Description of Firm Marmo Financial Group, LLC is a registered investment adviser based in Johnson City, TN. We are organized as a limited liability company ("LLC") under the laws of the State of Tennessee. We have been providing investment advisory services since 04/01/2007. We are owned by Scott A. Marmo.
As of December 31, 2023, MFG managed $225,940,649 on a discretionary basis, and $29,406 assets on a non-discretionary basis.
Types of Investments We primarily offer advice on Mutual Funds & Exchange Trade Funds "ETF's". Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
SERVICES PROVIDED At the outset of each client relationship, MFG spends time with the client, asking questions, discussing the client's investment experience and financial circumstances, and broadly identifying major goals of the client.
Clients may elect to retain MFG to prepare a full financial plan as described below. This written report is presented to the client for consideration. In most cases, clients subsequently retain MFG to manage the investment portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need financial planning but retain MFG for portfolio management services, based on all the information initially gathered, MFG generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the client's risk tolerance level (the "Financial Profile" or "Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan" or "Plan"). The Financial Profile is a reflection of the client's current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments MFG will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client, but are not necessarily written documents.
Financial Planning Services One of the services offered by MFG is financial planning, described below. This service may be provided as a stand-alone service, or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. Depending on a client's particular situation, financial planning may include some or all of the following:
•Gathering factual information concerning the client's personal and financial situation;
•Assisting the client in establishing financial goals and objectives;
•Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
•Identifying problems foreseen in the accomplishment of these financial goals and objectives 4 and offering alternative solutions to the problems;
•Making recommendations to help achieve retirement plan goals and objectives;
•Designing an investment portfolio to help meet the goals and objectives of the client;
•Providing estate planning;
•Assessing risk and reviewing basic health, life and disability insurance needs; or
•Reviewing goals and objectives and measuring progress toward these goals. Financial plans are based on your unique financial situation at the time we present the plan to you, and based upon the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. Once financial planning advice is given, the client may choose to have MFG implement the client's financial plan and manage the investment portfolio on an ongoing bases. However, the client is under no obligation to act upon any of the recommendations made by MFG under a financial planning engagement and/or to engage the services of any properly credentialed professional. Portfolio Management As described above, at the beginning of a client relationship, MFG meets with the client, gathers information and performs research and analysis as necessary to develop the client's Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by MFG based on updates to the client's financial or other circumstances.
To implement the client's Investment Plan, MFG will manage the client's investment portfolio on a discretionary basis. As a discretionary investment adviser, MFG will have the authority to supervise and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on MFG in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of MFG.
Small Account Services MFG offers combined retirement income planning and portfolio management services for portfolios under $50,000. Such services include ongoing management of the client's investment portfolio and a retirement planning consultation. Clients will also be provided access to certain MFG technology platforms to further assist with planning and monitoring of the client's portfolio.
Retirement Plan Advisory Services MFG provides a broad range of comprehensive consulting services to employer sponsored retirement plans, including 401(k), pension and profit sharing plans (the "Plan(s)"). These services may include:
•Retirement plan design and communications;
•Retirement plan service provider search;
•Retirement plan investment advisory services, including: investment analysis, selection, implementation, and ongoing monitoring of plan investments; and 5
•Participant educational services and retirement education. MFG may also provide additional types of administrative services to Plans on an individually negotiated hourly basis. All services, whether discussed above or customized for the Plan will be detailed in the written agreement with the Plan client.
Establishing a sound fiduciary governance process is vital to good

decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. MFG will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan.
Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 ("ERISA") sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, MFG will be considered a fiduciary under ERISA. For example, MFG will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain MFG to act as an investment manager within the meaning of ERISA § 3(38), MFG will provide discretionary investment management services to the Plan.
With respect to any account for which MFG meets the definition of a fiduciary under Department of Labor rules, MFG acknowledges that both MFG and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between MFG and Client.
Fiduciary Consulting Services
•Investment Selection Services MFG will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).

•Non-Discretionary Investment Advice MFG may provide Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.

•Investment Monitoring MFG will assist in monitoring the plan's investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and MFG will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties.
6 Fiduciary Management Services
•Discretionary Management Services When retained as an investment manager within the meaning of ERISA § 3(38), MFG provides continuous and ongoing supervision over the designated retirement plan assets. MFG will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, MFG will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.

•Discretionary Investment Selection Services MFG will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. MFG will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants.

•Investment Management via Model Portfolios. MFG will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual fund options made available in the Plan, and choose not to invest in the Model Portfolios at all).
Non-Fiduciary Services
•Participant Education MFG will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages MFG for such services. Plan Participants are responsible for implementing transactions in their own accounts.

•Participant Enrollment MFG will assist with group enrollment meetings designed to increase retirement Plan participation among employees as well as investment and financial understanding by the employees. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice); 7
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.