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Item 1 Cover Page
D I S C L O S U R E B R O C H U R E
Office Address:
4550 W 77th Street
Suite 380
Edina, MN 55435
Tel: 952-657-7470
vince@cfgretirement.com
www.cfgretirement.com
FEBRUARY 2025
This brochure provides information about the qualifications and business practices of Assured Retirement
Financial Group, Inc. Being registered as an investment adviser does not imply a certain level of skill or
training. If you have any questions about the contents of this brochure, please contact us at 952-657-7470.
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission, or by any state securities authority.
Additional information about Assured Retirement Financial Group, Inc. (CRD #179516) is available on the
SEC’s website at www.adviserinfo.sec.gov.
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Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when
material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
There have been no material changes to this brochure since our last annual filing in January 2024.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update .................................................................................................................................................................... ii
Material Changes since the Last Update .................................................................................................................. ii
Full Brochure Available .................................................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business ................................................................................................................... 6
Firm Description ................................................................................................................................................................ 6
Types of Advisory Services ........................................................................................................................................... 6
Client Tailored Services and Client Imposed Restrictions ................................................................................ 6
Wrap Fee Programs ......................................................................................................................................................... 6
Client Assets under Management ............................................................................................................................... 7
Item 5: Fees and Compensation ......................................................................................................... 7
Method of Compensation and Fee Schedule .......................................................................................................... 7
Client Payment of Fees .................................................................................................................................................... 7
Additional Client Fees Charged ................................................................................................................................... 7
Prepayment of Client Fees ............................................................................................................................................. 8
External Compensation for the Sale of Securities to Clients ............................................................................ 8
Item 6: Performance‐Based Fees and Side‐by‐Side Management .......................................... 8
Sharing of Capital Gains .................................................................................................................................................. 8
Item 7: Types of Clients ........................................................................................................................ 8
Description ........................................................................................................................................................................... 8
Account Minimums........................................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................. 8
Methods of Analysis ......................................................................................................................................................... 8
Investment Strategy ......................................................................................................................................................... 9
Security Specific Material Risks ................................................................................................................................... 9
Item 9: Disciplinary Information ................................................................................................... 10
Criminal or Civil Actions ............................................................................................................................................. 10
Administrative Enforcement Proceedings ........................................................................................................... 10
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Self-Regulatory Organization Enforcement Proceedings............................................................................... 10
Item 10: Other Financial Industry Activities and Affiliations .............................................. 10
Broker-Dealer or Representative Registration .................................................................................................. 10
Futures or Commodity Registration ....................................................................................................................... 10
Material Relationships Maintained by this Advisory Business and Conflicts of Interest .................. 10
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............... 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading .................................................................................................................................................... 11
Code of Ethics Description .......................................................................................................................................... 11
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 12
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 12
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ................................................................................................................... 12
Item 12: Brokerage Practices .......................................................................................................... 13
Factors Used to Select Broker-Dealers for Client Transactions .................................................................. 13
Aggregating Securities Transactions for Client Accounts .............................................................................. 14
Item 13: Review of Accounts ............................................................................................................ 14
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 14
Review of Client Accounts on Non-Periodic Basis ............................................................................................ 14
Content of Client Provided Reports and Frequency ......................................................................................... 14
Item 14: Client Referrals and Other Compensation ................................................................. 14
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 14
Advisory Firm Payments for Client Referrals ..................................................................................................... 14
Item 15: Custody .................................................................................................................................. 14
Account Statements ....................................................................................................................................................... 14
Item 16: Investment Discretion ...................................................................................................... 15
Discretionary Authority for Trading ...................................................................................................................... 15
Item 17: Voting Client Securities .................................................................................................... 15
Proxy Votes ....................................................................................................................................................................... 15
Item 18: Financial Information ....................................................................................................... 15
Balance Sheet ................................................................................................................................................................... 15
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Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 15
Bankruptcy Petitions during the Past Ten Years ............................................................................................... 15
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17
Principal Executive Officer - Vincent L. Oldre, CFP® ............................................................................................................................................ 17
Item 2 Educational Background and Business Experience ........................................................................... 17
Professional Certifications .......................................................................................................................................... 17
Item 3 Disciplinary Information ............................................................................................................................... 18
Item 4 Other Business Activities .............................................................................................................................. 18
Item 5 Additional Compensation ............................................................................................................................. 19
Item 6 Supervision ......................................................................................................................................................... 19
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Item 4: Advisory Business
Firm Description
Assured Retirement Financial Group, Inc. doing business as CFG Retirement (“CFG
Retirement”) was founded in 2015. Vincent L. Oldre is 100% owner.
Types of Advisory Services
ASSET MANAGEMENT
CFG Retirements offers discretionary asset management services through the utilization of sub-
advisors and/or co-advisors to advisory Clients. CFG Retirement will not manage any Client
accounts outside of the sub-advisor or co-advisors.
CFG Retirement will provide the following services when recommending services provided by
sub-advisors and/or co-advisors:
Refer persons it believes are suitable and appropriate to one or more of the provided
programs and provide certain ongoing services to Clients.
Customize the Client’s Portfolios (either through the designation of asset allocations,
the selection of portfolios, funds and strategies for each investment category in the
Portfolio or a combination of the foregoing).
Obtain information regarding the Client’s investment history and profile in order to
understand the Client’s investment needs and objectives, reasonable restrictions and
risk tolerance, and other relevant information, used to generate a proposal through the
Platform for a recommended Portfolio for the Client.
On behalf of the Client, designate allocations and select portfolios, funds and strategies
for each investment category in the proposal or Portfolio, and make adjustments to the
proposed Portfolio as appropriate and consistent with the agreement of the Client.
Verify at least annually whether the Client’s investment objectives or other financial
needs have changed and notify sub-advisor/co-advisors of any changes that need to be
made to a Client account.
CFG Retirement has full discretion to make changes with regard to the management of
the account as they deem suitable. Sub-Advisors will maintain the models or investment
strategies agreed upon between Sub-Advisor and CFG Retirement.
Sub-Advisors execute trades on behalf of CFG Retirement in Client accounts. CFG Retirement
will be responsible for the overall direct relationship with the Client. CFG Retirement retains
the authority to terminate the Sub-Advisor relationship at CFG Retirement’s discretion.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment strategies
are created that reflect the stated goals and objectives. Clients may impose restrictions on
investing in certain securities or types of securities. Agreements may not be assigned without
written client consent.
Wrap Fee Programs
CFG Retirement does not sponsor any wrap fee programs.
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Client Assets under Management
CFG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$181,849,897
$0
Date Calculated:
12/31/2024
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
CFG Retirement may enter into sub-advisor/co-advisor agreements with other registered
investment advisor firms. When using sub-advisors/co-advisors, the Client may incur
additional platform or sub-advisor/co-advisor fees. The sub-advisor/co-advisor fees are not
included in the fees charged by CFG Retirement, but are disclosed on the subadvisor’s
investment management agreement, which each client is provided, and must sign, in order to
access the services of the sub-advisor/co-advisor. Such additional fees are only incurred on the
portion of clients’ portfolio managed by the sub-advisor/co-advisor. CFG Retirement charges an
annual investment advisory fee based on the total assets under management as follows:
Amount Under Management
Up to $500,000
$500,001 - $3,000,000
$3,000,001 – $5,000,000
$5,000,001 - $10,000,000
$10,000,001 - $25,000,000
$25,000,001 - $50,000,000
$50,000,001 - $100,000,000
CFG Retirement Fee
1.20%
1.00%
.85%
.80%
.70%
.40%
.30%
The annual fee may be negotiable. Accounts within the same household may be combined for a
reduced fee. Fees are withdrawn from a Clients account in accordance with the sub- advisor/co-
advisor utilized. Specific details will be provided in the Client Agreement signed by the Client.
Lower fees for comparable services may be available from other sources. Clients may terminate
their account within five (5) business days of signing the Investment Advisory Agreement with
no obligation. Clients may terminate advisory services with thirty (30) days written notice. For
accounts closed mid-quarter, CFG Retirement will be entitled to a pro rata fee for the days
service was provided in the final quarter. Client shall be given thirty (30) days prior written
notice of any increase in fees. Any increase in fees will be acknowledged in writing by both
parties before any increase in said fees occurs.
Client Payment of Fees
Fees for asset management services are deducted from a designated Client account. The Client
must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities,
and exchange-traded funds. These charges may include Mutual Fund transactions fees, postage
and handling and miscellaneous. The selection of the security is more important than the
nominal fee that the custodian charges to buy or sell the security.
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CFG Retirement, in its sole discretion, may waive its minimum fee and/or charge a lesser
investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of
assets to be managed, related accounts, account composition, negotiations with clients, etc.).
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
CFG Retirement does not charge fees in advance.
External Compensation for the Sale of Securities to Clients
CFG Retirement does not receive any external compensation for the sale of securities to clients,
nor do any of the investment advisor representatives of CFG Retirement.
Item 6: Performance‐Based Fees and Side‐by‐Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed securities.
CFG Retirement does not use a performance-based fee structure because of the conflict of
interest. Performance based compensation may create an incentive for the adviser to
recommend an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
CFG Retirement generally provides investment advice to individuals and high net worth
individuals. Client relationships vary in scope and length of service.
Account Minimums
CFG Retirement does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis, cyclical analysis and Modern
Portfolio Theory. Investing in securities involves risk of loss that clients should be prepared to
bear. Past performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth. Cyclical analysis involves analyzing the cycles of the market. Modern Portfolio Theory is
a theory of finance that attempts to maximize portfolio expected return for a given amount of
portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully
choosing the proportions of various assets.
The main sources of information include the services of Morningstar’s data fields and
deciphered through the institutionally based system, Zephyr Style. Zephyr Style relies strictly
on performance as its measure of analysis. This is defined as Returns- Based Analysis. Each
security analyzed in this system is positioned relative to the appropriate index with respect to
style, risk/return and performance.
Co-Advisors/Sub-Advisors utilized by CFG Retirement may use various methods of analysis to
determine the proper strategy for the Client referred and these will be disclosed in the Co-
Advisor/Sub-Advisor’s Form ADV Part 2. Investing in securities involves risk of loss that
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Clients should be prepared to bear. Past performance is not a guarantee of future returns. Other
strategies utilized by Co-Advisors/Sub-Advisors may include long-term purchases, short-term
purchases, trading, and option writing (including covered options, uncovered options or
spreading strategies).
Investment Strategy
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client executes
an Investment Policy Statement or Risk Tolerance that documents their objectives and their
desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and option
writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical
analysis involves inflation risk, market risk, and currency risk.
Our investment approach constantly keeps the risk of loss in mind. Investors face the following
investment risks and should discuss these risks with CFG Retirement:
Interest‐rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline.
Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible
and intangible events and conditions. This type of risk is caused by external factors
independent of a security’s particular underlying circumstances. For example, political,
economic and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will buy more than a
dollar next year, because purchasing power is eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to
fixed income securities.
Business Risk: These risks are associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then
refining it, a lengthy process, before they can generate a profit. They carry a higher risk of
profitability than an electric company which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For
example, Treasury Bills are highly liquid, while real estate properties are not.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times
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and bad. During periods of financial stress, the inability to meet loan obligations may
result in bankruptcy and/or a declining market value.
The risks associated with utilizing Sub-Advisor/co-advisor’s include:
Manager Risk
o Sub-Advisor/co-advisor fails to execute the stated investment strategy
Business Risk
o Sub-Advisor/co-advisor has financial or regulatory problems
The specific risks associated with the portfolios of the Sub-Advisor/co-advisor’s which is
disclosed in the Sub-Advisor’s Form ADV Part 2.
Item 9: Disciplinary Information
Criminal or Civil Actions
CFG Retirement and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
CFG Retirement and its management have not been involved in administrative enforcement
proceedings.
Self‐Regulatory Organization Enforcement Proceedings
CFG Retirement and its management have not been involved in legal or disciplinary events
related to past or present investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker‐Dealer or Representative Registration
No affiliated representatives of CFG Retirement are registered representatives of a broker-
dealer.
Futures or Commodity Registration
Neither CFG Retirement nor its employees are registered or has an application pending to
register as a futures commission merchant, commodity pool operator, or a commodity trading
advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Appointed Insurance Representative
Managing member Vincent Oldre is also a licensed insurance agent through his affiliated
insurance agency, CFG Retirement.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission and/or fee amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client
first and the clients are not required to purchase any products or services. Clients have the
option to purchase these products or services through another insurance agent of their
choosing.
Advanced Advisor Marketing, LLC
Vincent Oldre is also Co-Founder of Advanced Advisor Marketing, LLC (AAM). AAM is an
Insurance Marketing Organization (IMO) which provides a distribution channel on behalf of
insurance companies for independent licensed insurance agents. In the event an independent
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agent elects to partner with AAM, AAM will be compensated directly from the insurance
company. The commission structure built into insurance products is predetermined by the
insurance companies. The product purchased by the client is issued by the insurance company
and the cost to the client is in no way altered by the IMO or the insurance agent involved.
Furthermore, the client has no obligation to do business with the advisor/agent. Vincent Oldre
receives a salary plus bonuses from AAM and therefore, a conflict of interest occurs. This conflict
is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation. Independent
insurance agents may work with any insurance company and any IMO of their choosing, one of
which may be AAM.
Approximately 15% of his time is spent in this practice. From time to time, he will offer clients
products and/or services from these activities.
CRG Team, Inc.
Mr. Oldre is also owner of CRG Team, Inc. and National Retirement Academy. Approximately
10% of his time is spent in these activities. CRG Team, Inc. is a competitive kids racing team and
National Retirement Academy is a non-profit that helps bring education around retirement.
These activities do not create any conflict of interest as there are no crossover clients.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
CFG Retirement may also utilize the services of a Sub-Advisor/co-advisor to manage Clients’
investment portfolios. Sub-Advisor/co-advisor will maintain the models or investment
strategies agreed upon between Sub-Advisor/co-advisor and CFG Retirement. Sub-
Advisor/co-advisor executes all trades on behalf of CFG Retirement in Client accounts. CFG
Retirement will be responsible for the overall direct relationship with the Client. CFG
Retirement retains the authority to terminate the Sub-Advisor/co-advisor relationship at CFG
Retirement’s discretion.
In addition to the authority granted to CFG Retirement, Clients will grant CFG Retirement full
discretionary authority and authorizes CFG Retirement to select and appoint one or more
independent investment advisors (“Advisors”) to provide investment advisory services to
Client without prior consultation with or the prior consent of Client. Such Advisors shall have
all of the same authority relating to the management of Client’s investment accounts as is
granted to CFG Retirement in the Agreement. In addition, at CFG Retirement’s discretion, CFG
Retirement may grant such Advisors full authority to further delegate such discretionary
investment authority to additional Advisors.
This practice represents a conflict of interest as CFG Retirement may select Sub-Advisor/co-
advisor who charge a lower fee for their services than other Sub-Advisor/co-advisor. This
conflict is mitigated by disclosures, procedures, and by the fact that CFG Retirement has a
fiduciary duty to place the best interest of the Client first and will adhere to their code of ethics.
CreativeOne Wealth, LLC
Mr. Oldre has entered into a Marketing Agreement with CreativeOne, LLC, where Mr. Oldre
borrows funds according to the terms and conditions set forth in a written Forgivable Loan &
Promissory Note and Marketing Agreement, the latter outlines Mr. Oldre’s obligations to
CreativeOne for receipt of the loan. Mr. Oldre is required to (1) maintain a solicitor or sub-
advisory relationship with CreativeOne, LLC, and (2) the he maintains certain minimum billable
assets under management in order to forgive the loan. This creates a conflict of interest that gives
Mr. Oldre the incentive to place client assets with CreativeOne, LLC.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics Description
The employees of CFG Retirement have committed to a Code of Ethics (“Code”). The purpose of
our Code is to set forth standards of conduct expected of CFG Retirement employees and
addresses conflicts that may arise. The Code defines acceptable behavior for employees of CFG
Retirement. The Code reflects CFG Retirement and its supervised persons’ responsibility to act
in the best interest of their client.
One area which the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
CFG Retirement’s policy prohibits any person from acting upon or otherwise misusing non-
public or inside information. No advisory representative or other employee, officer or director
of CFG Retirement may recommend any transaction in a security or its derivative to advisory
clients or engage in personal securities transactions for a security or its derivatives if the
advisory representative possesses material, non-public information regarding the security.
CFG Retirement’s Code is based on the guiding principle that the interests of the client are our
top priority. CFG Retirement’s officers, directors, advisors, and other employees have a fiduciary
duty to our clients and must diligently perform that duty to maintain the complete trust and
confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests
over the interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to non-
public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in making
securities recommendations to clients, or who have access to such recommendations that are
non-public.
CFG Retirement will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
CFG Retirement and its employees do not recommend to clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
CFG Retirement and its employees may buy or sell securities that are also held by clients. In
order to mitigate conflicts of interest such as trading ahead of client transactions, employees
are required to disclose all reportable securities transactions as well as provide CFG Retirement
with copies of their brokerage statements.
The Chief Compliance Officer of CFG Retirement is Vince Oldre. He reviews all employee trades
each quarter. The personal trading reviews ensure that the personal trading of employees does
not affect the markets and that clients of the firm receive preferential treatment over employee
transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest
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CFG Retirement does not maintain a firm proprietary trading account and does not have a
material financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy or sell
securities for clients. In order to mitigate conflicts of interest such as front running, employees
are required to disclose all reportable securities transactions as well as provide CFG Retirement
with copies of their brokerage statements.
Item 12: Brokerage Practices
Factors Used to Select Broker‐Dealers for Client Transactions
CFG Retirement may recommend the use of a particular broker-dealer such as TD Ameritrade
or may utilize a broker-dealer of the client's choosing. CFG Retirement will select appropriate
brokers based on a number of factors including but not limited to their relatively low
transaction fees and reporting ability. CFG Retirement relies on its broker to provide its
execution services at the best prices available. Lower fees for comparable services may be
available from other sources. Clients pay for any and all custodial fees in addition to the advisory
fee charged by CFG Retirement.
Directed Brokerage
In circumstances where a client directs CFG Retirement to use a certain broker-dealer, CFG
Retirement still has a fiduciary duty to its clients. The following may apply with Directed
Brokerage: CFG Retirement's inability to negotiate commissions, to obtain volume
discounts, there may be a disparity in commission charges among clients and conflicts of
interest arising from brokerage firm referrals.
Best Execution
Investment advisors who manage or supervise client portfolios on a discretionary basis
have a fiduciary obligation of best execution. The determination of what may constitute
best execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is effected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. The firm does not receive
any portion of the trading fees.
Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as arrangement
under which products or services other than execution services are obtained by CFG
Retirement from or through a broker-dealer in exchange for directing client transactions
to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934,
CFG Retirement receives economic benefits as a result of commissions generated from
securities transactions by the broker-dealer from the accounts of CFG Retirement. These
benefits include both proprietary research from the broker and other research written by
third parties.
CFG Retirement utilizes the services of custodial broker dealers. Economic benefits are
received by CFG Retirement which would not be received if CFG Retirement did not give
investment advice to clients. These benefits include: A dedicated trading desk, a dedicated
service group and an account services manager dedicated to CFG Retirement's accounts,
ability to conduct "block" client trades, electronic download of trades, balances and
positions, duplicate and batched client statements, and the ability to have advisory fees
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directly deducted from client accounts.
A conflict of interest exists when CFG Retirement receives soft dollars. This conflict is
mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the best
interest of our clients and the services received are beneficial to all clients.
Aggregating Securities Transactions for Client Accounts
CFG Retirement is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of CFG Retirement. All clients participating in the aggregated order
shall receive an average share price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved
Account reviews are performed quarterly by the Chief Compliance Officer of CFG Retirement.
Account reviews are performed more frequently when market conditions dictate.
Review of Client Accounts on Non‐Periodic Basis
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the third party money manager’s custodian. Client receives
confirmations of each transaction in account from Custodian and an additional statement
during any month in which a transaction occurs. CFG Retirement does not provide additional
reports to Clients.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest
CFG Retirement receives a portion of the annual management fees collected by the Co-
Advisors/Sub-Advisors to whom CFG Retirement refers clients.
This situation creates a conflict of interest because CFG Retirement and/or its Investment
Advisor Representative have an incentive to decide what Co-Advisors/Sub-Advisors to use
because of the higher referral fees to be received by CFG Retirement. However, when referring
clients to a Co-Advisor/Sub-Advisor, the client’s best interest will be the main determining
factor of CFG Retirement.
Advisory Firm Payments for Client Referrals
CFG Retirement does not compensate for client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged to
compare the account statements received directly from their custodians to the performance
report statements prepared by CFG Retirement.
CFG Retirement is deemed to have constructive custody solely because advisory fees are
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directly deducted from client’s accounts by the custodian on behalf of CFG Retirement.
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are urged to
compare the account statements received directly from their custodians to any documentation
or reports prepared by Co-Advisor/Sub-Advisor.
Item 16: Investment Discretion
Discretionary Authority for Trading
CFG Retirement accepts discretionary authority to manage securities accounts on behalf of
clients. CFG Retirement has the authority to determine, without obtaining specific client
consent, the securities to be bought or sold, and the amount of the securities to be bought or
sold. However, CFG Retirement consults with the client prior to each trade to obtain
concurrence if a blanket trading authorization has not been given.
The client approves the custodian to be used and the commission rates paid to the custodian.
CFG Retirement does not receive any portion of the transaction fees or commissions paid by the
client to the custodian on certain trades..
Item 17: Voting Client Securities
Proxy Votes
CFG Retirement does not vote proxies on securities. Clients are expected to vote their own
proxies. The client will receive their proxies directly from the custodian of their account or from
a transfer agent.
When assistance on voting proxies is requested, CFG Retirement will provide recommendations
to the client. If a conflict of interest exists, it will be disclosed to the client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because CFG Retirement does not serve as a
custodian for client funds or securities and CFG Retirement does not require prepayment of fees
of more than $1,200 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
CFG Retirement has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
Neither CFG Retirement nor its management has had any bankruptcy petitions in the last ten
years.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M AD V P A R T 2B
Vincent L. Oldre, CFP®
Office Address:
4550 W 77th Street
Suite 380
Edina, MN 55435
Tel: 952-657-7470
vince@cfgretirement.com
cfgretirement.com
DECEMBER 2024
This brochure supplement provides information about Vincent L. Oldre and supplements Assured
Retirement Financial Group, Inc.’s brochure. You should have received a copy of that brochure.
Please contact Vincent L. Oldre if you did not receive the brochure or if you have any questions about
the contents of this supplement.
Additional information about Vincent L. Oldre (CRD #6316933) is available on the SEC’s website at
www.adviserinfo.sec.gov.
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CFG Retirement
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer ‐ Vincent L. Oldre, CFP®
Year of birth: 1986
Item 2 Educational Background and Business Experience
Educational Background:
Gustavus Adolphus College; B.A. Degree in Business Management; 2008
Business Experience:
CRG Team, Inc., Owner; 02/2024 – Present
National Retirement Academy; Founder; 01/2023 - Present
Assured Retirement Financial Group,
Inc. dba CFG Retirement; Managing
Member/Investment Advisor Representative; 05/2015 - Present
CFG Retirement formerly Assured Retirement Group; Owner/Insurance Agent;
12/2014 – Present
Advanced Advisor Marketing, LLC; Co-Founder; 10/2017 – Present
Mastermind Advisor Marketing, LLC dba Advisor Fuel, LLC; President; 02/2021 –
12/2023
Secured Retirement Advisors, LLC; Investment Advisor Representative; 03/2014 –
03/2015
The Annuity Store; Marketing Consultant; 10/2010 – 03/2014
Allianz Life; Internal Wholesaler; 04/2010 – 10/2010
Marcus and Millichamp; Sales Representative; 06/2008 – 04/2010
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
of other countries for its (1) high standard of professional education; (2) stringent code of
conduct and standards of practice; and (3) ethical requirements that govern professional
engagements with clients. Currently, more than 62,000 individuals have obtained CFP®
certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
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CFG Retirement
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial
planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be
subject to CFP Board’s enforcement process, which could result in suspension or permanent
revocation of their CFP® certification.
Item 3 Disciplinary Information
None to report.
Item 4 Other Business Activities
Managing member Vincent Oldre is also a licensed insurance agent through his affiliated
insurance agency, CFG Retirement.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission and/or fee amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the client
first and the clients are not required to purchase any products or services. Clients have the
option to purchase these products or services through another insurance agent of their
choosing.
Vincent Oldre is also Co-Founder of Advanced Advisor Marketing, LLC (AAM). Approximately
15% of his time is spent in this practice. AAM is an Insurance Marketing Organization (IMO)
which provides a distribution channel on behalf of insurance companies for independent
licensed insurance agents. In the event an independent agent elects to partner with AAM, AAM
will be compensated directly from the insurance company. The commission structure built into
insurance products is predetermined by the insurance companies. The product purchased by
the client is issued by the insurance company and the cost to the client is in no way altered by
the IMO or the insurance agent involved. Furthermore, the client has no obligation to do
business with the advisor/agent. Vincent Oldre receives a salary plus bonuses from AAM and
therefore, a conflict of interest occurs. This conflict is mitigated by disclosures, procedures, and
the firm’s Fiduciary obligation. Independent insurance agents may work with any insurance
company and any IMO of their choosing, one of which may be AAM.
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CFG Retirement
Mr. Oldre is also owner of CRG Team, Inc. and National Retirement Academy. Approximately
10% of his time is spent in these activities. CRG Team, Inc. is a competitive kids racing team and
National Retirement Academy is a non-profit that helps bring education around retirement.
These activities do not create any conflict of interest as there are no crossover clients.
Item 5 Additional Compensation
Mr. Oldre receives additional compensation in his capacity as an insurance agent, but he does
not receive any performance-based fees.
CreativeOne Wealth, LLC
Mr. Oldre has entered into a Marketing Agreement with CreativeOne, LLC, where Mr. Oldre
borrows funds according to the terms and conditions set forth in a written Forgivable Loan &
Promissory Note and Marketing Agreement, the latter outlines Mr. Oldre’s obligations to
CreativeOne for receipt of the loan. Mr. Oldre is required to (1) maintain a solicitor or sub-
advisory relationship with CreativeOne, LLC, and (2) the he maintains certain minimum billable
assets under management in order to forgive the loan. This creates a conflict of interest that gives
Mr. Oldre the incentive to place client assets with CreativeOne, LLC above all other advisor options
who may offer better or different services and pricing.
Item 6 Supervision
the
firm’s Compliance Manual. He can be
Since Mr. Oldre is the Chief Compliance Officer & President of Assured Retirement Financial
Group, Inc. he is solely responsible for all supervision and formulation and monitoring of
investment advice offered to clients. He will adhere to the policies and procedures as described
in
reached at 952-657-7470 or
vince@cfgretirement.com.
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CFG Retirement
Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M AD V P A R T 2B
Marty O’Shaughnessy, CFP
Office Address:
4550 W 77th Street
Suite 380
Edina, MN 55435
Tel: 952-657-7470
marty@cfgretirement.com
cfgretirement.com
March 2025
This brochure supplement provides information about Marty O’Shaughenessy and supplements
Assured Retirement Financial Group, Inc.’s brochure. You should have received a copy of that
brochure. Please contact Vincent L. Oldre if you did not receive the brochure or if you have any
questions about the contents of this supplement.
Additional information about Marty O’Shaughnessy (CRD #7014969) is available on the SEC’s website
at www.adviserinfo.sec.gov.
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CFG Retirement
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Financial Planner – Marty O’Shaughnessy, CFP®
Year of birth: 1995
Item 2 Educational Background and Business Experience
Educational Background:
Bradley University; B.S. Degree in Marketing; 2017
Business Experience:
Assured Retirement Financial Group,
Inc. dba CFG Retirement; Financial
Planner; 02/2025 - Present
Guardian Resources; Wealth Advisor; 6/2024 – 02/2025
DAI Securities, LLC; Registered Representative; 07/2023 – 5/2024
DAI Wealth, LLC; Registered Investment Advisor; 07/2023 – 5/2024
AssetMark, Inc.; Business Development Consultant; 03/2019 – 06/2023
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
of other countries for its (1) high standard of professional education; (2) stringent code of
conduct and standards of practice; and (3) ethical requirements that govern professional
engagements with clients. Currently, more than 62,000 individuals have obtained CFP®
certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a Bachelor’s
Degree from a regionally accredited United States college or university (or its equivalent
from a foreign university). CFP Board’s financial planning subject areas include insurance
planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios
designed to test one’s ability to correctly diagnose financial planning issues and apply one’s
knowledge of financial planning to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
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CFG Retirement
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning
field; and
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial
planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be
subject to CFP Board’s enforcement process, which could result in suspension or permanent
revocation of their CFP® certification.
Item 3 Disciplinary Information
None to report.
Item 4 Other Business Activities
Mr. O’Shaughnessy is a licensed insurance agent through his affiliated insurance agency, CFG
Retirement. This represents a conflict of interest because it gives an incentive to recommend
products and services based on the commission and/or fee amount received. This conflict is
mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best
interest of the client first and the clients are not required to purchase any products or services.
Clients have the option to purchase these products or services through another insurance agent
of their choosing.
Item 5 Additional Compensation
Mr. O’Shaughnessy receives additional compensation in his capacity as an insurance agent, but
he does not receive any performance-based fees.
Item 6 Supervision
Vincent Oldre is the Chief Compliance Officer & President of Assured Retirement Financial
Group; Inc. who is solely responsible the supervision of investment advice offered to clients by
Mr. O’Shaughnessy. Mr. O’Shaughnessy will adhere to the policies and procedures as described
in the firm’s Compliance Manual. Mr. Oldre, CCO can be reached at 952-657-7470 or
vince@cfgretirement.com.
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CFG Retirement