NFP Retirement is federally registered as an investment adviser and also does business as (“dba”) 401(k) Advisers, 403(b) Advisors, Fiduciary First, and SST Benefits and Consulting Services LLC (collectively referred to in the Brochure as “Adviser” or “NFPR” or “we”). NFPR is owned by NFP Corp. From time to time, we may recommend that you purchase or sell products and services from or through NFP Affiliates and these NFP Affiliates and our firm may receive compensation as a result of such recommendations. A recommendation that you purchase or sell products or services by or through an NFP Affiliate creates a conflict of interest if there is increased compensation to an NFP Affiliate or our firm. NFPR provides comprehensive qualified and non-qualified retirement plan consulting, investment advice and fiduciary due diligence services, employee plan and investment education, asset allocation services, plan service provider proposal and provider research and analysis, and plan design guidance to individuals, qualified and non-qualified retirement plan sponsors and business entities. The Adviser provides clients both Investment Advice (non-discretionary) and/or Investment Management (discretionary) investment advisory services, based on the scope of the engagement for these clients. The Adviser also provides asset management and investment and financial consulting services for individuals to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Investment Advice (Plan Level) The Adviser shall provide research and analysis regarding investment advice and fiduciary due diligence services for the client. The Adviser shall also provide research and analysis that covers the investment products of several qualified and non-qualified retirement plan providers. The goal of the investment due diligence process is to establish a logical, technical, and comprehensive process that is consistently employed in the selection and ongoing monitoring of funds for plan sponsors and individuals, accompanied by an investment policy statement (for plan sponsors only), that defines the process utilized to recommend the investments to plan sponsors and individuals. The employer (and client of the Adviser) sponsors a retirement plan for the benefit of its employees. The plan is a qualified or non-qualified employee benefit plan intended to comply with all applicable federal laws and regulations, including the Internal Revenue Code of 1986, as amended (“IRC”), and the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, if applicable. In addition, applicable plans are intended to comply with ERISA Section 404(c). The Adviser may employ many different calculations, processes, and screening techniques to arrive at specific recommended individual investments within the array of investments offered by each investment provider that is being analyzed including but not limited to the following:
• Investment analysis by asset class (domestic equity, international equity, income, hybrid/managed accounts), including market capitalization (small, medium, and large), and investment objective (value, blend, and growth orientation);
• Performance relative to other investments in the same asset class;
• Investment performance relative to benchmark performance for the same asset class;
• Percentile ranking of investment performance for the same asset class;
• Style-based analysis to determine the impact of an investment being managed differently than its stated investment objective (which is usually a combination of the stated market capitalization category, and investment objective category); 5 | P a g e
• Macro screens to eliminate long term under-performing investments, funds with total managed assets of less than the minimum threshold deemed to be adequate by the Adviser;
• Review of upside and downside capture, to estimate upside potential and downside risk of each investment;
• Common objective risk and return statistical measurements, such as Sharpe ratio, standard deviation, alpha, and beta;
• Common statistically relevant manager value measurements such as information ratio and tracking error;
• R-squared, correlation coefficients, and other statistically relevant information;
• Excess return over the given performance benchmark;
• Short and long term historical analysis with any of the above measurements;
• Financial strength, stability, and reputation of the investment provider, and individual investments offered by and through the investment provider;
• Tenure and experience of investment management personnel;
• Investment philosophy, process, and style; and
• Investment fees. The Adviser shall provide a draft of the Investment Policy Statement for client review. In addition, the Adviser will evaluate client’s existing Investment Policy Statement and provide recommendations that are consistent with assisting the client meet their fiduciary obligations, if applicable, under ERISA Section 404(c). Investment Management (Plan Level): The Adviser shall be responsible, and maintains discretion, for the selection, mapping, and ongoing monitoring, of investments offered within the plan. The Adviser hereby accepts co-fiduciary responsibility for such duties. The client engages the Adviser for management of plan assets and shall delegate specified authority and discretion to the Adviser for the selection, mapping, and ongoing monitoring (including replacement, as prudent), of investments offered within the plan. However, services provided by the Adviser under this Agreement will not include any services with respect to employer securities or company stock nor is the Adviser a fiduciary in regards to any single security offering or SDBA (self-directed brokerage account) available in a plan. The Adviser shall be responsible and possess discretion for the selection of investment options used to populate the asset allocation models. The Adviser shall also provide documentation supporting the investment due diligence in a regularly prepared Fiduciary Investment Review report. The Adviser will have an established investment due diligence process that is a logical, technical, and comprehensive process that is consistently employed in the selection, de-selection, and ongoing monitoring of funds for plan sponsors and individuals, accompanied by an investment policy statement, that defines the process utilized to guide decision making in the management of the plan investments offered to plan sponsors and individuals. The client sponsors a qualified retirement plan for the benefit of its employees. The plan is a qualified employee benefit plan intended to comply with all applicable federal laws and regulations, including the IRC and ERISA. In addition, the plan is intended to comply with ERISA Section 404(c) and all regulations promulgated there under. The client intends to engage their best efforts to comply with all requirements of ERISA Section 404(c) and the regulations there under. The Adviser may employ many different calculations, processes, and screening techniques, to arrive at specific recommended individual investments within the array of investments offered by each investment provider that is being analyzed. 6 | P a g e The Adviser shall provide the client with the Investment Policy Statement for client’s review and inform the client when, and if, there are any changes thereto. In addition, the Adviser will provide its services with the objective of meeting the Adviser’s and client’s fiduciary obligations under ERISA Section 404(a) and with the intent of meeting the requirements of ERISA Section 404(c). Employee Plan and Investment Education The Adviser may provide group employee enrollment, re-enrollment, and investment education support. The goal of this process is to help employees make educated and informed choices about the plan and investment allocation under the investment education guidelines set forth by the U.S. Department of Labor. Meetings are offered on a(n) annual, semi-annual, quarterly, or as requested basis. The scope of the meetings will be group and/or individual, and will be conducted on-site and/or as data conferencing. Employee (Participant) Investment Advice and/or Asset Allocation Models The Adviser shall create, monitor, adjust (when prudent), and rebalance asset allocation models (“Models”) for plan sponsor use as an investment tool provided to participants for use in assisting plan Participants in making asset allocation decisions for their investment portfolios (i.e. equity and fixed income). Whether the Models are used as stand-alone tools or used in conjunction with the delivery of investment advice, they are designed to have different investment objectives based on risk level. To meet these varying investment needs, participants and beneficiaries will be able to elect to direct their account balances among a range of investment options to construct diversified portfolios that reasonably span the risk/return spectrum. The goal of the investment advice process is to assist plan participants in finding the asset mix which is most likely to meet their investment objectives within acceptable risk parameters. Asset class sub- types can include domestic large cap value equity, domestic large cap growth equity, domestic mid-cap value equity, domestic mid-cap growth equity, domestic small cap value equity, domestic small cap growth equity, international equity, core fixed income, short term fixed income, high yield fixed income, and other appropriate asset classes and investments. The Adviser shall direct the rebalancing of asset allocation Models on a periodic basis. Participants and beneficiaries alone bear the risk of investment results from the options and asset allocation that they select. Plan Service Provider Proposal Research and Analysis The Adviser may assist clients with the selection of a plan provider or providers for their plan, based on detailed research and analysis of several providers. The provider review process includes an evaluation of administrative, recordkeeping, compliance, and employee communications services, administrative and investment-related fees, and an investment overview that incorporates a very similar analysis to the investment due diligence process described above. Newsletter Campaign Periodic employer newsletters includes industry and marketplace updates, plan design and compliance suggestions, and legislative updates. Market Review The Adviser prepares quarterly market

reviews to help inform and educate the client on the performance and events surrounding the capital markets. 7 | P a g e Plan Design Guidance The Adviser provides in-depth plan reviews that include an analysis of relevant design features, including: age and length of service eligibility requirements; vesting; forfeitures; employer matching contributions formulas; entry and re-entry dates; and other pertinent design features. Management of Conversion Process Adviser will assist client with conversions between investment providers, including (i) interfacing with company consultants and relationship managers to facilitate the conversion, (ii) providing sample letters and correspondence related to the plan conversion, and (iii) monitoring the action items identified in the NFP Retirement Conversion Checklist. Fiduciary Plan Review The Fiduciary Plan Review™ includes a compliance checklist, plan design analysis, and other related analysis designed to address plan compliance and efficiency. This document typically exceeds 20 pages in length and may also include a list of action items and suggestions, based on plan demographics and a discussion by the client’s plan fiduciaries and NFPR. General Plan Consulting Services NFPR will assign a Plan Adviser (an Investment Adviser Representatives (“IARs”)), who is responsible for responding to ongoing questions, concerns, and issues raised by the Adviser that are related to client's qualified or non-qualified retirement plan. Services include plan pricing and contract negotiation by the incumbent provider and client, recommendations of specific service and product enhancements, facilitation for the solution of service, administrative, and recordkeeping issues, plan compliance assistance and guidance, and ongoing problem solving. NFPR may provide a "help email" address, and "1-800" phone consultation assistance for participants. 404(c) Audit NFPR will provide a comprehensive checklist of the latest industry accepted standards with respect to 404(c) compliance, and will work with client to facilitate completion of the checklist. The responsible party for addressing and verifying each item will either be; the plan provider, the Customer, or in some instances NFPR will provide the research and analysis. Fiduciary Role under ERISA For those services stated under Investment Advice (Plan Level) the Adviser acknowledges that it is a fiduciary with respect to the plan under Section 3(21)(A)(ii) of ERISA and, as such, is a co-fiduciary with the trustees(s) of the client’s plan solely with respect to (a) the provision of investment education of the employer and/or plan participants (depending on the specific Advisory services provided); (b) the periodic reporting on, and analysis of, the investment options available under the plan; and (c) the provision of advice to the trustee(s) regarding the elimination or addition of investment options available under the plan; provided, however, that the trustee(s) acknowledge and agree that the trustee(s) have the final and conclusive responsibility for the investment options selected to be available under the plan. For those services stated under Investment Management (plan Level), the Adviser acknowledges that it is a co-fiduciary with respect to the plan under Section 3(38) of ERISA. The co-fiduciary duties of the Adviser are limited to the selection, mapping, monitoring, and replacement of plan investment options for which they have explicit authorized discretionary control. 8 | P a g e The Adviser will not be responsible for investment decisions made by individual plan participants with respect to the investment of their accounts and/or investment into a model portfolio managed by Adviser, if applicable. The Adviser is not responsible for any fiduciary duties or responsibilities imposed on the plan’s fiduciaries under ERISA not explicitly contemplated in the services stated under the Investment Management (plan Level) section. The Adviser will not be responsible for investment decisions made by the plan participants with respect to the investment of their accounts. For those services stated under Employee (Participant) Investment Advice and/or Asset Allocation Models, the Adviser acknowledges that it is a limited scope fiduciary with respect to the plan under Section 3(38) of ERISA. The Adviser is a fiduciary to the plan under Section 3(38) of ERISA for only those services under this Agreement for which they have explicit authorized discretion over plan assets. The Adviser is authorized by the client to exercise its best judgment in investing, selling and reinvesting cash and securities of Participants and Beneficiaries who have elected to use the Models, but only to the extent such actions relate to determining allocation based on the Models, adjustments thereof, or rebalancing of the Models. The client does not authorize, nor does the Adviser accept, any discretionary authority outside the scope of this paragraph. Portfolio Management Some IARs of the Adviser perform investment management services for portfolios of their clients. The nature of the portfolios is limited primarily to mutual funds and ETFs but may have some individual securities as well. Additionally, some IARs utilize an automated advisory service which maintains model asset allocations by automatically generating trades. This automated service is through Schwab who also maintains custody of these assets. The IARs manage the portfolios on a discretionary basis and on a case by case basis may undertake a non-discretionary account. The IARs are responsible for the maintenance and rebalancing of the portfolio accounts in addition to communicating with the clients on the performance of their portfolio. The portfolio management accounts are custodied with third parties, primarily, with Charles Schwab and Fidelity as custodians, and the Adviser does not maintain custody of client funds or securities in the provision of this service other than as noted in Item 15 - Custody. Investment and Financial Consulting Some Investment Adviser Representatives of the Adviser perform investment and financial consulting to individuals. The service provides general guidance based upon an evaluation of client’s goals and objectives furnished to Adviser as contemplated herein. Adviser shall make recommendations to purchase or sell securities consistent with those goals and objectives. These services may be purchased separately from other services provided by the Adviser and there is no obligation to purchase other services from the Adviser. Product and Services Conflict of Interest NFPR provides services that may recommend the purchase of services and/or products that are also offered by NFP Corp. and its affiliates. There is an inherent conflict of interest when a product or service recommends use of other products or services offered by NFP Corp. and its affiliates. The Adviser or its associated persons may receive compensation for these products and services. The Adviser does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of the Adviser or use the services and/or products of the Adviser in particular. WRAP Programs 9 | P a g e The Adviser does not sponsor a WRAP program nor does the Adviser act as an investment adviser or provide investment advice to a WRAP program. Tailored Relationships The goals and objectives for each client are documented in Investment Policy Statements that are created to reflect the stated goals and objectives of the client. Clients may impose restrictions on investing in certain securities or investment products (as necessary). They may also provide specific discretion for investing in certain securities that may not be consistent with the Investment Policy Statements. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of ERISA and/or the IRC, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Termination of Agreement Agreement may be terminated by either party upon providing written notification to the other party. Adviser will not accept any termination instructions, including account liquidation instructions, unless provided in writing by client. In the event of termination of this agreement, Adviser shall have no obligation whatsoever to recommend any action with respect to the assets in client’s account. Adviser shall be paid its fees in connection with its services provided hereunder for the period to such termination. Clients who wish to terminate this Agreement must notify the Adviser in writing within five (5) business days of its date of initial execution (shown below). If services are terminated within (5) business days from the date of executing this Agreement (shown below), services will be terminated without penalty. After the initial (5) business days, the client may be responsible for payment of fees for the number of days services are provided by the Adviser prior to receipt of the notice of termination. 10 | P a g e Investment Advice Assets As of December 31, 2023, the Adviser advises on a total of $76,949,665,936 on a non-discretionary basis and $19,504,829,491 on a discretionary basis.