A. NEXT is a Delaware limited liability company formed on December 18, 1998, which became registered as an Investment Adviser in March 1999. NEXT is ninety-nine percent owned by Next Capital Holdings, which is principally owned and controlled: by Andrew C. Hart, who is NEXT’s Managing Member, and the ACH Family Trust, which is a trust created for the benefit of Mr. Hart and his family. B. As discussed below, NEXT offers to clients (generally: individuals, high net worth individuals, trusts, pension and profit sharing plans, charitable organizations, and business entities, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage NEXT to provide discretionary and/or non- discretionary investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services on a fee-only basis as discussed at Item 5 below. Unless the client and NEXT agree to a fixed-fee arrangement or a different arrangement, NEXT’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under NEXT’s management. Before engaging NEXT to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with NEXT setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. NEXT provides investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, NEXT will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, NEXT provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may execute or recommend execution of account transactions as a result of those reviews. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent specifically requested by a client, NEXT may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, retirement planning, and cash flow analysis) on a stand-alone separate fee basis. Before engaging NEXT to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with NEXT setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before NEXT commences services. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested and engaged by a client to do so, NEXT may provide financial planning and related consulting services regarding non- investment related matters, such as estate planning, retirement planning and cash flow analysis per the terms and conditions of a separate agreement and a separate fee as discussed at Item 5 below, the fee for which shall be based upon the individual providing the service and the scope of the services to be provided. NEXT does not serve as an attorney, accountant, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance brokerage services. Accordingly, NEXT does not prepare estate planning or any other type of legal documents, tax returns or sell insurance products. Unless specifically agreed in writing, neither NEXT nor its representatives are responsible to: implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. To the extent requested by a client, NEXT may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who shall be solely responsible for the quality and competency of the services they provide. If the client engages any unaffiliated recommended professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not NEXT, shall be responsible for the quality and competency of the services provided. The client retains absolute discretion over all financial planning and consulting / implementation decisions and is free to accept or reject any recommendation made by NEXT or its representatives in that respect. Unaffiliated Private Investment Funds. NEXT may provide non-discretionary investment advice regarding unaffiliated private investment funds. NEXT, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. NEXT’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. Unless otherwise set forth in this Brochure, if a client determines to become a private fund investor, the amount of assets invested in the fund(s) will be included as part of “assets under management” for purposes of NEXT calculating its investment advisory fee. NEXT’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Private Investment Fund Risk Factors: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Private Investment Fund Valuation. If NEXT bills an investment advisory fee based upon the value of private investment funds or otherwise references private investment funds owned by the client on any supplemental account reports prepared by NEXT, the valuations of those private investment funds will reflect either the most recent valuation provided by the private fund sponsor, or an estimate of the valuation which is likely to be more accurate than the latest statement value available. In the case of estimates, valuations are based on estimated values provided by the private fund sponsor or the most recent statement value adjusted for client transactions such as capital calls and distributions. NEXT employs the use of estimates to mitigate the risk of over or underbilling client assets. NEXT reconciles its estimated values upon receipt of final private fund valuations and adjusts future bills accordingly. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. Interval Funds/Risks and Limitations: Where appropriate, NEXT may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct NEXT, in writing, not to employ any or all such strategies for the client’s account. Independent Managers/Sub-Advisers. NEXT may also allocate a portion of client assets among certain independent investment manager(s) and or sub-advisers who will manage the designated assets on a day-to- day discretionary basis (the “Independent Manager(s)”) consistent with the client’s investment objectives. NEXT will continue to provide investment advisory services to the client relative to the ongoing monitoring and review of the Independent Manager(s), account performance, asset allocation and client investment objectives. Factors which NEXT may consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Although not a material consideration for recommending asset allocation to a particular Independent Manager, NEXT may receive services, products and reimbursement from Independent Manager(s) relative to the Independent Manager evaluation process, such as: compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, and/or other products used by NEXT in furtherance of its investment advisory business operations. Certain Independent Manager(s) may impose individual account minimums. The fee charged by the Independent Manager(s) is separate from, and in addition to, NEXT’s investment advisory fee described at Item 5 below. ANY QUESTIONS: NEXT’s Chief Compliance Officer, Andrew Hart, remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). Business Relationship with Dynasty. NEXT maintains a business relationship with Dynasty Financial Partners, LLC (“Dynasty”). Please refer to Items 10.C. and 14 for a description of the services and the conflicts of interest presented. NEXT’s Chief Compliance Officer, Andrew C. Hart, remains available to address any questions that a client or prospective client may have regarding these relationships and the related conflicts of interest. Charles Schwab & Co., Inc. and Pershing As discussed below at Item 12, when requested to recommend a broker-dealer/custodian for client accounts, NEXT generally recommends that Charles Schwab & Co., Inc. (“Schwab”) or Pershing serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab and Pershing charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab and Pershing, do not currently charge fees on individual equity transactions, others do). When beneficial to the client, individual fixed‐ income and/or equity transactions may be effected through broker‐dealers with whom NEXT and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab and Pershing). These fees/charges are in addition to NEXT’s investment advisory fee at Item 5 below. NEXT does not receive any portion of these fees/charges. NEXT’s Chief Compliance Officer, Andrew C. Hart, remains available to address any questions that a client or prospective client may have regarding the above. Asset-Based Fees versus Transaction-Based Fees: Custodians such as Schwab are compensated for their services that include, but are not limited to execution, custody and reporting. Schwab can charge a fixed percentage fee for its services based upon the dollar amount of the assets placed in its custody and/or on their platform (for example: if Schwab was to charge an annual 0.10% of the market value of the client assets in its custody, the fee would include the execution of all account transactions). This is referred to as an “Asset-Based Fee”. In the alternative, rather than a fixed percentage fee based upon the market value of the assets in its custody, Schwab could charge a separate fee for the execution of each transaction. This is referred to as a “Transaction-Based Fee”. Under a Transaction Based Fee, the amount of total fees charged to the client account for trade execution will vary depending upon the number of transactions that are placed for the account. Most clients will be subject to the Transaction Based Fee. However, a small number of accounts will be subject to the Asset-Based Fee because of the amount of assets invested. NEXT, on an annual basis, will conduct a sampling to confirm its reasonable belief (given the inability to predict the markets and the corresponding amount of trading that will occur, as well as the frequency of client deposits and/or withdrawals which cause additional transactions) that Asset-Based pricing continues to be beneficial for those clients. Before engaging Schwab regardless of pricing (Asset-Based versus Transaction-Based), the client will be required to execute a separate agreement with Schwab agreeing to such pricing/fees. The fees charged by Schwab are separate and in addition to the advisory fee payable by the client to NEXT. The client can request at any time to switch from Asset-Based pricing to Transaction-Based pricing, however, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to Transaction-Based pricing could prove to be economically detrimental. Please Note: You are under no obligation to enter into an asset-based arrangement, and, if you do, you can request at any time to switch from asset based pricing to transactions based pricing, however, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to transaction based pricing could prove to be economically disadvantageous. NEXT’s Chief Compliance Officer, Andrew C. Hart, remains available to address any questions that a client or prospective client may have regarding Asset-Based versus Transaction- Based pricing. Retirement Rollovers - 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 NEXT recommends that a client roll over their retirement plan assets into an account to be managed by NEXT, such a recommendation creates a conflict of interest if NEXT will earn a new (or increase its current) advisory fee as a result of the rollover. If NEXT provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), NEXT is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to rollover retirement plan assets to an account managed by NEXT. NEXT’s Chief Compliance Officer, Andrew Hart remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such rollover recommendation. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types

of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, NEXT does not recommend such borrowing unless it is for specific purpose (i.e. a bridge loan to purchase a new residence). From time to time, NEXT may recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to NEXT:
• by taking the loan rather than liquidating assets in the client’s account, NEXT continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by NEXT, NEXT will receive an advisory fee on the invested amount; and,
• if NEXT’s advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), NEXT will earn a correspondingly higher advisory fee. This could provide NEXT with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loans. Portfolio Activity. NEXT has a fiduciary duty to provide services consistent with the client’s best interest. NEXT will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when NEXT determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by NEXT will be profitable or equal any specific performance level(s). Please Note: Cash Positions. NEXT continues to treat cash as an asset class. As such, unless determined to the contrary by NEXT, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating NEXT’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), NEXT may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, NEXT’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: NEXT’s Chief Compliance Officer, Andrew Hart, remains available to address any questions that a client or prospective may have regarding the above fee billing practice Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, NEXT shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless NEXT reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within NEXT’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of NEXT’s unmanaged accounts. ANY QUESTIONS: NEXT’ Chief Compliance Officer, Andrew Hart, remains available to address any questions that a client or prospective client may have regarding the above. ERISA Plan Engagements. NEXT may be engaged by Plan sponsors to provide discretionary and/or non-discretionary investment advisory services to ERISA retirement plans, whereby NEXT shall manage Plan assets in the amount and objective as designated by the Plan sponsor. In such engagements, NEXT will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) either as a 3(38) “investment manager” for discretionary engagements or as a 3(21) “fiduciary” for non-discretionary consulting engagements. In either engagement, NEXT will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and NEXT. Participant Directed Retirement Plans. NEXT may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between NEXT and the plan. For such engagements, NEXT shall assist the Plan sponsor to select an investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, shall provide corresponding education to assist the participants with their decision making process. Client Retirement Plan Assets. If requested to do so, NEXT shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, NEXT shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. NEXT’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. NEXT will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify NEXT of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Please Note - Use of Mutual Funds and Exchange Traded Funds. NEXT utilizes mutual funds and exchange traded funds for its client portfolios. In addition to NEXT’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, NEXT generally recommends that Schwab or Pershing serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab and Pershing charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark- ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab and Pershing, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab and/or Pershing will not change their transaction fee pricing in the future. Please Also Note: Schwab and Pershing may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Tradeaways: When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom NEXT and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab). The above fees/charges are in addition to NEXT’s investment advisory fee at Item 5 below. NEXT does not receive any portion of these fees/charges. ANY QUESTIONS: NEXT’s Chief Compliance Officer, Andrew C. Hart, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by NEXT), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. NEXT does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Private Placement Life Insurance. NEXT can be engaged by insurance companies as a sub-adviser to manage the investment assets within a private placement life insurance policy (“PPLI”). PPLI is acquired by the client with the assistance of the client’s insurance professional, for which the insurance professional generally receives commission compensation from the insurance company. NEXT does not receive any portion of the commission compensation earned by the insurance professional. NEXT’s only fee is its investment advisory fee. In the event that NEXT recommends that a client meet with an insurance professional to discuss the potential benefits of PPLI, a conflict of interest arises if NEXT is subsequently engaged by the insurance company as the sub-adviser for the PPLI investment assets. Structured Notes. NEXT may purchase Structured Notes for client accounts. A Structured Note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity constraints, such that the sale thereof before the maturity date could result in a substantial loss. There can be no assurance that the Structured Notes investment will be profitable, equal any historical performance level(s), or prove successful. Please Note: If the issuer of the Structured Note defaults, the entire value of the investment could be lost. See additional Risk Disclosure at Item 8 below Asset Aggregation / Reporting Services. NEXT may provide access to reporting services through one or more third-party aggregation / reporting platforms, i.e., ByAllAccounts, Addepar and Portfolio Center, that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged NEXT to manage (the “Excluded Assets”). NEXT’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because NEXT does not have trading authority for the Excluded Assets, the client (and/or another investment professional), and not NEXT, shall be exclusively responsible for directly managing, monitoring and implementing any recommendations for the Excluded Assets. Further, the client and/or their other advisors that maintain trading authority, and not NEXT, shall be exclusively responsible for the investment performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by NEXT. Accordingly, NEXT shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without NEXT’s participation or oversight. The client can engage NEXT to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between NEXT and the client. Non-Discretionary Service Limitations. Clients that determine to engage NEXT on a non- discretionary investment advisory basis must be willing to accept that NEXT cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, if NEXT would like to make a transaction for a client’s account (including removing a security that NEXT no longer believes is appropriate, adding a security that NEXT believes is appropriate, or in the event of a correction), and the client is unavailable, NEXT will be unable to execute the account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. This may place affected clients at an economic disadvantage. Use of Pontera Platform: NEXT may use an investment platform made available by Pontera Solutions, Inc. (“Pontera”), a third-party online platform, to assist with management of clients’ “held-away” accounts, including 401(k)s, 403(b)s, annuities, and 529 education savings plans. The Pontera platform permits advisers to manage held-away assets without having to reflect that it has custody of such assets on Part 1 of Form ADV. The advisory fee charged by NEXT for the management of held-away assets is established in the client’s Investment Advisory Agreement. Pontera charges NEXT an annual fee based upon the percentage of assets managed in the held- away accounts. Other than NEXT’s advisory fee, clients do not pay any additional fee to Pontera or to NEXT in connection with the use of Pontera platform. Cybersecurity Risk. The information technology systems and networks that NEXT and its third-party service providers use to provide services to NEXT’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in NEXT’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and NEXT are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although NEXT has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that NEXT does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker- dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Client Obligations. In performing its services, NEXT 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 their responsibility to promptly notify NEXT if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising NEXT’s previous recommendations and/or services. Disclosure Brochure. A copy of NEXT’s written Privacy Notice, Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of the applicable form of agreement between NEXT and the client. C. NEXT provides investment advisory services tailored specifically to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, NEXT shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on NEXT’s services. D. NEXT does not participate in a wrap fee program. E. As of December 31, 2023, NEXT had $1,062,987,914 in assets under management on a discretionary basis and $380,214,699 in assets under management on a non-discretionary basis.