N.E.W. Advisory Services, LLC April 2024 5 of 26 N.E.W. Advisory Services, LLC primarily uses open-ended mutual funds that are no-load and load waived or mutual funds purchased at net asset value (NAV) and exchange traded funds (ETFs). However, managed accounts are not exclusively limited to mutual funds and ETFs and may include stocks, options and bonds which are typically transferred or requested by you. Transactions in the account, account reallocations and rebalancing may trigger a taxable event, with the exception of IRA accounts, 403(b) accounts and other qualified retirement accounts. Orion Portfolio Solutions – Advisor Directed Model Portfolios N.E.W. Advisory Services, LLC offers Orion Portfolio Solutions for model management, administration such as for reporting, fee calculation, and research, model portfolios management, and rebalancing strategy. N.E.W. Advisory Services, LLC will analyze your financial situation and recommend a model portfolio appropriate to your situation and implement the investment strategy. N.E.W. Advisory Services, LLC will determine the securities, allocation of the account, and execute transactions as deemed suitable. Asset Management accounts utilizing Orion Portfolio Solutions are a bundled or wrap fee program where the client will pay one fee for asset management, administration, and transaction charges. There is an incentive for Advisory Representatives to utilize funds with no transaction charges to reduce their costs. A wrap fee program could be more expensive if no transaction fee securities are used or there is minimal trading. Financial Planning Services N.E.W. Advisory Services, LLC offers broad-based and modular financial planning services. Financial planning services will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of the client’s individual needs. N.E.W. Advisory Services, LLC may use financial planning software to assist in determining the client’s current financial position and define and quantify long term goals and objectives. The financial planning software will run hypothetical scenarios based on variables to assist a client to determine a course of action. In no way can any program or software predict future results. It is a tool to enable analysis based on historical information to review possibilities that could occur if historical events repeat. A financial plan can analyze the following areas:
• Personal: family records, budgeting, personal liability, estate information and financial goals
• Tax and Cash Flow: Income tax and spending analysis and planning for past, current, and future years. N.E.W. Advisory Services, LLC will illustrate the impact of various investments on your current income tax and future liability.
• Death and Disability: Cash needs at death, income needs of the surviving dependents, estate planning and disability income analysis
• Retirement: Analysis of current strategies and investment plans to help you work toward retirement goals
• Investments: Analysis of investment alternatives and their potential effect on a client’s portfolio. April 2024 6 of 26
• Estate Planning: Advice with respect to property ownership, distribution strategies, disposition of business interest, estate tax reduction, and tax payment techniques as well as discussion of gifts, trusts, etc. Further, a review of death and disability issues will be examined. Tax consequences and their implications are identified and evaluated. N.E.W. Advisory Services, LLC will schedule a meeting with you and present the analysis of your situation and recommendations for steps to be taken to assist you to work toward financial goals. Plans are based on your financial situation at the time and are based on financial information disclosed by you to N.E.W. Advisory Services, LLC. You are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. N.E.W. Advisory Services, LLC cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify N.E.W. Advisory Services, LLC promptly of the changes. The advice offered by N.E.W. Advisory Services, LLC may be limited and is not meant to be comprehensive. Therefore, you may need to seek the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through N.E.W. Advisory Services, LLC or Advisory Representatives. Should you implement the plan with N.E.W. Advisory Services, LLC’s Advisory Representatives commissions or other compensation will be received in addition to the advisory fee paid to N.E.W. Advisory Services, LLC. 401(K) Advisory and Retirement Plan Consulting Services N.E.W. Advisory Services, LLC offers retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting its management and fiduciary obligations to the plan under ERISA. N.E.W. Advisory Services, LLC offers the following services: i. Provide non-discretionary investment recommendations to the Client with respect to the included Assets in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, removal and addition of investment options including the selection of prudent and appropriate share classes. ii. Assist the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. The Client retains the sole responsibility for all other compliance with ERISA section 404(c). iii. Assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. April 2024 7 of 26 iv. Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformity to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. v. Meet with Client at least annually to review plan reports and the investment recommendations, and more frequently at the discretion and agreement of the Advisor and Client. vi. Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a QDIA for participants whom no investment selection has been made. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). vii. Advisor will provide investment advice to participants in group settings. In addition to the fiduciary services provided above, N.E.W. Advisory Services, LLC may perform certain non-fiduciary services for employee benefit plans and their fiduciaries. In those instances, N.E.W. Advisory Services, LLC may provide the following services: i. Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that N.E.W. Advisory Services, LLC’s assistance in participant investment education shall be consistent with and within the scope of (d) (i.e., the definition of investment education) of Department of Labor Interpretive Bulletin 96-1. ii. Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. iii. Offer services to plan participants regarding assets outside the plan. These services will be governed by agreements directly with the participant and considered outside the scope of this Agreement. It is understood and will be communicated to the participant that the Client does not specifically endorse these services. Costs of these services may vary from those charged inside the Plan and will be based on the scope and complexity of each participant’s situation. N.E.W. Advisory Services, LLC will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. We will also provide additional disclosures about our services and fees, where required by ERISA. C. N.E.W. Advisory Services, LLC tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. N.E.W. Advisory Services, LLC will ask you to complete a fact finder or data gathering questionnaire to assist N.E.W. Advisory Services, LLC with obtaining information about your financial situation and history. Additionally, N.E.W. Advisory Services, LLC will meet with you and conduct an interview and data gathering session to continue the due diligence process. The information gathered by N.E.W. Advisory Services, LLC will assist N.E.W. Advisory Services, LLC to provide you with the requested services and customize the April 2024 8 of 26 services to your financial situation. Depending on the services you have requested, N.E.W. Advisory Services, LLC will gather various financial information and history from you including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by N.E.W. Advisory Services, LLC in order

to provide the investment advisory services requested. D. There is no significant difference between how N.E.W. Advisory Services, LLC manages wrap fee accounts and non-wrap fee accounts. However, as stated above, if a client determines to engage N.E.W. Advisory Services, LLC on a wrap fee basis the client will pay a single fee for bundled services (i.e., investment advisory, brokerage, custody). The services included in a wrap fee agreement will depend upon each client’s particular need. If the client determines to engage N.E.W. Advisory Services, LLC on a non-wrap fee basis the client will select individual services on an unbundled basis, paying for each service separately (i.e., investment advisory, brokerage, custody). Please Note: When managing a client’s account on a wrap fee basis, N.E.W. Advisory Services, LLC shall receive as payment for its investment advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee have been deducted. Wrap programs are more suitable for clients who will have active management in their account and transactions will not generally involve transactions where transaction fees are not charged. Asset management services that involve the use of no transaction fee funds and/or a more static management strategy, therefore, infrequent trading, will be more suitable for a non-wrap or unbundled program. Additionally, as disclosed under Item 5, there is a conflict of interest for N.E.W. Advisory Services, LLC to use no transaction fee securities in a wrap account to reduce its costs. See the Wrap Fee Appendix 2A for additional details on wrap fees. E. As of December 31, 2023, N.E.W. Advisory Services, LLC has approximately $1,071,272,133 discretionary assets under management and $27,478,883 non-discretionary assets under management. General Information The investment recommendations and advice offered by N.E.W. Advisory Services, LLC are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. It is necessary to inform N.E.W. Advisory Services, LLC promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify N.E.W. Advisory Services, LLC of any such changes could result in investment recommendations not meeting your needs. April 2024 9 of 26 IRA Rollover Considerations As an investment adviser, we are a fiduciary to our advisory clients. As fiduciaries, we are expected to act and provide advice in the best interests of clients; have a duty to be loyal to our clients; make full and fair disclosure of all material conflicts of interest; seek best execution for client transactions; ensure that investment advice is suitable for clients' objectives, needs and circumstances; have a duty to have a reasonable, independent basis for investment advice; and refrain from effecting personal securities transactions that are inconsistent with client interests. If your account is a retirement account and subject to the Employee Retirement Income Security Act of 1974, we are also a fiduciary within Section 3(21) under the Employee Retirement Income Security Act of 1974 (ERISA), as amended. As ERISA fiduciaries, we are expected to provide advice that is in your best interest; only charge fees that are reasonable; and not make any materially misleading statements about recommended transactions, fees and compensation, conflicts of interest, or any other matters relevant to your investment decisions. As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations may include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on your behalf have an incentive to recommend a rollover to you for the purpose of generating fee based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Move the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: April 2024 10 of 26 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. April 2024 11 of 26 Asset Management Services A. Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds. You may make additions to the Account or withdrawals from the Account. No fee adjustments will be made for Account appreciation or depreciation. N.E.W. Advisory Services, LLC aggregates or households all of your managed accounts together to determine your monthly fee. For example, if you have four managed accounts with a value of: $101,569.40, $55,498.46, $675,879.50, and $74,301.12 with a total value of $907,248.48, you will not pay a fee on the managed accounts greater than 1.20% on all accounts. N.E.W. Advisory Services, LLC may change the above fee schedule upon 30-days prior written notice to you. N.E.W. Advisory Services, LLC offers clients two account options: A wrap fee program or bundled fee program and a non-wrap or unbundled fee program. The difference between a wrap fee program and a non-wrap fee program is in a wrap fee program the client will pay a higher advisory fee but will not pay transaction charges. Wrap fee programs can be more or less expensive depending on if no-transaction fee securities are generally used and if there is minimal trading. Non wrap fee accounts can be more expensive if there is frequent trading and securities charging transaction fees are generally used Non-Wrap Program Account Value N.E.W Advisory Services Fee $0 - $49,999 1.50% $50,000 - $99,999 1.40% $100,000 - $249,999 1.30% $250,000 - $499,999 1.25% $500,000 - $999,999 1.20% $1,000,000 - $1,999,999 1.15% $2,000,000 - $2,999,999 1.13% $3,000,000 - $3,999,999 1.11% $4,000,000 - $4,999,999 1.09% $5,000,000 - $7,499,999 1.05% $7,500,000 and above 1.00% In addition to the advisory fees above, you will pay transaction fees for securities transactions executed in your account in accordance with the custodian’s transaction fee schedule. Additionally, you will pay fees for custodial services, account maintenance fees to the account custodian and any third party platform, transaction fees, and other fees associated with