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
PMG Wealth Management Page 5 Form ADV Part 2A, Rev. 04/2024
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 offers financial planning services, which involves preparing a written financial plan covering specific
or multiple topics. We provide full written financial plans, which typically address the following topics:
Investment Planning, Retirement Planning, Tax Planning, Portfolios 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 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 Debt Management: 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 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 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: PMG works with 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
PMG Wealth Management Page 7 Form ADV Part 2A, Rev. 04/2024
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. 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.
• 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
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. 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, you
must execute a separate written agreement with PMG for our asset management services.
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.
PMG Wealth Management Page 8 Form ADV Part 2A, Rev. 04/2024
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.)
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).
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• 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
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.
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• 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.
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.
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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.
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.
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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.
Whenever a fee is charged to a client for services described in this brochure (whether wrap fee or non-
wrap fee), we will receive all or a portion of the fee charged.
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, 2023, PMG manages $138,935.766 of client assets, all on a discretionary basis.