NexAdvisors, LLC (“NexAdvisors,”, “Advisor”, “Registrant”, “Firm”, “we” or “us”) is an investment adviser registered with the SEC and provides investment advisory services to our clients (individuals, business entities, trusts, and pension and profit-sharing plans, etc.), directly or through one of our affiliated entities. OWNERSHIP NexAdvisors, LLC is owned by NexAnnuity Holdings, Inc. The Dugaboy Investment Trust owns a majority interest in NexAnnuity Holdings, Inc., whose wholly owned subsidiaries include NexPoint Insurance Solutions, L.P., The Ohio State Life Insurance Company, NexAnnuity Asset Management, L.P., NexAnnuity Services, LLC and NexAnnuity Insurance Distributors, LLC. INVESTMENT ADVISORY SERVICES We provide discretionary and/or non-discretionary investment advisory services to individuals, high-net-worth individuals, high net worth families, business or trust entities, and retirement plans. We may allocate some assets among affiliated funds or other investment vehicles (including those advised by our investment advisor affiliates identified in Item 10 hereof, “Affiliated Funds”) in a recommended mix. Before engaging us to provide investment advisory services, clients are required to enter into an agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that a client will incur. While we believe our portfolios offer a level of diversification and liquidity that can make it appropriate for a portion of most large investor portfolios, we tailor client portfolios as needed for client suitability. Before providing investment advisory services, we plan to ascertain the size of the client’s investment portfolio, liquidity needs and risk tolerance. ERISA PLAN ENGAGEMENTS We may be engaged to provide investment advisory services to ERISA retirement plans, whereby we shall manage plan assets consistent with the investment objective designated by the plan sponsor. In such engagements, we will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). We generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the plan and us. We may also provide investment advisory services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between us and the plan. For such engagements, we will assist the plan with the selection of an investment platform from which plan participants shall make their respective investment choices, and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process.
AFFILIATED FUND ALLOCATIONS AND POTENTIAL CONFLICT OF INTEREST As discussed above, we may allocate some assets among affiliated funds or other investment vehicles (including those advised by our investment advisor affiliates identified in Item 10 hereof, “Affiliated Funds”) in a recommended mix. This allocation will be made notwithstanding that other non-affiliated funds may be available in the marketplace that offer lower fees and/or periods of higher performance. A conflict of interest arises whenever the Registrant has an actual or perceived economic or other incentive in its management of client’s accounts in a way that benefits the Registrant. A conflict is present

where we invest in our Affiliated Funds or investment vehicles because such allocation not only increases the assets under management of our affiliates but also results in additional fee income to such affiliates as stipulated in the governing documents of the Affiliated Funds or investment vehicles. The applicable fees associated with any such affiliated vehicles will be disclosed to clients prior to any investment; in the case of a qualified retirement plan subject to ERISA, Registrant’s fee disclosures shall satisfy the applicable requirements of 29 C.F.R. 2550.408(b)-2(c). In addition, we also have a conflict with respect to how we allocate among the funds our affiliates manage if one fund charges higher fees. The Registrant is not required to deviate from this allocation except where required under applicable law (e.g. ERISA). The Registrant will comply with ERISA and Section 4975 of the Internal Revenue Code for all purchases of Affiliated Funds or vehicles in Individual Retirement Accounts or in qualified retirement plans subject to ERISA. The Registrant will not use any of its authority, control, or responsibility as a fiduciary with respect to a retirement plan subject to ERISA or an Individual Retirement Account, to cause such retirement plan or an Individual Retirement Account to purchase shares of Affiliated Funds or investment vehicles. Any purchase of shares of affiliated funds or investment vehicles by a retirement plan subject to ERISA or by an Individual Retirement Account will be made only if approved by a fiduciary of the retirement plan or Individual Retirement Account independent of the Registrant. MISCELLANEOUS Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by Registrant. Client Obligations. In performing its services, except as may be required by law, Registrant shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or risk tolerance for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. The Registrant encourages each client to review the documents for each underlying fund including each relevant Affiliated Fund, the relevant offering documents along with related investment risks in Section 8 “Methods of Analysis, Investment Strategies and Risk of Loss” in this brochure and fee disclosure in Item 5 “Fees and Compensation.”