Firm History and Ownership NEIRG Wealth Management, LLC (“NEIRG” or the “Firm”) is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a limited liability company formed under the laws of the State of Delaware. NEIRG acquired the investment advisory business of New England Investment & Retirement Group, Inc., which was founded in 1995 by Nicholas Giacoumakis. NEIRG is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, NEIRG is a wholly owned subsidiary of Connectus Group, LLC, which is a wholly owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is a wholly owned subsidiary of Focus LLC. Focus Financial Partners Inc. (“Focus Inc.”) is the sole managing member of Focus LLC and is a public company traded on the NASDAQ Global Select Market. Focus Inc. owns approximately two-thirds of the economic interests in Focus LLC. Focus Inc. has no single 25% or greater shareholder. Focus Inc. is the managing member of Focus LLC and has 100% of its governance rights. Accordingly, all governance is through the voting rights and Board at Focus Inc. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. NEIRG is managed by Nicholas Giacoumakis, Brian Pirri, Robert Cowles and Christopher Wilde, who serve as officers of NEIRG and, in that capacity, are responsible for the management, supervision and oversight of NEIRG. The Firm's business is to provide investment management services as well as other ancillary services necessary to meet the financial needs of its clients. Wealth and Investment Management Services Asset Management Services. The Firm provides asset management services directly to clients, including high-net-worth individuals or families, trusts, estates, endowments, retirement plans and other legal entities. NEIRG generally provides investment guidance with respect to long/short equity and fixed income securities in a wide range of market capitalizations. Types of Investments. NEIRG uses a number of centrally managed strategies or 'models' as building blocks for account diversification. The NEIRG models are designed with varying investment objectives, strategies, weightings of equities, fixed income and alternative investments, and risk. NEIRG's advice may include advice regarding the following securities:
• mutual funds
• exchange-traded funds
• equities (stocks)
• warrants
• corporate debt securities
• managed futures funds
• CDs
• municipal securities
• investment company securities (including variable annuities, variable insurance trusts, mutual fund shares)
• U.S. government securities
• options
• futures contracts and exchange traded funds
• bonds
• direct participation programs (including alternative energy programs, research and development programs, and leasing programs)
• real estate investment trusts ("REITS")
• collateralized mortgage obligations ("CMOs") If appropriate, NEIRG may recommend hedge funds or other restricted and/or unregistered products to qualified clients. Initial public offerings (IPOs) are not available through the Firm. NEIRG also offers asset allocation services and investment recommendations to clients regarding variable annuity products, 529 college savings plans, and/or individual employer-sponsored retirement and deferred compensation plans. We either direct or recommend the allocation of assets among the various mutual fund and investment choices offered by the variable annuity, 529 plan or retirement/deferred compensation plan. Your assets are maintained at either the specific fund company or insurance company that issued the variable annuity or 529 plan or at the custodian designated by the sponsor of your retirement/deferred compensation plan. Retirement Plan Account Allocation Advice. With respect to individuals’ accounts under employer- sponsored retirement and deferred compensation plans, we may recommend the allocation of assets among the various mutual fund and other investment choices offered by the plan (which we refer to as “Plan Account Allocation Services”), but we do not assume custody of or have investment discretion with respect to such investments. Further, if such retirement and deferred compensation plan permits you to direct investment in individual securities (for example, using a directed “brokerage window”), we may, on request, recommend individual investments and will advise you on the securities you hold in the plan. You are responsible for implementing any recommendations we provide. Your plan account is governed by the plan documents and agreements with your plan’s sponsor and other fiduciaries, including rules that specify the extent to which you may direct the investment of your account. We do not sponsor or provide advice to the plan and are not otherwise a party to the plan. We will recommend an asset allocation to you based on the information you provide about your financial situation, retirement investment objectives, and desired investment style, taking into account the investments available to you under the plan. We may also advise you periodically of any changes to the recommended investment strategy and selection of particular funds. You may accept the recommended strategy and advice regarding particular funds when directing your retirement plan account, or you may choose a different investment strategy or funds from time to time. Services for Retirement Plans. We advise 401(k) plans and other employer-sponsored retirement plans. Those services include advising the sponsor with respect to investment alternatives, default investments, performance of available investment options, and changes in investment options. We assist the sponsor with development of an investment policy statement and review investments against the policy. Our services include participant education, enrollment, and counseling on model portfolios, asset allocation and investment objectives generally. NEIRG is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including plan participants. NEIRG is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, NEIRG is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either

avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). Financial Planning Services. The Firm provides wealth management consulting services to clients upon request. A financial plan will be developed consistent with a client's financial and tax status, age, risk tolerance and investment objectives. NEIRG will gather financial information and history from clients 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, and other applicable financial information required by NEIRG in order to provide the consulting services requested. Based upon a client's needs, NEIRG will prepare a written financial plan addressing those needs. Whether or not to implement any of the recommendations detailed in the plan is at the client's discretion. NEIRG may also provide other general, non-securities consultation on topics including tax planning analysis, estate planning analysis, business planning, retirement planning, education planning, budgeting and cash flow, risk management/insurance services, and/or fringe benefit analysis. NEIRG and its employees do not provide legal advice, and do not provide tax advice outside of the advice given in relation to financial planning and asset management services. Implementation of any recommendations is at the discretion of the client. Rejection of Client Accounts. NEIRG reserves the right to reject any account not consistent with its investment philosophy and reserves the right to decline management of any accounts for non-U.S. citizens. Adviser Liability. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Individual Client Needs for Wealth and Investment Management Services The Firm manages each client relationship individually in accordance with the client's stated investment goals and objectives. The Firm's financial advisers will gather information on a client's financial history, goals, objectives, and financial concerns and assist the client in developing an asset allocation strategy. To assist our clients with developing an investment objective, NEIRG prepares a Client Profile, Investor Questionnaire and Risk Profile ("Client Profile") for the client to complete. In addition to the information provided on the Client Profile, a financial adviser will schedule meetings with prospective clients to further understand their investment goals and objectives, and provide ongoing monitoring of client accounts. All information gathered from a client is confidential. (Please see Item 13 Review of Accounts for further information.) The Firm will accommodate reasonable account restrictions imposed by the client with respect to management of accounts. However, the Firm reserves the right to decline guidelines submitted by clients determined in its sole judgment to be unduly restrictive or inappropriate in light of the client's suitability and/or risk tolerance. Except as otherwise stated herein (e.g., for Plan Account Allocation Services), NEIRG generally has discretionary authority of its clients' accounts for the limited purpose of buying and selling securities in the accounts without communicating with the client prior to each transaction decision. The client always makes the final decision on the overall investment strategy. (Please see Item 16 Investment Discretion for further information.) NEIRG may tailor the level of service among varying client types. For example, high-net-worth client arrangements may include additional advisory services not required or desired by other clients, such as recommendation of alternative investment vehicles, ongoing education regarding certain estate planning concepts, and more periodic evaluation of performance and investment objectives. Smaller accounts may not be invested fully in NEIRG models due to account size limitations. All advisory clients are assigned a financial adviser to oversee their investment accounts. Pooled Investment Vehicle An affiliate of NEIRG, TopRidge Capital Partners II, LLC, serves as the general partner (the “General Partner”) of one affiliated private investment fund, TopRidge Capital Partners (AI), L.P. The Firm serves as the investment manager of the Fund. The Fund is an unregistered pooled investment vehicle that was offered and sold to high-net-worth individual investors as well as institutional investors including endowments, foundations, and other entities, in each case that are “accredited investors” as defined in Regulation D under the Securities Act and “qualified clients” or “qualified purchasers” as defined in the Investment Company Act. Please note that any information provided in this Brochure regarding the Fund merely summarizes the detailed information provided in the Fund’s offering and/or organizational documents. Current Fund investors or prospective investors in any new Fund launched by NEIRG should be aware of the substantial risks associated with an investment as well as the terms applicable to such investment. This and other detailed information are provided in the Fund offering and/or organizational documents. A conflict of interest exists as NEIRG has a financial incentive to recommend an investment in the Fund to promote the success of the Fund. NEIRG will devote its best efforts with respect to its management of the Fund and its individual client accounts. Additional information about our affiliation with the Fund is provided in Item 10 of this Brochure. Focus Risk Solutions, LLC (“FRS”) We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, FRS, a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Focus Treasury & Credit Solutions, LLC (“FTCS”) We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions with the assistance of our affiliate, FTCS, a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. SCS Capital Management LLC (“SCS”) We have a business arrangement with SCS, who is an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of NEIRG have the option of investing in certain private investment vehicles managed by SCS. NEIRG is an affiliate of SCS by virtue of being under common control with it. Please see Items 5, 10, and 11 of this Brochure for further details. Assets Under Management As of December 31, 2022, NEIRG had $883,229,573 in client assets on a discretionary basis, and $16,101,641 in client assets on a non-discretionary basis.