A. NPPG Plan Professionals, LLC (“NPPG,” “we,” or “us”) is a limited liability company formed
in January, 2021 in the State of New Jersey. Michael M. Salerno is the President and
Managing Member. NPPG is wholly owned by NPPG Holdings, LLC, which is ultimately
controlled by Mr. Salerno. NPPG is registered as an investment adviser with the United
States Securities and Exchange Commission.
B. PENSION CONSULTING SERVICES – Non-NPPG-Sponsored Plans
NPPG may be engaged by ERISA-qualified retirement plans to assist with the discretionary
or non-discretionary selection and/or monitoring of investment options (generally open-
end mutual funds) from which plan participants may choose in self-directing the
investments for their individual plan accounts. NPPG provides this service in its capacity
as a “fiduciary” as defined under ERISA Section 3(21) and, when engaged on a
discretionary basis, as an “investment manager” as defined under ERISA Section 3(38).
NPPG may also retain a qualified investment fiduciary or directly create discretionary
asset allocation models, from which plan participants may choose in managing their
individual retirement accounts. The composition of asset allocation models are not
restricted to the investment options made available directly to plan participants. The
composition and allocation of model assets may be managed by NPPG on a discretionary
basis in its capacity as an ERISA 3(38) investment manager.
NPPG also offers a comparable suite of services to non-ERISA and non-qualified
retirement plans.
PENSION CONSULTING SERVICES – NPPG-Sponsored Pooled Employer Plans
NPPG is a Pooled Plan Provider (“PPP”) under the Setting Every Community Up for
Retirement Enhancement Act (the “SECURE Act”). In this role, NPPG serves as the named
plan fiduciary for pooled employer plans (“PEPs”). Conducting the pension consulting
services described herein may be a requirement of NPPG in performing its duties and
responsibilities as the PPP.
Employers who participate in an NPPG-sponsored PEP will engage NPPG to assist with the
discretionary or non-discretionary selection and/or monitoring of investment options
(generally open-end mutual funds) from which plan participants may choose in self-
directing the investments for their individual plan retirement accounts. NPPG provides
this service in its capacity as a “fiduciary” as defined under ERISA Section 3(21) and as PPP
under the SECURE Act.
NPPG may also retain a qualified investment fiduciary or directly create discretionary
asset allocation models, from which plan participants may choose in managing their
individual retirement accounts. The composition of asset allocation models are not
restricted to the investment options made available directly to plan participants. The
composition and allocation of model assets may be managed by NPPG on a discretionary
basis in its capacity as PPP under the SECURE Act.
SELECTION OF OTHER ADVISERS
As part of our investment advisory services, we may also recommend third-party advisers
(“TPA”) to you for investment advisory services. The TPA may be retained to manage a
portion of, or a plan’s entire, portfolio. In doing so, our primary objective is to align you
with the appropriate TPA(s) to allow you to capitalize on opportunities with the goal of
strengthening or enhancing your portfolio. Under such arrangements, we will monitor the
TPA’s performance to ensure that it remains aligned with your stated investment goals
and objectives.
Factors that we take into consideration when making our recommendation(s) include, but
are not limited to, the following: the TPA’s performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance, and investment objectives.
We do not charge you a separate fee for the selection of other advisers. We may share in
the advisory fee you pay directly to the TPA. The advisory fee you pay to the TPA is
established and payable in accordance with the brochure provided by each TPA retained
or recommended by NPPG. These fees may or may not be negotiable. Our compensation
may differ depending upon the individual agreement we have with each TPA. As such, a
conflict of interest may arise, as we have an incentive to recommend one TPA over
another TPA based on one TPA offering more favorable compensation arrangements.
If NPPG retains a TPA(s) or you are referred to a TPA(s), you will receive full disclosure,
including services rendered and fee schedules, at the time of the referral by delivery of a
copy of the relevant
TPA’s Form ADV Part 2 or equivalent disclosure document. Either our
firm or the TPA will provide you with all appropriate disclosure statements, including
disclosure of any solicitation fees we may receive.
You may be required to sign an agreement directly with the recommended TPA(s). You
may terminate your advisory relationship with the TPA according to the terms of your
agreement with the TPA. You should review each TPA’s brochure for specific information
on how you may terminate your advisory relationship with the TPA and how you may
receive a refund, if applicable. You should contact the TPA directly for questions regarding
your advisory agreement with the TPA.
MISCELLANEOUS
Client Obligations. In performing its services, NPPG 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 the
client’s responsibility to promptly notify NPPG if there is ever any change in the client’s
financial situation or investment objectives for the purpose of reviewing, evaluating, or
revising NPPG’s previous recommendations and/or services.
Periods of Account Inactivity. NPPG has a fiduciary duty to provide services consistent
with the client’s best interest. As part of its investment advisory services, NPPG will review
a client’s investment lineup and or account (as applicable) on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, mutual fund manager tenure, style drift, and/or a
change in the plan’s or client’s investment objective. Based upon these factors, there may
be extended periods of time when NPPG determines that changes are neither necessary
nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below
during such periods. Of course, as indicated below, there can be no assurance that
decisions and/or recommendations made by NPPG will be profitable or equal any specific
performance level(s).
ERISA / IRC Fiduciary Acknowledgment. When NPPG provides investment advice to a
client regarding the client’s retirement plan and/or retirement plan account, it does so as
a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. The way NPPG makes money creates some conflicts with
client interests, so NPPG operates under a special rule that requires it to act in the client’s
best interest and not put its interests ahead of the client’s.
Under this special rule's provisions, NPPG must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put its financial interests ahead of the client’s when making
recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that NPPG gives advice that is
in the client’s best interest;
• Charge no more than is reasonable for NPPG’s services; and
• Give the client basic information about conflicts of interest.
Investment Risk. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by NPPG) will be profitable or equal any specific performance level(s).
B. NPPG provides advisory services specific to the needs of each client. Prior to providing
advisory services, an investment adviser representative will consult with the client to
determine their needs, goals, and objectives. Thereafter, NPPG’s advisory services will be
provided in a manner consistent with those identified needs, goals, and objectives. The
client may, at anytime, impose reasonable restrictions, in writing, on NPPG’s advisory
services.
C. NPPG does not participate in a wrap fee program. For these purposes, a “wrap fee
program” is considered to be an investment program where the client is charged a single,
bundled, or “wrap” fee for investment advice, brokerage services (such as commissions
and other transaction fees), administrative expenses, and other fees and expenses.
D. As of December 31, 2023, NPPG has approximately $3,152,539,436 in discretionary assets
under management and approximately $25,424,041 in non-discretionary assets under
management.