CAPITAL MARKET STRATEGIES LLC

Alpha Beta Gamma Wealth Management Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Alpha Beta Gamma Wealth Management. If you have any questions about the contents of this brochure, please contact us at (561) 207-6399 or by email at: clyman@abgwealth.com. 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 Alpha Beta Gamma Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. Alpha Beta Gamma Wealth Management’s CRD number is: 286579. 3801 PGA Blvd. Suite 600 Palm Beach Gardens, FL 33410 (561) 207-6399 clyman@abgwealth.com https://www.abgwealth.com Registration does not imply a certain level of skill or training. Version Date: 03/5/2025 i  Item 2: Material Changes We are required to inform client of material changes via this brochure. Alpha Beta Gamma Wealth Management has the following changes to report since our last brochure: 1. Alpha Beta Gamma Wealth Management has named Stephanie Lynn West as the Alpha Beta Gamma Wealth Chief Compliance Officer, any questions regarding Alpha Beta Gamma Wealth can be directed to Stephanie West or Curtis Lyman. 2. Alpha Beta Gamma Wealth Management has updated its floating rate schedule. 3. Alpha Beta Gamma Wealth Management will no longer proxy vote on behalf of clients. Please see Section 17 for additional details. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................................................... ii Item 3: Table of Contents ......................................................................................................................................................... iii Item 4: Advisory Business ........................................................................................................................................................ 2 A. Description of the Advisory Firm .................................................................................................................................. 2 B. Types of Advisory Services ............................................................................................................................................. 2 Financial Planning ............................................................................................................................................................ 3 C. Client Tailored Services and Client Imposed Restrictions .......................................................................................... 3 D. Wrap Fee Programs ......................................................................................................................................................... 3 E. Assets Under Management ............................................................................................................................................. 3 Item 5: Fees and Compensation ............................................................................................................................................... 4 A. Portfolio Management Fee Schedules ........................................................................................................................... 4 Financial Planning Fees .................................................................................................................................................... 5 Fixed Fees .......................................................................................................................................................................... 5 Hourly Fees ........................................................................................................................................................................ 5 B. Payment of Fees ................................................................................................................................................................ 5 C. Client Responsibility For Third Party Fees ................................................................................................................... 5 D. Prepayment of Fees .......................................................................................................................................................... 6 E. Outside Compensation For the Sale of Securities to Clients ....................................................................................... 6 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................................... 6 Item 7: Types of Clients ............................................................................................................................................................ 6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................................. 6 A. Methods of Analysis and Investment Strategies.................................................................................................... 6 B. Material Risks Involved ............................................................................................................................................ 7 Risks of Specific Securities Utilized ......................................................................................................................... 8 C. Item 9: Disciplinary Information ........................................................................................................................................... 10 Criminal or Civil Actions ....................................................................................................................................... 10 A. Administrative Proceedings ................................................................................................................................... 10 B. Self-regulatory Organization (SRO) Proceedings ................................................................................................ 10 C. Item 10: Other Financial Industry Activities and Affiliations ............................................................................................ 11 Registration as a Broker/Dealer or Broker/Dealer Representative .................................................................. 11 A. iii  Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading B. Advisor ................................................................................................................................................................................. 11 Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .............. 11 C. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections 12 D. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................... 12 Code of Ethics .......................................................................................................................................................... 12 A. Recommendations Involving Material Financial Interests ................................................................................. 12 B. Investing Personal Money in the Same Securities as Clients ............................................................................. 12 C. Trading Securities At/Around the Same Time as Clients’ Securities ............................................................... 12 D. Item 12: Brokerage Practices .................................................................................................................................................. 13 Factors Used to Select Custodians and/or Broker/Dealers ............................................................................... 13 A. Research and Other Soft-Dollar Benefits .......................................................................................................... 13 1. Brokerage for Client Referrals ............................................................................................................................ 13 2. Clients Directing Which Broker/Dealer/Custodian to Use ........................................................................... 13 3. Aggregating (Block) Trading for Multiple Client Accounts ............................................................................... 14 B. Item 13: Review of Accounts .................................................................................................................................................. 14 Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................................................ 14 A. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................................. 14 B. Content and Frequency of Regular Reports Provided to Clients ...................................................................... 14 C. Item 14: Client Referrals and Other Compensation ............................................................................................................ 14 Item 15: Custody ..................................................................................................................................................................... 15 Item 16: Investment Discretion .............................................................................................................................................. 15 Item 17: Voting Client Securities (Proxy Voting) ................................................................................................................. 15 Item 18: Financial Information ............................................................................................................................................... 16 Balance Sheet............................................................................................................................................................ 16 A. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 16 Bankruptcy Petitions in Previous Ten Years ........................................................................................................ 16 C. iv  Item 4: Advisory Business A. Description of the Advisory Firm Capital Market Strategies LLC d/b/a Alpha Beta Gamma Wealth Management (hereinafter “ABG Wealth”) is a Limited Liability Company organized in the State of Florida. The firm was formed in November 2005, and the principal owner is Curtis Lee Lyman. B. Types of Advisory Services Portfolio Management Services ABG Wealth offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ABG Wealth creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • ABG Wealth evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. ABG Wealth requests discretionary authority from clients as a standard part of our services, allowing us to select securities and execute transactions on their behalf without seeking permission before each transaction. Each client's risk tolerance level is documented in the Investment Policy Statement, which is provided to them. ABG Wealth is committed to making investment decisions that align with the fiduciary duties owed to its clients, ensuring these decisions are made without considering ABG Wealth’s own economic, investment, or other financial interests. To meet its fiduciary obligations, ABG Wealth attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, ABG Wealth is dedicated to ensuring a fair and equitable distribution of investment opportunities among its clients, aiming to prevent any preferential treatment over time. This commitment includes the allocation of appropriate and prudent investment transactions, such as initial public offerings (IPOs) and other limited supply opportunities, to ensure all clients benefit from a balanced and equitable approach over time. 2  Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax planning; retirement planning; college planning; and debt/credit planning. These services are based on fixed and or hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Services Limited to Specific Types of Investments ABG Wealth generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non- U.S. securities, venture capital funds and private placements. ABG Wealth may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ABG Wealth offers the same suite of services to all its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Please note, ABG Wealth does not participate in wrap fee programs. E. Assets Under Management ABG Wealth has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $267,040,009 $ 0.00 December 2024 3  Item 5: Fees and Compensation A. Portfolio Management Fee Schedules Floating Flat Rate Total Assets Under Management Annual Fees $0 - $1,000,000 1.00% $1,000,001 - $2,000,000 .85% $2,000,001 - $5,000,000 0.70% $5,000,001 - $10,000,000 0.55% $10,000,001 + Negotiable. There is an account minimum of $100,000, which may be waived by ABG Wealth in its discretion. There is a minimum fee for portfolio management of $75 per quarter per account. Accounts will be charged this minimum platform fee or the advisory fee, whichever is greater. For accounts smaller in size, payment of the minimum platform fee may result in the client paying a fee greater than the industry standard of 2%. In such cases the client should be aware lower fees for comparable services may be available from other sources. ABG Wealth Management allows for the possibility that clients may receive interest rates different from the standard tiered rates. Any adjustments to the advertised rates, either increases or decreases, will depend on the level of engagement between ABG Wealth Management, its Investment Adviser Representatives (IARs), and the client. This policy suggests that the rates a client receives could be personalized, reflecting the firm's discretion in adjusting rates based on the depth of the client's engagement with their financial advisors. ABG Wealth uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable, and the final fee schedule is attached as Exhibit I of the Investment Advisory Agreement. Clients may terminate the agreement without penalty for a full refund of ABG Wealth's fees within five business days of signing the Investment Advisory Agreement. Thereafter, clients may terminate the Investment Advisory Agreement immediately upon written notice. Financial Planning Fees 4  Fixed Fees The rate for creating client financial plans is up to $2,500. Fees are paid in arrears. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Clients may terminate the agreement without penalty within five business days of signing the Financial Planning Agreement. Hourly Fees Depending upon the complexity of the situation and the needs of the client, the hourly fee for these services is $350. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Clients may terminate the agreement without penalty within five business days of signing the Financial Planning Agreement. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by ABG Wealth. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees ABG Wealth collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither ABG Wealth nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management ABG Wealth does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 5  Item 7: Types of Clients ABG Wealth generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Charitable Organizations Pension and Profit-Sharing Plans Corporations or Other Businesses • • • • • Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis ABG Wealth’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. ABG Wealth uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment 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, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies ABG Wealth uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 6  B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be assuming that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies ABG Wealth's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long-term Trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically 7  surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin Transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets in a shorter time frame than desired. Options Transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized ABG Wealth's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using an investment strategy. The investment types listed below (leaving aside Treasury Inflation protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed Income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best- known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. 8  Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private Placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture Capital Funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. Securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 9  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither ABG Wealth nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither ABG Wealth nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Curtis Lee Lyman is a lawyer licensed in New York and before the U.S. courts and from time to time, may offer clients advice from those activities. Clients should be aware that these services may involve a conflict of interest. ABG Wealth Management always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of ABG Wealth Management in connection with such individual’s activities outside of ABG Wealth Management. Curtis Lee Lyman is the shareholder and officer of Alpha Beta Gamma Risk Management, PLLC, a corporation for insurance related business. He started the PLLC in July 2017. 10  Curtis Lee Lyman is an independent licensed insurance agent, and from time to time, may offer clients advice or products from those activities. Clients should be aware that insurance companies may pay a commission which could create a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. In such instances, an analysis is performed to determine whether the purchase of a commissionable insurance investment is in the client’s best interest. ABG Wealth Management always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of ABG Wealth Management in connection with such individual's activities outside of ABG Wealth Management. Curtis Lee Lyman is the managing member and treasurer at Capital Market Strategies Aviation Management, LLC. He is responsible for the operation of business related to airplane ownership. He started this activity in January 2019. Curtis Lee Lyman is the Chairman of Meiyun Haihua Company LLC. This entity was created in May 2022 to provide legal immigration and financial services to the Asian community. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ABG Wealth does not utilize nor select third-party investment advisers. All assets are managed by ABG Wealth Management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics ABG Wealth has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. ABG Wealth's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests ABG Wealth does not recommend that clients buy or sell any security in which a related person to ABG Wealth or ABG Wealth has a material financial interest. C. Investing Personal Money in the Same Securities as Clients 11  From time to time, representatives of ABG Wealth may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of ABG Wealth to buy or sell the same securities before or after recommending the buy or sell of the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. ABG Wealth will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of ABG Wealth may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of ABG Wealth to buy or sell securities before or after recommending securities transactions to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, ABG Wealth will never engage in trading that operates to the client’s disadvantage if representatives of ABG Wealth buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Broker-dealer/custodians will be recommended based on ABG Wealth’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and ABG Wealth may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the broker-dealer/custodians that may aid in ABG Wealth's research efforts. ABG Wealth will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. ABG Wealth prefers that clients utilize the services of Fidelity Clearing and Custody Services. 1. Research and Other Soft-Dollar Benefits While ABG Wealth has no formal soft dollar program in which soft dollars are used to pay for third party services, ABG Wealth may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). ABG Wealth may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and ABG Wealth does not seek to allocate benefits to 12  client accounts proportionate to any soft dollar credits generated by the accounts. ABG Wealth benefits by not having to produce or pay for the research, products or services, and ABG Wealth will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that ABG Wealth’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals ABG Wealth receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use ABG Wealth will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If ABG Wealth buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, ABG Wealth would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. ABG Wealth would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for which ABG Wealth's advisory services are provided on an ongoing basis are reviewed at least Quarterly by a registered investment adviser representative with regard to clients’ respective investment policies and risk tolerance levels. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client for whom ABG Wealth's advisory services are provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset values, and 13  fees. This written report will come from the custodian. Item 14: Client Referrals and Other Compensation ABG Wealth may enter into written arrangements with third parties to act as solicitors for ABG Wealth's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. ABG Wealth will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-3 under the Advisers Act, where applicable. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, ABG Wealth will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion ABG Wealth provides discretionary investment advisory services to clients. The advisory agreement established with each client sets forth discretionary authority for trading. Where investment discretion has been granted, ABG Wealth generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought or sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) ABG Wealth does not vote on proxies for client securities. Instead, clients will directly receive proxies and communications regarding corporate actions from their custodian or transfer agent. If any proxies are mistakenly sent to ABG Wealth, we will promptly forward them to the client and request the sender to direct future mailings directly to the client. We encourage our clients to reach out to us with any questions they may have about proxy votes or other communications. Item 18: Financial Information A. Balance Sheet ABG Wealth neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. 14  B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ABG Wealth nor its management has any financial condition that is likely to reasonably impair ABG Wealth’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years ABG Wealth has not been the subject of a bankruptcy petition in the last ten years. 15