ROSEMEYER MANAGEMENT GROUP

Form ADV Part 2A: Firm Brochure Item 1 – Cover Page RMG Wealth Management, LLC Doing business as Rosemeyer Management Group 1290 E Mineral St. Platteville, WI 53818 608-348-2274 www.rosemeyermg.com Date of Disclosure Brochure: November 2025 ____________________________________________________________________________________ This disclosure brochure provides information about the qualifications and business practices of RMG Wealth Management, LLC doing business as Rosemeyer Management Group (also referred to as we, us and RMG throughout this disclosure brochure). If you have any questions about the contents of this disclosure brochure, please contact Andrew Tranel at 608-348-2274 or andrew@rosemeyermg.com. The 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 Rosemeyer Management Group is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for RMG Wealth Management, LLC or our firm’s CRD number 310363. *Registration as an investment adviser does not imply a certain level of skill or training. RMG Wealth Management, LLC Page 1 Form ADV Part 2A Firm Brochure  Item 2 – Material Changes Since filing our last annual update in March 2025, the following change has been made to this disclosure brochure: • In November 2025 the firm updated its Asset Management Fee Schedule. Please refer to Item 5- Fees and Compensation for more specific information. We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s 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 or provide a copy of the most current disclosure brochure. We may also provide other ongoing disclosure information about material changes, as necessary. RMG Wealth Management, LLC Page 2 Form ADV Part 2A Firm Brochure  Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Introduction................................................................................................................................................ 4 Description of Advisory Services .............................................................................................................. 4 Limits Advice to Certain Types of Investments ......................................................................................... 9 Tailor Advisory Services to Individual Needs of Clients ............................................................................ 9 Client Assets Managed by Rosemeyer Management Group .................................................................. 10 Item 5 – Fees and Compensation ............................................................................................................... 10 Asset Management Services .................................................................................................................. 10 Financial Planning Services .................................................................................................................... 11 Retirement Plan Services ........................................................................................................................ 13 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 14 Item 7 – Types of Clients ............................................................................................................................ 14 Minimum Investment Amounts Required ................................................................................................ 14 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 14 Methods of Analysis ................................................................................................................................ 14 Investment Strategies ............................................................................................................................. 16 Primarily Recommend One Type of Security .......................................................................................... 17 Risk of Loss ............................................................................................................................................. 17 Item 9 – Disciplinary Information ................................................................................................................. 19 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 19 Insurance Agent ...................................................................................................................................... 19 Accounting Services ................................................................................................................................ 20 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 20 Code of Ethics Summary ........................................................................................................................ 20 Affiliate and Employee Personal Securities Transactions Disclosure..................................................... 21 Item 12 – Brokerage Practices .................................................................................................................... 21 Brokerage Recommendations................................................................................................................. 22 Directed Brokerage ................................................................................................................................. 23 Block Trading Policy ................................................................................................................................ 23 Agency Cross Transactions .................................................................................................................... 24 Item 13 – Review of Accounts .................................................................................................................... 24 Account Reviews and Reviewers ............................................................................................................ 24 Statements and Reports ......................................................................................................................... 24 Item 14 – Client Referrals and Other Compensation .................................................................................. 24 Item 15 – Custody ....................................................................................................................................... 25 Item 16 – Investment Discretion ................................................................................................................. 25 Item 17 – Voting Client Securities ............................................................................................................... 26 Class Action Lawsuits ................................................................................................................................. 26 Item 18 – Financial Information ................................................................................................................... 26 Customer Privacy Policy Notice .................................................................................................................. 26 Business Continuity Plan ............................................................................................................................ 27 RMG Wealth Management, LLC Page 3 Form ADV Part 2A Firm Brochure  Item 4 – Advisory Business Rosemeyer Management Group is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a corporation formed under the laws of the State of Wisconsin. • Jacob E. Rosemeyer is the Chief Executive Officer and 12.5% owner of Rosemeyer Management Group and Andrew T. Tranel is the Chief Investment Officer, Chief Compliance Officer and 50% owner of Rosemeyer Management Group. Regan Shipp, Payton Simon and Kaley Bockhop each own 12.5% of the firm • Rosemeyer Management Group was approved as an investment adviser in November 2020. Introduction The investment advisory services of RMG are provided to you through an appropriately licensed individual who is an investment adviser representative of RMG (referred to as your investment adviser representative throughout this brochure). 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.]] Description of Advisory Services The following are descriptions of the primary advisory services of Rosemeyer Management Group. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and RMG before we can provide you the services described below. Asset Management Services – RMG offers asset management services, which involves RMG providing you with continuous and ongoing supervision over your specified accounts. 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 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 RMG Wealth Management, LLC Page 4 Form ADV Part 2A Firm Brochure  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 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 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 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 cannot 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 Services - RMG offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. When providing financial planning 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. Written financial plans prepared by us do not include specific recommendations of individual securities. Our financial planning services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning recommendations. To the extent that you would like to implement any of our investment recommendations through RMG or retain RMG to actively monitor and manage your investments, you must execute a separate written agreement with RMG for our asset management services. Retirement Plan Services - RMG 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 RMG provides the following Fiduciary Retirement Plan Consulting Services: • Investment Policy Statement Preparation. RMG 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. RMG 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. RMG will provide you with recommendations of investment options consistent with ERISA section 404(c). RMG Wealth Management, LLC Page 5 Form ADV Part 2A Firm Brochure  • Investment Due Diligence Review. RMG will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations. • Investment Monitoring. RMG 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 RMG will make recommendations to maintain or remove and replace investment options. • Default Investment Alternative Advice. RMG 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, RMG 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 RMG does not serve as administrator or trustee of the plan. RMG 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). RMG 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 of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. RMG will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause RMG to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, RMG (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. RMG Wealth Management, LLC Page 6 Form ADV Part 2A Firm Brochure  RMG provides clients with the following Non-Fiduciary Retirement Plan Consulting Services: • Participant Education. RMG will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Rosemeyer Management Group’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. RMG 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. RMG 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. RMG 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. RMG 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. RMG will provide you benchmarking services and will provide analysis concerning the operations of the Plan. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. 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 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, RMG 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. RMG Wealth Management, LLC Page 7 Form ADV Part 2A Firm Brochure  RMG 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 - To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by RMG please know that RMG 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 Rollover IRA managed by Rosemeyer Management Group. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by Rosemeyer Management Group. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover 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 RMG receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by RMG and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. To the extent we provide you investment advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the retirement plan to a Rollover IRA or make a distribution from the retirement plan, RMG here by acknowledges our fiduciary obligations to you with regard to our investment advice about whether to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement plan. RMG Wealth Management, LLC Page 8 Form ADV Part 2A Firm Brochure  Our investment advisor representatives shall 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 RMG or our affiliated personnel. Limits Advice to Certain Types of Investments RMG provides investment advice on the following types of investments: Interests in Partnerships Investing in Real Estate Interests in Partnerships Investing in Oil and Gas Interests • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Corporate Debt Securities • Commercial Paper • Certificates of Deposit • Municipal Securities • Variable Annuities • Variable Life Insurance • US Government Securities • Options Contracts on Securities • • • Fixed Income Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that are suitable for each client’s specific circumstances, needs, goals and objectives. 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 can also 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. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Rosemeyer Management Group’s advisory 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. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning services are always provided based on your individual needs. When providing financial planning services, we work with you on a one- RMG Wealth Management, LLC Page 9 Form ADV Part 2A Firm Brochure  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 Rosemeyer Management Group As of December 31, 2024, Rosemeyer Management Group had discretionary assets under management in the amount of $654,642,709 and $37,214,623 in non-discretionary assets under management. 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 Rosemeyer Management Group. Asset Management Services Fees charged for our asset management services are charged based on a percentage of assets under management, billed in arrears (at the end 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 current billing period. 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 the billing period, then the prorated fee for that billing period will be billed in arrears at the end of that billing period. The asset management services continue in effect until terminated by either party (i.e., RMG or you) by providing written notice of termination to the other party. When fees are billed in arrears, RMG will prorate the final fee payment based on the number of days services are provided during the final period. The amount of client assets on the termination date will be used to determine the final fee payment. Fees charged for our asset management services are negotiable based on the investment adviser representative providing the services, 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 adviser representative, and the total amount of assets under management for the client. For our asset management services the annual fee will range up to a maximum of 1.50%. The actual management fee to be charged will be specified in your client agreement. RMG Wealth Management, LLC Page 10 Form ADV Part 2A Firm Brochure  RMG believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you can also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). The investment advisory fees will be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. You will authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to our firm. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Brokerage expenses and/or transaction fees charged by the qualified custodian are billed directly to you by the qualified custodian. RMG does not receive any portion of such commissions or fees from you or the qualified custodian. In addition, you will incur certain charges imposed by third parties other than RMG in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by RMG 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 Services Fees charged for our financial planning services are negotiable based upon the type of client, the services requested, the investment adviser representative providing advice, the complexity of the client's situation, the composition of the client's account and other advisory services provided. The following are the fee arrangements available for financial planning services offered by Rosemeyer Management Group. Fees for Financial Planning Services Financial Planning Services are provided to our asset management clients on a complimentary basis (without any additional charges). For clients that do not participate in our asset management services RMG provides financial planning services under a fixed fee arrangement. A mutually agreed upon fixed fee is charged for financial planning services under this arrangement. There is a range in the amount of the fixed fee charged by RMG for financial planning services. The minimum fixed fee is generally $500, and the maximum fixed fee is generally no more than $5000. Financial Planning fees may be charged in a number of different ways. A flat fee charge would be defined as typically a one-time fee that is determined by the advisor and client to be appropriate for the services the advisor is providing to the client. Examples include Financial plan, settling an estate, portfolio analysis and review of employer sponsored 401k. However, at no time will RMG require payment of more than $1,200 in fees more than six months in advance. The hourly fee would be defined as a fee charged based on the number of hours worked by the advisor or advisor's office to complete advisory services a client needs. The usual rates are $100 to $500 per hour on various RMG Wealth Management, LLC Page 11 Form ADV Part 2A Firm Brochure  projects as generating a financial plan, settling an estate, portfolio analysis and review of employer sponsored 401k . A monthly fee would be defined as an annual fee broken down into a flat monthly fee going forward. Paying for ongoing financial advice from the advisor or a third-party service that can be canceled at any time without a termination fee. The fees for the financial planning services may be waived by RMG at our sole discretion. Financial Planning Fees charged are separate from any fees and expenses charged by mutual funds to their shareholders if Client invests in mutual funds due in part to the services under this Agreement. 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 (known as 12(b)-1 fees). If the mutual fund also imposes sales charges, Client may pay an initial or deferred sales charge. RMG does not receive any portion of any fees or expenses charged by the Mutual Fund company. In addition, if Client decides to invest through a qualified custodian due in part to the services under this Agreement, the qualified custodian or broker-dealer executing certain transaction will charge commissions for implementing transactions. RMG does not receive any portion of any fees to transaction charges imposed by the account custodian. To the extent RMG provides you with general investment recommendations as part of the financial planning services and you implement such investment recommendations through Rosemeyer Management Group, we may offer in our agreement with you to waive or reduce the fees for financial planning services. 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. 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 RMG prior to the receipt by RMG of your notice of termination. For financial planning services performed by RMG under a fixed fee arrangement, you will pay RMG a pro-rated fixed fee equivalent to the percentage of work completed by RMG as determined by Rosemeyer Management Group. In the event that there is a remaining balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be refunded by RMG to you. Other Fee Terms for Financial Planning Services You can pay the investment advisory fees owed for the financial planning services by submitting payment directly (for example, by check). You should notify RMG within ten (10) days of receipt of an invoice if you have questions about or dispute any billing entry. To the extent RMG engages an outside professional (i.e. attorney, independent investment adviser or accountant) while providing financial planning services to you, RMG 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 RMG 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 RMG 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 Rosemeyer Management Group, and you will be responsible for the payment of the fees for RMG Wealth Management, LLC Page 12 Form ADV Part 2A Firm Brochure  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 RMG 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 can also pay a commission and/or deferred sales charges in addition to the financial planning and consulting fees paid to RMG and any commissions, fees and expenses charged by the insurance company for subsequently acquired insurance and/or annuities. All fees paid to RMG for financial planning 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. It should be noted that lower fees for comparable services may be available from other sources. Retirement Plan Services For retirement plan sponsor clients, RMG has two advisory fee options. will charge a fixed annual fee that is calculated as a percentage of the value of plan assets. This fee is negotiable based upon the complexity of the plan, the size of the plan assets, the actual services requested and the potential for additional deposits. If RMG charges a fixed annual fee, we typically charge an annual fixed fee of up to $40,000. The exact amount of the fixed fee will be specified in you agreement with Rosemeyer Management Group. At our sole discretion you may be required to pay a portion of the fixed fee up front in the form of a retainer; however, at no time will we require payment of more than $1,200 in fees more than six months in advance. Upon completion of the services, the fixed fee is considered earned by RMG and any unpaid amount is immediately due. If RMG charges an annual fee based upon the value of the plan assets, we charge an annual fee of up to 2%. For retirement plan sponsors and participants, fees are billed in arrears (at the end 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 current billing period. 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. Retirement plan sponsors may also elect to pay all or a portion of fees for the individualized services provided by us to the plan participants. Clients can elect to have the fee deducted from their account or billed directly and due upon receipt of the billing notice. If clients elect to have the fee automatically deducted from an existing account, they are required to provide the custodian with written authorization to deduct the fees from the account and pay the fees to Rosemeyer Management Group. We will provide the custodian with a fee notification statement. Either party may terminate services by providing written notice of termination to the other party. If services are terminated within five business days of signing the client agreement, services are terminated without RMG Wealth Management, LLC Page 13 Form ADV Part 2A Firm Brochure  penalty. Any prepaid but unearned fees are promptly refunded to the client at the effective date of termination. RMG does not reasonably expect to receive any other compensation, direct or indirect, for its Services. If we receive any other compensation for such services, we will (i) offset that compensation against our stated fees, and (ii) will disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. 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 RMG 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 RMG specifying the particular advisory services in order to establish a client arrangement with Rosemeyer Management Group. Minimum Investment Amounts Required There are no minimum investment amounts or conditions required for establishing an account managed by Rosemeyer Management Group. However, all clients are required to execute an agreement for services in order to establish a client arrangement with RMG and/or the third-party money manager or the sponsor of third-party money manager platforms. The minimum fixed fee generally charged for financial planning services on a fixed fee basis is $500. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis RMG uses the following methods of analysis in formulating investment advice: Cyclical – This method analyzes the investments sensitive to business cycles and whose performance is strongly tied to the overall economy. For example, cyclical companies tend to RMG Wealth Management, LLC Page 14 Form ADV Part 2A Firm Brochure  make products or provide services that are in lower demand during downturns in the economy and in higher demand during upswings. Examples include the automobile, steel, and housing industries. The stock price of a cyclical company will often rise just before an economic upturn begins, and fall just before a downturn begins. Investors in cyclical stocks try to make the largest gains by buying the stock at the bottom of a business cycle, just before a turnaround begins. While most economists and investors agree that there are cycles in the economy that need to be respected, the duration of such cycles is generally unknown. An investment decision to buy at the bottom of a business cycle may actually turn out to be a trade that occurs before or after the bottom of the cycle. If done before the bottom, then downside price action can result prior to any gains. If done after the bottom, then some upside price action may be missed. Similarly, a sell decision meant to occur at the top of a cycle may result in missed opportunity or unrealized losses. 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 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 RMG Wealth Management, LLC Page 15 Form ADV Part 2A Firm Brochure  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. Investment Strategies RMG uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases - Investments held at least a year. Short term purchases - Investments sold within a year. Value-Investing - we primarily follow a value-investing strategy that attempts to acquire at reasonable valuations publicly traded businesses that can deliver sustainable excess returns. We focus on a long-only strategy. Long term strategies are designed to identify and select investments to be held for multiple years. We will also invest in value oriented special situations with shorter expected holding periods. Value Investing can be described as a strategy of selecting stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, resulting in stock price movements that do not correspond with the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to-earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e. businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. Margin transactions - When an investor buys a stock on margin, the investor pays for part of the purchase and borrows the rest of the purchase price from a brokerage firm. For example, an investor may buy $5,000 worth of stock in a margin account by paying for $2,500 and borrowing $2,500 from a brokerage firm. Clients cannot borrow stock from Rosemeyer Management Group. Option writing including cover options, uncovered options or spreading strategies - Options are contracts giving the purchaser the right to buy or sell a security, such as stocks, at a fixed price within a specific period of time. RMG Wealth Management, LLC Page 16 Form ADV Part 2A Firm Brochure  Strategic asset allocation - Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. 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. 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 RMG Wealth Management, LLC Page 17 Form ADV Part 2A Firm Brochure  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 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. • 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. • Margin Risk - When you purchase securities, you may pay for the securities in full or borrow part of the purchase price from your account custodian or clearing firm. If you intended to borrow funds in connection with your Account, you will be required to open a margin account, which will be carried by the clearing firm. The securities purchased in such an account are the clearing firm’s collateral for its loan to you. If those securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and as a result, the brokerage firm is required to take action in order to maintain the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell other assets in your account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin account that may be established as part of the Asset Management Agreement established between you and RMG and held by the account custodian or clearing firm. These risks include the following: • You can lose more funds than you deposit in your margin account. • The account custodian or clearing firm can force the sale of securities or other assets in your account. • The account custodian or clearing firm can sell your securities or other assets without contacting you. • You are not entitled to choose which securities or other assets in your margin account may be liquidated or sold to meet a margin call. • The account custodian or clearing firm may move securities held in your cash account to your margin account and pledge the transferred securities. • The account custodian or clearing firm can increase its “house” maintenance margin requirements at any time and they are not required to provide you advance written notice. • You are not entitled to an extension of time on a margin call. RMG Wealth Management, LLC Page 18 Form ADV Part 2A Firm Brochure  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 RMG is not and does not have a related person that is 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 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. Insurance Agent You are able to 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 RMG 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. Registered Representative of a Broker-Dealer Jacob E. Rosemeyer is also a registered representatives of Harbour Investments, a securities broker- dealer. You may work with him in his separate capacity as a registered representative of Harbour Investments. As a result of this relationship, Harbour Investments may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about clients of Rosemeyer Management Group, even if a client does not establish any account through Harbour Investments. If you would like a copy of the privacy policy of Harbour Investments, please contact Jacob E. Rosemeyer. When acting in his separate capacity as a registered representative, Jacob E. Rosemeyer 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, he may suggest that you implement RMG Wealth Management, LLC Page 19 Form ADV Part 2A Firm Brochure  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 products for which Jacob E. Rosemeyer will receive a commission in his separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of Jacob E. Rosemeyer in this separate capacity or to use Harbour Investments and can select any broker/dealer you wish to implement securities transactions. If you select Jacob E. Rosemeyer to implement securities transactions in his separate capacity as registered representatives, they must use Harbour Investments. Prior to effecting any such transactions, you are required to enter into a new account agreement with Harbour Investments. The commissions charged by Harbour Investments may be higher or lower than those charged by other broker/dealers. In addition, he 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. Accounting Services Kaley Bockhop, an associated person of Rosemeyer Management Group, is a licensed CPA. Clients needing assistance with tax preparation and/or account services may be referred to her but are not obligated to use her services. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary According to the Investment Advisers Act of 1940, an investment adviser is considered a fiduciary and has a fiduciary duty to all clients. RMG has established a Code of Ethics to comply with the requirements of Section 204(A)-1 of the Investment Advisers Act of 1940 that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. The 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. RMG requires its supervised persons to consistently act in your best interest in all advisory activities. RMG 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. An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. RMG 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. Rosemeyer Management Group’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. RMG requires its supervised persons to consistently act in your best interest in all advisory activities. RMG 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. RMG Wealth Management, LLC Page 20 Form ADV Part 2A Firm Brochure  This section is intended to provide a summary description of the Code of Ethics of Rosemeyer Management Group. 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 RMG or supervised persons of the firm buy and sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of RMG that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, RMG and its supervised 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 mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time RMG manages client accounts, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, supervised persons): • Supervised persons cannot prefer their own interests to that of the client. • Supervised persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Supervised 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. • Supervised persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider.” • Supervised persons are discouraged from conducting frequent personal trading. • Supervised 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 Rosemeyer Management Group. Any Supervised person not observing our policies is subject to sanctions up to and including termination. Item 12 – Brokerage Practices If RMG assists in the implementation of any recommendations, 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) RMG Wealth Management, LLC Page 21 Form ADV Part 2A Firm Brochure  • 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. Brokerage Recommendations RMG primarily recommends/requires that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc (“Schwab”) and/or TD Ameritrade, FINRA-registered broker-dealers, Members SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. RMG also uses Vanguard and Nationwide as custodial platforms for our ERISA based Retirement Plan accounts. (all of these firms will be referred to as “our custodians”). Although RMG may recommend/require the clients establish accounts at our custodians, it is the client’s decision to custody assets with the chosen firm. RMG is independently owned and operated and not affiliated with any broker dealer or custodian. RMG may recommend additional unaffiliated broker-dealers to affect fixed income transactions. Our custodians provide RMG with access to its institutional trading and custody services, which are typically not available to traditional retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a specified minimum level of client assets are maintained at the custodian. These services are not contingent upon RMG committing our custodians any specific amount of business (assets in custody or trading commissions). Our custodian’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require significantly higher minimum initial investment. Our Custodians also makes available to RMG other products are services that benefit RMG but may not directly benefit clients’ accounts. Many of these products and services may be used to service all or some substantial number of Rosemeyer Management Group’ accounts, including accounts not maintained at our Custodians. Our custodian’s products and services that assist RMG in managing and administering clients’ accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Rosemeyer Management Group’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Our Custodians also offer other services intended to help RMG manage and further develop its business enterprise. These services can include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Our Custodians may discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party RMG Wealth Management, LLC Page 22 Form ADV Part 2A Firm Brochure  providing these services to Rosemeyer Management Group. Our Custodians can also provide other benefits such as educational events or occasional business entertainment of RMG personnel. While as a fiduciary, RMG endeavors to act in its clients’ best interests, Rosemeyer Management Group’s recommendation that clients maintain their assets in accounts at a particular custodian may take into account availability of some of the foregoing products and services and other arrangements not solely on the nature of cost or quality of custody and brokerage services provided by the custodian, which creates a conflict of interest. Held Away Assets RMG uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. 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, RMG 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, RMG has decided to require our clients to use broker/dealers and other qualified custodians determined by Rosemeyer Management Group. 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 RMG 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. RMG uses the average price allocation method for transaction allocation. Under this procedure RMG will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. RMG Wealth Management, LLC Page 23 Form ADV Part 2A Firm Brochure  If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which RMG 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 the Investment Advisor Representative assigned to the account, with reviews performed in accordance with your investment goals and objectives. Our financial planning services terminate upon the presentation of the written plan. Our financial planning 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 monthly account statements in writing directly from the qualified custodian. Financial planning clients do not receive any report other than the written plan originally contracted for and provided by RMG. You are encouraged to always compare any reports or statements provided by us against the account statements delivered from the qualified custodian. When you 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 RMG has entered into an agreement with various persons or entities (Referring Parties) to refer clients to Rosemeyer Management Group. If a referred client enters into an investment advisory agreement with Rosemeyer Management Group, a cash referral fee is paid to the referring party, which is based upon a percentage of the client advisory fees that are generated. The referral agreements between any referring party and RMG will not result in any charges to clients in addition to the normal level of advisory fees charged. RMG Wealth Management, LLC Page 24 Form ADV Part 2A Firm Brochure  When a client is referred to us by a referring party, the referring party provides the client with a copy of our Disclosure Brochure as required by the Investment Advisers Act of 1940. The client also will complete a Solicitor’s Disclosure Statement document. If the referring party is an unaffiliated registered investment adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2 Disclosure Brochure. If a referred client enters into an investment advisory agreement with Rosemeyer Management Group, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The referral agreements between RMG and referring parties are in compliance with state and federal securities rules regarding paid solicitor arrangements. We receive an economic benefit from our custodians in the form of the support products and services it makes available to us and other independent investment advisers whose clients maintain their accounts at a particular custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of a custodian’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. 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. 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. For accounts in which RMG is deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered 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 reports received from Rosemeyer Management Group. When clients have questions about their account statements, they should contact RMG or the qualified custodian preparing the statement. Item 16 – Investment Discretion When providing asset management services, RMG 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. RMG Wealth Management, LLC Page 25 Form ADV Part 2A Firm Brochure  Item 17 – Voting Client Securities Clients are given the option to vote proxies themselves or have RMG vote proxies on their behalf. Class Action Lawsuits You retain the right under applicable securities laws to initiate individually a lawsuit or join a class-action lawsuit against the issuer of a security that was held, purchased or sold by or for you. RMG does not initiate such a legal proceeding on behalf of clients and does not provide legal advice to clients regarding potential causes of action against such a security issuer and whether the client should join a class-action lawsuit. We recommend that you seek legal counsel prior to making a decision regarding whether to participate in such a class-action lawsuit. Moreover, our services do not include monitoring or informing you of any potential or actual class-action lawsuits against the issuers of the securities that were held, purchased or sold by or for you. Item 18 – Financial Information This Item 18 is not applicable to this brochure. RMG does not require or solicit prepayment of more than $1200 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, RMG has not been the subject of a bankruptcy petition at any time. Customer Privacy Policy Notice In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to nonaffiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. Rosemeyer Management Group does not share or disclose customer information to nonaffiliated third parties except as permitted or required by law. Rosemeyer Management Group is committed to safeguarding the confidential information of its clients. RMG holds all personal information provided by clients in the strictest confidence and it is the objective of Rosemeyer Management Group to protect the privacy of all clients. Except as permitted or required by law, Rosemeyer Management Group does not share confidential information about clients with nonaffiliated parties. In the event that there were to be a change in this policy, RMG will provide clients with written notice and clients will be provided an opportunity to direct RMG as to whether such disclosure is permissible. To conduct regular business, RMG may collect personal information from sources such as: • • Information reported by the client on applications or other forms the client provides to Rosemeyer Management Group Information about the client’s transactions implemented by RMG or others RMG Wealth Management, LLC Page 26 Form ADV Part 2A Firm Brochure  • Information developed as part of investment advisory services To administer, manage, service, and provide related services for client accounts, it is necessary for RMG to provide access to customer information within the firm and to nonaffiliated companies, with whom RMG has entered into agreements with. To provide the utmost service, RMG may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on Rosemeyer Management Group’ behalf. • • • • Information RMG receives from the client on applications (name, social security number, address, assets, etc.) Information about the client’s transactions with RMG or others (account information, payment history, parties to transactions, etc.) Information concerning investment advisory account transactions Information about a client’s financial products and services transaction with Rosemeyer Management Group Since RMG shares nonpublic information solely to service client accounts, RMG does not disclose any nonpublic personal information about Rosemeyer Management Group’ customers or former customers to anyone, except as permitted by law. However, RMG may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. In the event that RMG has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, RMG will allow its clients the opportunity to opt out of such disclosure. Business Continuity Plan Rosemeyer Management Group 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. RMG Wealth Management, LLC Page 27 Form ADV Part 2A Firm Brochure