A. Firm Description Novem Group is organized as a corporation in the state of New York. The date of its inception is August of 2011, and the principal owner is Robert J. Bartolotta.
B. Types of Advisory Services Novem Group offers the following services to its advisory clients: Investment Supervisory Services Includes ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Novem Group’s Investment Policy Statement within the client contract outlines the client’s current situation and allows the representative to construct a plan to aid in the selection of a portfolio to correspond with that client’s risk tolerance, time horizon, and investment objectives. Additional services include, but are not limited to, determining risk tolerance, developing investment strategies and asset allocations, and regular monitoring of accounts and portfolios.
The current investments of each client are evaluated with respect to the client’s risk tolerance, investment time horizon, and other information related to suitability. Discretionary authority may be requested from clients in order to select securities and execute transactions without permission from the client beforehand. Representatives use tools and programs to determine a client’s risk tolerance and to run investment proposals.
Financial Planning Financial planning may include, but is not limited to, investment planning, retirement planning, college planning, debt and credit planning, discussing tax concerns, and evaluating life insurance and assets outside of the management of the representative. The services and fee structures, if applicable, are outlined in Novem Group’s Advisory Services Agreement. Available fee structures include a flat fee (dollar amount or percentage of assets), an hourly rate, or a tiered fee schedule with a floating flat rate percentage based on an account/portfolio value.
Selection of Other Advisers Novem Group may direct clients to third party money managers. This relationship will be disclosed in the contract between Novem Group and the third party. Novem Group will be compensated via a fee share from the manager to which it directs clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other

advisers for clients, Novem Group will ensure the other adviser is properly licensed or registered.
Services Limited to Specific Types of Investments Novem Group limits its investment advice and money management to mutual funds, ETFs, equities, bonds, fixed income, debt securities, options, REITs, and insurance products including annuities. Novem Group may use other securities to help diversify a portfolio.
C. Client Tailored Services and Client Imposed Restrictions Novem Group offers the same services to all its clients; however, specific client financial plans and their implementation are dependent upon the client’s contract. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs; however, if the restrictions prevent Novem Group or its representatives from properly servicing the account, or if the restrictions require Novem Group to deviate from its standard services, Novem Group reserves the right to end the relationship.
D. Wrap Fee Program A wrap fee program is an investment program where the investor pays one stated fee that includes all management fees, transaction costs, fund expenses, and any other administrative fees. Novem Group sponsors a wrap fee program and offers both non-wrap and wrap portfolio management. The maximum total fee schedule is listed in Item 5.A. Clients who participate in the wrap fee program will not have to pay for transaction or trading fees of the custodian; however, clients are still responsible for all other fees. Compensation of Client Participation Other than advisory fees, Novem Group nor its representatives receive any additional compensation for the participant of clients in the wrap fee program. Compensation received may be more than what would have been received if the client paid separately for investment advice and other services; therefore, Novem Group and its representatives may have a financial incentive to recommend a wrap fee program. This relationship is reviewed periodically by the representative and the firm for suitability.
E. Assets Under Management As of 1/1/2024, Novem Group has the following assets under management: Total Discretionary Total Non-Discretionary Total Assets Under Management $915,834,436 $254,796,921 $1,170,631,357