A. The Company On April 26, 2019, New England Financial Planning Group, LLC d/b/a NEFPG, a Massachusetts limited liability company (“NEFPG” or the “firm”), succeeded to the business of Richard J. Wojcik d/b/a/ New England Financial Planning Group, a sole proprietorship. NEFPG (through the registration of its predecessor entity, New England Financial Planning Group) has been registered with the U.S. Securities and Exchange Commission since 1982. The principal owner of NEFPG is Richard Wojcik. B. Advisory Services NEFPG offers the following services to advisory clients: Asset Management Services NEFPG provides asset management services, defined as giving continuous advice or making investments for clients based on the specific needs of each client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, NEFPG develops a client’s individual investment policy and creates and manages a portfolio based on that policy. NEFPG will manage advisory accounts on either a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). NEFPG will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Clients will retain individual ownership of all securities. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. NEFPG provides asset management services for assets held at Raymond James & Associates, Inc. (“RJA”), a broker/dealer, member of the New York Stock Exchange, member SIPC and the sponsor for the following programs: Investment Management Program for Advisory Clients (IMPAC) The Investment Management Program for Advisory Clients (“IMPAC”) is a fee-based account, offered and administered through RJA, in which NEFPG provides you with ongoing investment advice and monitoring of securities holdings. NEFPG will manage your account on a discretionary or non-discretionary basis according to your investment objectives. This account offers you the ability to pay an asset-based advisory fee and a nominal transaction fee in lieu of a commission for each transaction. RJA receives a portion of the advisory fee. The Freedom Account The FREEDOM Account is an investment advisory account which allocates client assets, through discretionary mutual fund or exchange traded fund (“ETF”) management, based upon their financial objectives and risk tolerances. You appoint RJA as your investment adviser to select the representative funds and monitor their performance on a continuing basis. NEFPG receives a portion of the fee for services provided under the agreement. An RJA Investment Committee selects the representative funds and monitors their performance on a continuing basis. The Investment Committee’s decisions will be driven by Asset Management Services (“AMS”) Manager Research and Due Diligence, and the mutual fund strategies may include “Highly Recommended” funds from the Raymond James Mutual Fund Research (“MFR”) coverage list. However, the Investment Committee is under no obligation to select funds exclusively from MFR’s “Highly Recommended” list. For funds selected by the Investment Committee that are not covered by MFR, it is likely that MFR will at some point in the future assume research coverage of the fund(s) and that such fund(s) may be rated “Highly Recommended” by MFR. AMS Manager Research and Due Diligence continually monitors the funds in the FREEDOM Account. If a fund is downgraded by MFR, the Investment Committee will convene and determine the appropriate course of action, which may include replacing the downgraded fund in all FREEDOM Accounts, if necessary. For further information refer to the RJA Wrap Fee Program Brochure. The EAGLE Account Clients participating in the EAGLE account program appoint Eagle Asset Management (“Eagle”) as their investment adviser. Eagle is a wholly owned subsidiary of Raymond James Investment Management, a wholly owned subsidiary of Raymond James Financial, Inc. (“RJF”) and an affiliate of Raymond James. Clients may select one or more investment objectives. Eagle will manage clients’ accounts in accordance with their financial needs and investment objectives on a discretionary basis. NEFPG’s services include assisting clients in choosing the appropriate Eagle objective, monitoring performance, communication reports, and other administrative services. NEFPG receives a portion of the fee. For further information please refer to the RJA Wrap Fee Program Brochure. Raymond James Consulting Services (RJCS) Program Clients participating in the RJCS account program appoint RJA, as adviser, to select certain portfolio managers, monitor performance of the client’s accounts, provide clients with accounting and other administrative services, and assist portfolio managers with certain trading activities. Based upon a client’s financial needs and investment objectives, NEFPG may assist clients in selecting an appropriate manager(s). NEFPG receives a portion of the fee. For further

information please refer to the RJA Wrap Fee Program Brochure. Investment Advisory Consulting Services NEFPG may also provide Investment Advisory Consulting Services for certain clients with assets not held at Raymond James Financial Services, Inc., a member FINRA/SIPC. NEFPG will review the fund options that are available in the outside account and make recommendations based on the client’s investment profile and portfolio. 3 Financial Planning Services Financial planning is primarily an analytical process designed to organize financial data, identify needs and opportunities and evaluate alternative courses of action; it may include analysis of current net worth, income taxes, cash flow and budgeting, investments and asset allocation, retirement planning, employee benefit plan analysis, estate and gift tax planning, education pre-funding and risk management focusing on life, health and disability coverage. In general, NEFPG gathers required information through personal interviews. NEFPG will typically meet with the client to conduct an evaluation of the client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are reviewed. NEFPG conducts a financial analysis and prepares a written plan that describes the client’s current situation, identifies needs and opportunities and makes suggestions designed to help the client achieve stated goals. Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client's existing portfolio, recommendations concerning which assets should be held or liquidated, recommendations concerning appropriate allocation of assets among different investment categories. NEFPG also provides specific consultation and administrative services regarding investment and financial concerns of the client. NEFPG will also provide ongoing financial planning services for updates to existing financial plans. While financial analyses may include investment advice concerning mutual funds and securities, it may also include investment advice with respect to products that may or may not constitute “securities,” such as life insurance and annuities. It also takes into consideration estate tax planning issues that may not constitute “investment” advice. NEFPG may recommend its own services, the services of its own investment adviser representatives in their individual capacities as registered representatives of a broker- dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if NEFPG recommends its own services or that of its own investment adviser representatives. The client is under no obligation to act upon any of the recommendations made by NEFPG under a financial planning engagement and/or engage the services of any such recommended professional, including NEFPG or any of its related persons. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of NEFPG’s recommendations. In performing its services, NEFPG 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 on such information. If requested by the client, NEFPG may suggest the services of other professionals for implementation services, but the client is under no obligation to engage the services of any suggested professional. In addition, each client is advised that it remains their responsibility to promptly notify NEFPG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising NEFPG’s previous recommendations and/or services. C. Client Tailored Services and Client Imposed Restrictions NEFPG’s investment management services are tailored to meet the specific needs of each client. In order to provide appropriately individualized services, NEFPG will work with the client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing certain types of accounts. In addition, a restriction request may not be honored if it is fundamentally inconsistent with NEFPG’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent NEFPG from properly servicing client accounts. D. Wrap Fee Programs Please see the RJA Wrap Fee Program Brochure for additional information on the wrap fee programs in which NEFPG participates. E. Assets Under Management As of December 31, 2022, NEFPG has the following assets under management: Total Assets Under Management Discretionary Assets Non-Discretionary Assets $202,452,000 $109,447,000 $93,005,000.00