HFG is a joint venture between Herbein + Company, Inc. (“H+C”) and Northeast Financial Group, Inc. (“NEFG”). NEFG is a registered investment adviser. HFG filed for registration as an investment adviser in July 2022 and is owned by H+C and NEFG. HFG does not have any assets under management; however, the Firm will be registered with the Securities Exchange Commission because it is under common control and shares the same principal office and place of business as NEFG. The Firm does not expect to have assets under management but will report assets under advisement in the future, which will be the assets at NEFG where the Firm has the primary relationship. HFG offers a variety of advisory services, which include financial planning, consulting, and investment management services. Some of these services are provided in conjunction with NEFG. The services are often described throughout this brochure as being provided through NEFG as well as describing the services as provided by the “Firms” which includes HFG and NEFG. Prior to HFG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with HFG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). The Advisory Agreement could be a tri-party agreement between the Firm, the client and NEFG. Alternatively, the client could have an agreement with the Firm which allows the Firm to engage NEFG for the services. While this brochure generally describes the business of HFG, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on HFG’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services HFG offers, directly or in coordination with NEFG, a broad range of financial planning and consulting services, addressing a variety of matters, which include any or all of the following functions:
• Financial plan maintenance • Education funding
• Estate planning • Risk management
• Cash flow analysis • Long-term care assessment
• Business planning • Tax Planning
• Retirement planning • Disability and survivorship planning In performing its services, HFG is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. HFG recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if HFG recommends its own services or those offered by its Supervised Persons. The client is under no obligation to act upon any of the recommendations made by HFG under a financial planning or consulting engagement or to engage the services of any such recommended professional, including HFG itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of HFG’s recommendations. Clients are advised that it remains their responsibility to promptly notify HFG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising HFG’s previous recommendations and/or services. Investment Management Services All of the Firm’s Investment Management Services are provided through NEFG. Clients will be provided with a copy of NEFG’s Disclosure Brochure in addition to this brochure. Clients should review the NEFG brochure which will provide all current information about NEFG’s services, fees, conflicts of interest and any other material information required. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage HFG to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, HFG directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. HFG and NEFG tailor the advisory services to meet the needs of individual clients and seek to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. HFG and NEFG consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify HFG if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if HFG and NEFG determine, in their sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the management efforts. 1031 Tax-Free Real Estate Exchange Services The Firm or HFG provides services in the review and selection of properties and programs to complete 1031 tax-free real estate exchanges. The Firm or NEFG will recommend Qualified Intermediaries, or work with the buyers Qualified Intermediary to assist in the complete transaction. Services include research and recommendations of primary and or secondary backup properties or programs to satisfy the requirements of identifying and completing the transactions within the required time limits. Retirement Plan Services The Firms provide comprehensive services to retirement plans, including retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), “ERISA Plans.” Participant-Level Investment Advisory Services: HFG provides non-discretionary investment advisory services to retirement plan participants

about the plan investment options (“Participant-Level Investment Advisory Services”). The plan participant has the final decision-making authority regarding the initial selection, retention and changes in investment selections. In providing Participant-Level Investment Advisory Services to participants of ERISA Plans, HFG is acting as a fiduciary under ERISA. Plan-Level Investment Advisory and Investment Management Services: All of the Firms’ plan-level investment advisory services and investment management services are provided through NEFG. Retirement plan clients are provided with a copy of NEFG’s Disclosure Brochure which provides detailed information about the plan-level investment advisory and investment management services provided to retirement plans, including ERISA Plans. In providing plan-level investment advisory and investment management services to ERISA Plans, NEFG is acting as a fiduciary under ERISA. Consulting Services: HFG provides consulting services to retirement plan clients that may include assisting in group enrollment meetings, educating plan participants about general investment principles and the plan’s investment options and in the case of an ERISA Plan, educating the ERISA Plan client as to its fiduciary responsibilities. HFG’s consulting services may also include assisting retirement plan clients in monitoring, selecting and supervising plan service vendors and performing benchmarking studies. For a more detailed description of the Firms’ services, the retirement plan client should refer to the Advisory Agreement. Use of Independent Managers As mentioned above, HFG uses the advisory services of NEFG for all clients. NEFG selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between NEFG and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Management of Pooled Investment Vehicles Robert L. Hackenberg serves as the managing member to affiliated private investment funds, H&L Capital Group, LLC, H&L Capital II, LLC. In addition, Robert L. Hackenberg and Josh R. Laychock serve as the managing members of NEFG Capital Partners LLC, the managing member to two additional affiliated private investment funds, Capital Partners Alternative Income & Growth Fund, LLC and Capital Partners Lending Fund, LLC (collectively with H&L Capital Group, LLC and H&L Capital II, LLC, “the Funds”). Interests in the Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Funds currently rely on an exemption from registration under the Investment Company Act of 1940, as amended. Participation as an investor in the Funds is restricted to investors that are qualified clients pursuant to the requirements under Rule 205-3 under the Advisers Act, as well as “accredited investors” as defined under Rule 501(a) of the Securities Act of 1933, as amended and “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended. To the extent certain that the Firm’s individual advisory clients qualify, they will be eligible to participate as members of the Funds. Investment in the Funds involves a significant degree of risk. All relevant information, terms and conditions relative to the Funds, including the compensation received by NEFG or its affiliate as managing member, suitability, risk factors, and potential conflicts of interest, are set forth in the Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and/or Subscription Agreement of each Fund (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Funds. While the Funds are generally considered to be a client of NEFG, “client(s)” may also refer to the investors in the Funds. NEFG will devote its best efforts with respect to its management of both the Funds and the individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Funds, NEFG may give advice or take action with respect to the Funds that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Funds and certain individual client accounts, such investments will be allocated between the Funds and the individual client accounts in a manner which NEFG determines is fair and equitable under the circumstances to all of its clients. Conflict Disclosure for Rollover Recommendation A conflict of interest arises when HFG makes recommendations about retirement plan distributions and rollovers to IRAs, IRA to IRA transfers, IRA to plan rollovers, plan to plan rollovers and change of account types for a retirement plan or IRA (each, a “rollover recommendation”) if it results in HFG receiving compensation that it would not have received absent the recommendation, for example, fees for advising or managing a rollover IRA. HFG will manage this conflict through a process designed to develop an informed recommendation in the best interest of the client. No client is under an obligation to roll over retirement plan or IRA assets to an account advised or managed by HFG. When HFG makes a rollover recommendation, it is fiduciary advice under the Investment Advisers Act of 1940 (the “Advisers Act”). Also, when HFG provides investment advice to a plan participant about his/her retirement plan account or to an IRA owner about his/her IRA, including a rollover recommendation, HFG is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. In addition to being a conflict of interest, it is also a prohibited transaction under ERISA and/or the Code when HFG receives compensation as a result of the rollover that it would not have received absent the recommendation. In that circumstance, HFG will comply with the conditions of exceptions to the prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as PTE 2020-02 or non-enforcement policy). Herbein Financial Group, LLC