Originally founded in 1987, NEFG has been in business as an independent registered investment adviser since July 1998. From the onset, NEFG has maintained its commitment to providing comprehensive planning and investment services to the firm’s clients, which NEFG believes has led to the firm’s continued growth throughout complex times in the financial markets. It is NEFG’s focus to provide its clients with a wide array of investment options and unvarying support in an effort to enable them to meet their individual planning objectives. Josh R. Laychock is the principal owner of NEFG. As of December 31, 2023, the firm had $1,000,469,143 in assets under management, of which $538,515,684 was managed on a discretionary basis and $461,953,459 was managed on a non- discretionary basis. Prior to engaging NEFG to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with NEFG setting forth the terms and conditions under which NEFG renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of NEFG. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of NEFG’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on NEFG’s behalf and is subject to NEFG’s supervision or control. Financial Planning and Consulting Services NEFG offers clients a broad range of comprehensive financial planning and consulting services, addressing a variety of matters. These services, which are offered on both a standalone and ongoing basis, may address any or all of the following:
• Financial plan maintenance • Education funding;
• Estate planning; • Estate planning;
• Cash flow analysis; • Risk management;
• Business planning; • Long-term care assessment; and
• Retirement planning • Disability and survivorship planning. In performing its services, NEFG is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. NEFG recommends the services of itself, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if NEFG recommends its own services or those offered by its Supervised Persons. The client is under no obligation to act upon any of the recommendations made by NEFG under a financial planning or consulting engagement or to engage the services of any such recommended professional, including NEFG itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of NEFG’s recommendations. Clients are advised that it remains their responsibility to promptly notify NEFG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising NEFG’s previous recommendations and/or services. Investment Management Services NEFG manages clients’ investment portfolios on a discretionary or non-discretionary basis. NEFG primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and/or Independent Managers (as defined below), as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. NEFG also provides advice about any type of legacy position or investment otherwise held in its clients' portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. NEFG also renders non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, NEFG either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Additionally, where appropriate, NEFG recommend that certain accredited investors, as defined in Rule 501 under Regulation D under the Securities Act of 1933, invest in certain private placements, which may include equity, debt and/or pooled investment vehicles. NEFG consults with its clients to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. NEFG ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify NEFG if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon NEFG’s management services. Clients can impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in NEFG’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As mentioned above, NEFG recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between NEFG and/or the client and the designated Independent Managers. NEFG renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. NEFG also monitors and reviews the account performance and the client’s investment objectives. NEFG receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. NEFG’s annual advisory fee, combined with any fee charged by the Independent Managers, will never exceed three percent. When recommending or selecting an Independent Manager for a client, NEFG reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that NEFG considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, NEFG’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by NEFG, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to NEFG’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than NEFG. In such instances, NEFG may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Management of Pooled Investment Vehicles Robert L. Hackenberg serves as the managing member to affiliated private investment funds, H&L Capital Group, LLC, H&L Capital II, LLC. In addition, Chief Compliance Officer, Robert L. Hackenberg and Principal, Josh R. Laychock serve as the managing members of NEFG Capital Partners LLC, the managing member to two additional affiliated private investment funds, Capital Partners Alternative Income & Growth Fund, LLC and Capital Partners Lending Fund, LLC (collectively with H&L Capital Group, LLC and H&L Capital II, LLC, “the Funds”). Interests in the Funds are privately offered. The Funds currently rely on an exemption from registration under the Investment Company Act of 1940, as amended. Participation as an investor in the Funds is restricted to investors that are qualified clients pursuant to the requirements under Rule 205-3 under the Advisers Act, as well as “accredited investors” as defined under Rule 501(a) of the Securities Act of 1933, as amended and “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended. The Funds are real estate, debt and private lending focused pooled investment vehicles. To the extent certain of NEFG’s individual advisory clients qualify, they will be eligible to participate as members of the Funds. Investment in the Funds involves a significant degree of risk. All relevant information, terms and conditions relative to the Funds, including the compensation and fees received by NEFG or its affiliate as managing member (including any performance-based compensation), suitability, risk factors, and potential conflicts of interest, are set forth in the Confidential Private Offering Memorandum

(the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and/or Subscription Agreement of each Fund (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Funds. While the Funds are generally considered to be a client of NEFG, “client(s)” may also refer to the investors in the Funds. NEFG will devote its best efforts with respect to its management of both the Funds and the individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Funds, NEFG may give advice or take action with respect to the Funds that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Funds and certain individual client accounts, such investments will be allocated between the Funds and the individual client accounts in a manner which NEFG determines is fair and equitable under the circumstances to all of its clients. A conflict of interest exists since we have a financial incentive to recommend the Funds to clients. However, as a fiduciary, we are obligated to act in our clients’ best interests and, therefore, we only recommend the Funds when we determine the investment is suitable for the client. 1031 Tax-Free Real Estate Exchange Services NEFG provides services in the review and selection of properties and programs to complete 1031 tax-free real estate exchanges. The firm will recommend Qualified Intermediaries, or work with the buyers Qualified Intermediary to assist in the complete transaction. Services include research and recommendations of primary and or secondary backup properties or programs to satisfy the requirements of identifying and completing the transactions within the required time limits. Pension Consulting Services NEFG provides comprehensive consulting services to pension plans. In general, NEFG assists the engaging client in designing and implementing a plan. The plan design lists the criteria for the selection of investment vehicles and the procedures and timing intervals for monitoring investment performance. NEFG also reviews and recommends various investment options, primarily consisting of mutual funds and ETFs, in an effort to implement an investment platform designed to further the client’s stated objectives. As part of these services, the firm may provide pension plan participants with educational support services and investment workshops, addressing general financial and plan related matters. NEFG also offers individual enrollment meetings, whereby the firm provides employees with individualized assistance on asset allocations within their respective retirement accounts. These services are rendered pursuant to specialized engagements which are customized to accommodate the needs and objectives of the engaging party. Retirement Plan Services NEFG provides comprehensive services to retirement plans, including retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), “ERISA Plans.” ERISA Plan Clients: NEFG provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients that are participant-directed plans. ERISA Fiduciary Services: NEFG provides ERISA fiduciary services either as a discretionary investment manager or a non-discretionary investment adviser to ERISA Plan Clients. Investment Management Services: NEFG provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA § 3(38) and in that capacity, NEFG’s investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. Each ERISA Plan Client who engages NEFG to perform investment management services is required to enter into an investment management agreement. NEFG’s investment management services include developing and implementing an investment policy statement, selecting a broad range of investment options consistent with ERISA § 404(c), making decisions about the selection, retention, removal and/or replacement of investment options and if the ERISA Plan Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment that will serve as a QDIA. Investment Advisory Services: NEFG also provides investment advisory services on a non-discretionary basis and in that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of NEFG’s recommendations or advice. Each ERISA Plan Client who engages NEFG to perform non-discretionary investment advisory services is required to enter into an investment advisory agreement. NEFG’s non-discretionary investment advisory services include assisting the ERISA Plan Client in developing and implementing an investment policy statement, assisting the ERISA Plan Client in selecting a broad range of investment options consistent with ERISA § 404(c), assisting the ERISA Plan Client in making decisions about the selection, retention, removal and/or replacement of investment options, and if the ERISA Client has determined that the Plan should have a QDIA for participants who fail to make an investment election, assisting in the selection of the investment that will serve as a QDIA. Participant-Level Services: NEFG may also provide non-discretionary investment advice to Plan participants about the Plan investment options. The Plan participant has the final decision-making authority regarding the initial selection, retention and changes in investment selections. Non-Fiduciary Services: NEFG’s non-fiduciary services to ERISA Plan Clients include assisting in group enrollment meetings, educating plan participants about general investment principles and the plan’s investment options and educating the ERISA Plan Client as to its fiduciary responsibilities. NEFG’s non- fiduciary services also include assisting the ERISA Plan Client in monitoring, selecting and supervising plan service vendors and performing benchmarking studies. Non-ERISA Plan Clients: NEFG also provides discretionary investment management services and non- discretionary investment advisory services to retirement plans not covered under ERISA (“non-ERISA Plan Clients”). NEFG provides investment management services to non-ERISA Plan Clients on a discretionary basis and in that capacity, NEFG’s investment decisions are made in its sole discretion without the client’s prior approval. Each client who engages NEFG to perform investment management services is required to enter into an investment management agreement. NEFG’s investment management services include developing and implementing an investment policy statement, and making decisions about the selection, retention, removal and/or replacement of investment options. NEFG also provides investment advisory services on a non-discretionary basis and in that capacity, the non-ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of NEFG’s recommendations or advice. Each client who engages NEFG to perform non-discretionary investment advisory services is required to enter into an investment advisory agreement. NEFG’s non-discretionary investment advisory services include assisting the client in developing and implementing an investment policy statement and assisting the client in making decisions about the selection, retention, removal and/or replacement of investment options. In addition, NEFG assists non-ERISA Plan Clients with group enrollment meetings and educating plan participants about general investment principles and the plan’s investment options. NEFG also assists the client in monitoring, selecting and supervising plan service vendors and performing benchmarking studies. For a more detailed description of NEFG’s services, the retirement plan client should refer to the investment advisory agreement or investment management agreement, as the case may be. Rollover Recommendations A conflict of interest arises when NEFG makes recommendations about retirement plan distributions and rollovers to IRAs, IRA to IRA transfers, IRA to plan rollovers, plan to plan rollovers and change of account types for a retirement plan or IRA (each, a “rollover recommendation”) if it results in NEFG receiving compensation that it would not have received absent the recommendation, for example, fees for advising or managing a rollover IRA. NEFG will manage this conflict through a process designed to develop an informed recommendation in the best interest of the client. No client is under an obligation to roll over retirement plan or IRA assets to an account advised or managed by NEFG. When NEFG makes a rollover recommendation, it is fiduciary advice under the Investment Advisers Act of 1940 (the “Advisers Act”). Also, when NEFG provides investment advice to a plan participant about his/her retirement plan account or to an IRA owner about his/her IRA, including a rollover recommendation, NEFG is a fiduciary within the meaning of ERISA and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. In addition to being a conflict of interest, it is also a prohibited transaction under ERISA and/or the Code when NEFG receives compensation as a result of the rollover that it would not have received absent the recommendation. In that circumstance, NEFG will comply with the conditions of exceptions to the prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as PTE 2020-02 or non-enforcement policy).