to provide management and
advisory services to the client. Clients should understand that, due to certain regulatory constraints,
Daniel R. Dame, in his capacity as a LPL Financial, LLC. Daniel R. Dame must place all purchases and
sales of securities products in commission-based brokerage accounts through LPL Financial, LLC or its
other approved institutions.
PMG Wealth Management
Page 40
Form ADV Part 2A, Rev. 10/2025
Insurance Agent
Daniel R. Dame is independently licensed to sell insurance and annuity products through various
insurance companies. When acting in this capacity, Daniel R. Dame will receive commissions for selling
insurance and annuity products.
Daniel R. Dame may also receive other incentive awards for the recommendation/sale of annuities and
other insurance products. The receipt of compensation and other incentive benefits may affect the
judgment of Daniel R. Dame when recommending products to its clients. While Daniel R. Dame
endeavors at all times to put the interest of his clients first as a part of PMG’s overall fiduciary duty to
clients, clients should be aware that the receipt of commissions and additional compensation itself
creates a conflict of interest, and may affect Daniel R. Dame ’s decision making process when making
recommendations.
Clients are never obligated or required to purchase insurance products from or through Daniel R. Dame
and may choose any independent insurance agent and insurance company to purchase insurance
products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal
commissions from the sale.
Item 5 – Additional Compensation
In addition to the description of additional compensation provided in Item 4, Daniel R. Dame can receive
additional benefits.
Certain product sponsors may provide Daniel R. Dame with other economic benefits from LPL Financial
as a result of his recommendation or sale of the product sponsors’ investments. The economic benefits
received by Daniel R. Dame from product sponsors can include but are not limited to, financial assistance
or the sponsorship of conferences and educational sessions, marketing support, incentive awards,
payment of travel expenses, and tools to assist Daniel R. Dame in providing various services to clients.
This potential additional compensation creates a conflict of interest. PMG and Daniel R. Dame endeavor
at all times to put the interest of its clients ahead of its own or those of its officers, directors, or
representatives (“affiliated persons”), these arrangements could affect the judgment of Daniel R. Dame
when recommending investment products. These situations present a conflict of interest that may affect
the judgment of affiliated persons including Daniel R. Dame.
Item 6 – Supervision
Phillip Guerrero is the Chief Compliance Officer of PMG. He is responsible for overseeing and enforcing
the firm’s compliance programs that have been established to monitor and supervise the activities and
services provided by the firm and its representatives. Phillip Guerrero can be contacted at 847-550-6100.
PMG Wealth Management
Page 41
Form ADV Part 2A, Rev. 10/2025
FORM ADV PART 2B BROCHURE SUPPLEMENT – George Maroudas
Item 1 – Cover Page
George Maroudas
PMG Wealth Management, Inc.
60 Landover Parkway, Suite D
Hawthorn Woods, IL 60047
847-550-6100
www.pmgwealth.com
Date of Supplement: September 2025
This brochure supplement provides information about George Maroudas that supplements the
PMG Management, Inc. (“PMG”) disclosure brochure. You should have received a copy of that
brochure. Please contact Phillip Guerrero at 847-550-6100 or at phil@pmgwealth.com if you did
not receive PMG’s brochure or if you have any questions about the contents of this supplement.
Additional information about George Maroudas is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
George Maroudas
Born 1996, CRD # 6950499
Post-Secondary Educational Background:
Michigan State University, BSBA - Finance: 2019
Business Background:
PMG Wealth Management Inc., Investment Advisor Representative, 01/2020 to Present
LPL Financial, LLC, Registered Representative, 1/20 to Present
PMG Wealth Management, Wealth Management Coordinator, 5/19-1/20
Professional Designations
George Maroudas has no additional professional designations at this time.
Item 3 – Disciplinary Information
George Maroudas has no legal or disciplinary events to report.
PMG Wealth Management
Page 42
Form ADV Part 2A, Rev. 10/2025
Item 4 – Other Business Activities
Registered Representative of a Broker-Dealer
George Marounas is separately licensed as a registered representative with LPL Financial, LLC, a
registered securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA) and
the Securities Investors Protection Corporation (SIPC). When acting in his separate capacity as a
registered representative of LPL Financial, LLC, George Maroudas may sell, for commissions, general
securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity
and variable life products to advisory clients. As such, George Maroudas may suggest that advisory
clients implement investment advice by purchasing securities products through a commission-based LPL
Financial, LLC account in addition to a PMG advisory account.
The receipt of commissions creates an incentive for George Maroudas to recommend those products for
which he will receive a commission. Consequently, the objectivity of the advice rendered to clients could
be biased. George Maroudas controls for this potential conflict of interest by discussing with clients the
advantages and disadvantages of establishing a fee-based account through PMG versus establishing a
commission-based account through LPL Financial, LLC. PMG does not require its advisor
representatives to encourage clients to implement investment advice through LPL Financial, LLC.
George Maroudas does not earn commissions in fee-based accounts.
George Maroudas will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s
prospectus. 12b-1 fees come from fund assets, therefore, indirectly from client assets. The receipt of
such fees could represent an incentive for George Maroudas to recommend funds with 12b-1 fees over
funds that have no fees or lower fees. Typically, George Maroudas will receive 12b-1 fees only in
commission-based brokerage accounts. However, such fees can be earned in fee-based accounts
managed by George Maroudas if 12b-1 fee paying mutual funds are held in the managed account. For
ERISA accounts, there is an offset for any amount of 12b-1 fees. In such a situation, Phillip Guerrero
discusses with clients the selection of a 12b-1 or other trail paying mutual funds. LPL Financial, LLC
maintains records of all 12b-1 fee payments to Phillip Guerrero which may be viewed by clients upon
request.
Clients are never obligated or required to establish accounts through PMG or LPL Financial, LLC.
However, if a client does not choose to accept George Maroudas’ advice or decides not to establish an
account through LPL Financial, LLC, George Maroudas may not be able to provide management and
advisory services to the client. Clients should understand that, due to certain regulatory constraints,
George Maroudas, in his capacity as a LPL Financial, LLC. George Maroudas must place all purchases
and sales of securities products in commission-based brokerage accounts through LPL Financial, LLC or
its other approved institutions.
Insurance Agent
George Maroudas is independently licensed to sell insurance and annuity products through various
insurance companies. When acting in this capacity, George Maroudas will receive commissions for
selling insurance and annuity products.
PMG Wealth Management
Page 43
Form ADV Part 2A, Rev. 10/2025
George Maroudas may also receive other incentive awards for the recommendation/sale of annuities and
other insurance products. The receipt of compensation and other incentive benefits may affect the
judgment of George Maroudas when recommending products to its clients. While George Maroudas
endeavors at all times to put the interest of his clients first as a part of PMG’s overall fiduciary duty to
clients, clients should be aware that the receipt of commissions and additional compensation itself
creates a conflict of interest, and may affect George Maroudas’ decision making process when making
recommendations.
Clients are never obligated or required to purchase insurance products from or through George Maroudas
and may choose any independent insurance agent and insurance company to purchase insurance
products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal
commissions from the sale.
Item 5 – Additional Compensation
In addition to the description of additional compensation provided in Item 4, George Maroudas can
receive additional benefits.
Certain product sponsors may provide George Maroudas with other economic benefits from LPL
Financial as a result of his recommendation or sale of the product sponsors’ investments. The economic
benefits received by George Maroudas from product sponsors can include but are not limited to, financial
assistance or the sponsorship of conferences and educational sessions, marketing support, incentive
awards, payment of travel expenses, and tools to assist George Maroudas in providing various services
to clients.
This potential additional compensation creates a conflict of interest. PMG and George Maroudas
endeavor at all times to put the interest of its clients ahead of its own or those of its officers, directors, or
representatives (“affiliated persons”), these arrangements could affect the judgment of George Maroudas
when recommending investment products. These situations present a conflict of interest that may affect
the judgment of affiliated persons including George Maroudas.
Item 6 – Supervision
George Maroudas is supervised by Phillip Guerrero, Chief Compliance Officer of PMG. Phillip Guerrero
is responsible for overseeing and enforcing the firm’s compliance programs that have been established to
monitor and supervise the activities and services provided by the firm and its representatives. Phillip
Guerrero can be contacted at 847-550-6100.
PMG Wealth Management
Page 44
Form ADV Part 2A, Rev. 10/2025
FORM ADV PART 2B BROCHURE SUPPLEMENT – Ryan Zentz
Item 1 – Cover Page
Ryan Zentz
PMG Wealth Management, Inc.
60 Landover Parkway, Suite D
Hawthorn Woods, IL 60047
847-550-6100
www.pmgwealth.com
Date of Supplement: September 2025
This brochure supplement provides information about Ryan Zentz that supplements the PMG
Management, Inc. (“PMG”) disclosure brochure. You should have received a copy of that
brochure. Please contact Phillip Guerrero at 847-550-6100 or at phil@pmgwealth.com if you did
not receive PMG’s brochure or if you have any questions about the contents of this supplement.
Additional information about Ryan Zentz is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Ryan Zentz
Born 2000, CRD # 7566664
Post-Secondary Educational Background:
University of Kentucky, BSBA - Finance: 2023
Business Background:
PMG Wealth Management Inc., Investment Advisor Representative, 04/2024 to Present
LPL Financial, LLC, Registered Representative, 03/2024 to Present
LPL Financial, LLC, Client Service Associate, 05/2023 to 03/2024
PMG Wealth Management, Wealth Management Client Service Associate, 05/2023 to 04/2024
Door Dash, Driver, 09/2020 to 03/2021
Lake Point, Landscaper, 05/2020 t0 08/2020
Professional Designations
Ryan Zentz has no additional professional designations at this time.
Item 3 – Disciplinary Information
Ryan Zentz has no legal or disciplinary events to report.
PMG Wealth Management
Page 45
Form ADV Part 2A, Rev. 10/2025
Item 4 – Other Business Activities
Registered Representative of a Broker-Dealer
Ryan Zentz is separately licensed as a registered representative with LPL Financial, LLC, a registered
securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA) and the
Securities Investors Protection Corporation (SIPC). When acting in his separate capacity as a registered
representative of LPL Financial, LLC, Ryan Zentz may sell, for commissions, general securities products
such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life
products to advisory clients. As such, Ryan Zentz may suggest that advisory clients implement
investment advice by purchasing securities products through a commission-based LPL Financial, LLC
account in addition to a PMG advisory account.
The receipt of commissions creates an incentive for Ryan Zentz to recommend those products for which
he will receive a commission. Consequently, the objectivity of the advice rendered to clients could be
biased. Ryan Zentz controls for this potential conflict of interest by discussing with clients the advantages
and disadvantages of establishing a fee-based account through PMG versus establishing a commission-
based account through LPL Financial, LLC. PMG does not require its advisor representatives to
encourage clients to implement investment advice through LPL Financial, LLC.
Ryan Zentz does not earn commissions in fee-based accounts.
Ryan Zentz will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s
prospectus. 12b-1 fees come from fund assets, therefore, indirectly from client assets. The receipt of
such fees could represent an incentive for Ryan Zentz to recommend funds with 12b-1 fees over funds
that have no fees or lower fees. Typically, Ryan Zentz will receive 12b-1 fees only in commission-based
brokerage accounts. However, such fees can be earned in fee-based accounts managed by Ryan Zentz
if 12b-1 fee paying mutual funds are held in the managed account. For ERISA accounts, there is an
offset for any amount of 12b-1 fees. In such a situation, Phillip Guerrero discusses with clients the
selection of a 12b-1 or other trail paying mutual funds. LPL Financial, LLC maintains records of all 12b-1
fee payments to Phillip Guerrero which may be viewed by clients upon request.
Clients are never obligated or required to establish accounts through PMG or LPL Financial, LLC.
However, if a client does not choose to accept Ryan Zentz’ advice or decides not to establish an account
through LPL Financial, LLC, Ryan Zentz may not be able to provide management and advisory services
to the client. Clients should understand that, due to certain regulatory constraints, Ryan Zentz, in his
capacity as a LPL Financial, LLC. Ryan Zentz must place all purchases and sales of securities products
in commission-based brokerage accounts through LPL Financial, LLC or its other approved institutions.
Item 5 – Additional Compensation
In addition to the description of additional compensation provided in Item 4, Ryan Zentz can receive
additional benefits.
Certain product sponsors may provide Ryan Zentz with other economic benefits from LPL Financial as a
result of his recommendation or sale of the product sponsors’ investments. The economic benefits
received by Ryan Zentz from product sponsors can include but are not limited to, financial assistance or
PMG Wealth Management
Page 46
Form ADV Part 2A, Rev. 10/2025
the sponsorship of conferences and educational sessions, marketing support, incentive awards, payment
of travel expenses, and tools to assist Ryan Zentz in providing various services to clients.
This potential additional compensation creates a conflict of interest. PMG and Ryan Zentz endeavor at all
times to put the interest of its clients ahead of its own or those of its officers, directors, or representatives
(“affiliated persons”), these arrangements could affect the judgment of Ryan Zentz when recommending
investment products. These situations present a conflict of interest that may affect the judgment of
affiliated persons including Ryan Zentz.
Item 6 – Supervision
Ryan Zentz is supervised by Phillip Guerrero, Chief Compliance Officer of PMG. Phillip Guerrero is
responsible for overseeing and enforcing the firm’s compliance programs that have been established to
monitor and supervise the activities and services provided by the firm and its representatives. Phillip
Guerrero can be contacted at 847-550-6100.
PMG Wealth Management
Page 47
Form ADV Part 2A, Rev. 10/2025