NEW ENGLAND PRIVATE WEALTH ADVISORS, LLC

Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 1. Cover Page New England Private Wealth Advisors, LLC Annual Disclosure Brochure Form ADV Part 2A Dated: September 3, 2025 This brochure provides information about the qualifications and business practices of New England Private . If you have any questions about the contents of this brochure, please contact us at: (781) 416-1707. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. not imply a certain level of skill or training. www.adviserinfo.sec.gov. You . You can www.nepwealth.com 36 Washington Street, Suite 280 | Wellesley, MA 02481 | Phone: (781) 416-1700 | Fax: (781) 416-1718 1  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 2. MATERIAL CHANGES This Item of the Brochure will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. This is an other than annual updating amendment reflecting the following changes: Item 5 has been updated to disclose our new advisory fee. The last update to our Brochure reflected the following: NEPWA was acquired by Aspen Standard Group, LLC leadership team continue to work at NEPWA following the transaction, and in connection with the transaction acquired minority ownership interests in Aspen. In addition, the professionals ts are not changing as a result of the transaction, so clients will not experience any interruption in the services NEPWA provides. As such, Item 4, Advisory Business of this Brochure was updated to reflect that Aspen, is now the principal owner of NEPWA as of March 2025. Currently, our Brochure may be requested by contacting Melissa Boccaci, Chief Compliance Officer of NEPWA at (781) 416-1707 or by emailing melissa.boccaci@nepwealth.com. 2  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 3. TABLE OF CONTENTS ITEM 1. COVER PAGE .......................................................................................................................................................... 1 ITEM 2. MATERIAL CHANGES ............................................................................................................................................ 2 ITEM 3. TABLE OF CONTENTS ........................................................................................................................................... 3 ITEM 4. ADVISORY BUSINESS ........................................................................................................................................... 4 ITEM 5. FEES AND COMPENSATION ................................................................................................................................. 4 ITEM 6. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................ 9 ITEM 7. TYPES OF CLIENTS ............................................................................................................................................... 8 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................................. 8 ITEM 9. DISCIPLINARY INFORMATION ............................................................................................................................ 11 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................................. 11 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..11 ITEM 12. BROKERAGE PRACTICES ................................................................................................................................ 11 ITEM 13. REVIEW OF ACCOUNTS .................................................................................................................................... 13 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................... 14 ITEM 15. CUSTODY ............................................................................................................................................................ 14 ITEM 16. INVESTMENT DISCRETION ............................................................................................................................... 14 ITEM 17. VOTING CLIENT SECURITIES ........................................................................................................................... 15 ITEM 18. FINANCIAL INFORMATION ................................................................................................................................ 15 3  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 4. ADVISORY BUSINESS Firm Overview acquired by Aspen Standard Group, LLC in March 2025. As such, NEPWA is now wholly owned by Aspen Standard Group, LLC. Aspen is not a registered investment adviser and does not provide investment advice; rather, Aspen is a holding company that owns registered investment advisers. Additional information on NEPWA ownership is available within our Form ADV Part 1. NEPWA offers continuous investment advisory and wealth management services on a fee-only basis for individuals, high-net worth individuals, trusts, estates, charitable/non-profit organizations and endowments, corporations and/or business entities, corporate pension, and profit-sharing plans, etc. Services involve asset allocation planning and suggesting and/or implementing investments in cash products, government bonds, mutual funds, exchange traded funds (ETFs), separately managed accounts, and on a limited basis and for certain clients, private real estate and other alternative investments. investment portfolio, NEPWA will consult with clients on various financial planning topics (as discussed below in more detail). . NEPWA is a fee-only NEPWA provides objective investment advice and investment advisory and wealth planning firm. The firm does not sell annuities, insurance products, mutual funds, or any other commissioned product and we are not affiliated with any entities that sell financial products or securities. No commissions are accepted in any form and no finder fees are paid. Types of Advisory Services Initially and on a continuous basis, we consult with clients through meetings, phone calls and emails to -class preferences, time horizons, tax situation and liquidity needs, among other things. Based on discussions with clients regarding these factors, NEPWA develops a client's asset allocation and constructs and manages a broadly diversified portfolio across global asset classes. Clients are advised that it remains their responsibility to promptly notify the firm of any change in their personal or financial situation or investment objectives, for the purposes of reviewing, advisors such as their attorney, CPA, insurance agent) on various financial areas including tax planning, education planning, retirement planning, estate planning, insurance needs, personal cash flow, net worth statements, charitable giving, mortgage refinancing, establishment of retirement plans, general business issues, among other things. NEPWA does not charge a separate fee for these services. In performing our services, NEPWA shall not be required to verify any information received from the client or . If requested by the client, NEPWA may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from NEPWA. Moreov 4  Firm Brochure Part 2A of Form ADV September 3, 2025 there is ever any change in his/her/their financial situation or investment objectives for the purpose of NEPWA also provides certain legacy clients income tax services which include preparing annual returns and quarterly estimates. NEPWA may charge a separate fee for services related to income tax preparation services. Retirement Plan Advisory Services NEPWA also provides advisory services on a retirement plan level, working directly with Plan Trustees/Senior Management/Committee Members. We do not communicate directly with plan participants, nor do we provide employee education. NEPWA will analyze the plan's current investment platform and monitor and recommend changes in the plan's investment options as may be appropriate from time to time. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include vendor analysis, investment oversight and performance reporting. As of December 31, 2024, NEPWA managed a total of $2,999,207,083- consisting of $2,641,227,946 on a discretionary basis and $357,979,137 on a non-discretionary basis. Asset Management NEPWA typically suggests clients consider investing in Exchange Traded Funds (ETFs) and/or mutual funds within their investment portfolio. When selecting mutual funds, NEPWA attempts to utilize the lowest cost share class available. This is determined on an account-by-account basis depending on what share class is available at that time and other fees that may be assessed. NEPWA will monitor the performance of the selected ETFs and mutual funds. If NEPWA determines the investment is no longer consistent with the client's personal investment objectives or asset allocation and/or identifies another potential reason to sell the investment (for example: a manager change, underperformance) NEPWA will suggest removing the client's assets from that selected investment. Similarly, NEPWA will provide the client with suggestions for purchasing ETFs and/or . NEPWA has the discretionary authority to implement . However, as a matter of practice, NEPWA, when possible, will first consult with the client prior to implementing the purchase or sale of ETFs and/or mutual funds. Under certain limited circumstances, NEPWA may also advise on individual securities including corporate debt securities, municipal and government securities, certificates of deposit, bank and FDIC insured products and other investment solutions. In certain situations, NEPWA may suggest a client consider an annuity product. Additionally, clients may maintain legacy positions within their accounts, when it is believed to be in the best interest of the client and/or at the request of the client. portfolio to be managed by an independent third-party NEPWA can suggest allocating a portion of a manager, such as a separate account manager. Our firm will consider several factors in evaluating and/or recommending third party managers including, but not limited to: investment strategy, management style, past performance, reputation, reporting, research capabilities and financial strength. As part of our due diligence, we will make reasonable inquiries into their policies and procedures, code of ethics and other operational matters. Separate account money managers provide investment opportunities among various assets including stocks, bonds, derivatives, mutual funds, ETFs and other types of publicly traded securities. Generally, the 5  Firm Brochure Part 2A of Form ADV September 3, 2025 . terms and conditions under which the client shall engage a third-party manager are outlined in a separate agreement between the client and the selected manager. In certain situations, clients are not required to sign a separate agreement with the third-party manager, and NEWPA retains the authority to hire and terminate third- party managers. Clients are highly encouraged to carefully review the separate account disclosure brochure for important information on the firm, fees, and investment strategy. NEPWA will monitor the performance of the selected investment manager(s). If NEPWA determines that a particular investment manager(s) is not managing the client's portfolio in a manner consistent with the client's personal investment objectives or asset allocation, and/or for another reason (for example: a manager change, underperformance), NEPWA will suggest removing the client's assets from that investment manager(s). In most cases, NEPWA has the discretionary authority to terminate separate a However, as a matter of practice, NEPWA, when possible, will first consult with the client prior to terminating the selected investment manager(s). The client may be required to complete the necessary paperwork to facilitate a change in investment manager(s). NEPWA will not trade securities managed by such selected investment manager(s) unless otherwise directed by the client. In certain situations, NEPWA may suggest to qualified clients allocating a portion of a portfolio to be invested in private real estate and alternative investment strategies. Because these types of investments involve certain additional degrees of risk, less liquidity, and higher fees, they will only be recommended when consistent with the client's investment objectives, risk tolerances, time horizons, liquidity needs, investor eligibility, as well as other factors. Additional information about the fees related to alternative investments is included in the offering documents provided to prospective investors. Clients need to be aware that these types of investments do not provide the same level of liquidity as traditional investments and may be subject to lock-ups and other liquidity restrictions. Managers of alternative investments may not disclose details related to their trading and investment methodologies as it may be considered proprietary. This can lead to a lack of transparency for investors. NEPWA may also recommend investments in private companies in which a client of NEPWA has a vested interest. This presents a conflict of interest which will be disclosed to the client. The client must approve in advance and consent to the purchase and sale of these investments and will be required to complete the necessary paperwork to facilitate the purchase and/or sale of these alternative investments. NEPWA will monitor the performance of the selected alternative investment(s). If NEPWA determines that a particular selected alternative investment(s) is no longer consistent with the client's personal investment objectives or asset allocation, and/or for another reason (for example: a manager change, underperformance), NEPWA will suggest removing the client's assets from that selected investment(s). In these cases, the client will be subject to the liquidity provisions associated with that selected investment(s) and must complete paperwork to directly terminate the manager. NEPWA does not participate in any wrap fee programs. 6  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 5. FEES AND COMPENSATION NEPWA. NEPWA charges an annual investment advisory fee for its services based on either assets under management (AUM) or a fixed annual fee. This fee includes both investment advisory services as well as wealth management services, such as financial planning. NEPWA has the discretion, on a case-by-case basis, to charge a lesser investment advisory fee to clients based on several factors such as anticipated future earnings and future deposits, amount of assets to be managed, pre-existing relationships and related accounts, among other things. NEPWA may aggregate assets for family-related accounts in determining AUM for fee calculation. All fees are agreed upon prior to entering into a contract with any client. fee schedule is AUM Fee Calculation: For client accounts where NEPWA is compensated on an AUM basis, shown below: Assets Under Management First $2,000,000 Next $8,000,000 Over $10,000,000 Annual Fee (%) 1.00% 0.80% 0.50% The above fee schedule is tiered based on the assets under management. For example, a client with $11 million in assets under management will be charged 1.0% on the first $2 million, 0.80% on the next $8 million, then 0.500% for all assets over $10 million. The fee shall be billed in arrears each calendar quarter based on the value (market value or estimated fair market value in the absence of market value) of the portfolio as of the last business day of the previous quarter. The fees will be pro-rated for client relationships initiated during the quarter or client relationships terminated during the quarter. Fixed Fee: For clients where NEPWA is compensated on a fixed fee basis, the amount of the fixed fee will be established in the agreement between the parties. The fixed fee amount will be based upon a number of factors, including complexity of accounts, level of services and amount of assets. The fixed amount will be billed on a quarterly basis (1/4 of the annual fixed fee each calendar quarter). Legacy Fee Arrangements NEPWA maintains legacy fee schedules for certain longstanding or acquired client relationships that will differ from the fee structure currently outlined in this brochure. These legacy arrangements were established prior to the implementation of the current Form ADV and were agreed upon by the client via their investment advisory agreement. Legacy fee arrangements can include fixed fees or a flat fee. 7  Firm Brochure Part 2A of Form ADV September 3, 2025 Form of Payment: investment account. Alternatively, clients have the option to pay the quarterly fee to NEPWA by check. For clients billed on AUM, NEPWA provides the client with a copy of the quarterly fee calculation prior to debiting Other Fees: NEPWA clients may incur other fees including fees paid to qualified custodians and third-party managers in connection with the management of their assets. NEPWA does not receive any portion of these fees. NEPWA does not receive compensation from third parties in connection with the purchase and/or sale of securities or other investment products. Mutual Fund & ETF Fees: All fees paid to NEPWA for investment advisory services are separate and distinct from the internal management fees and expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described in each fund's prospectus and will generally include a management fee, other fund expenses, and a possible distribution fee. The services provided by NEPWA are designed, among other things, to assist the client in determining which mutual funds and/or ETFs are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by NEPWA to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Third Party Investment Manager Expenses: Fees paid to NEPWA by the client for investment advisory services are separate and distinct from the fees and expenses charged to the client by independent separate account managers and/or independent alternative investment managers for that entity's advisory/management services. Additional Fees and Expenses: Clients are also responsible for the fees and expenses charged by qualified custodians, including, but not limited to, any transaction charges imposed by a qualified custodian with which NEPWA and/or a third-party . manager effects transaction Tax-Related Services: As noted in Item 4, NEPWA may charge a separate fee for services related to tax preparation. Termination of Advisory Relationship: A client agreement can be terminated at any time, by either party, for any reason upon receipt of prior written notice. Upon termination, a pro-rated portion of the earned but unpaid advisory fee shall be due. Additionally, in the event of withdrawal of funds or closing of any account, any fees, commissions or other expenses associated with rebalancing or liquidating the account holdings will be assessed to the client's account. 8  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT NEPWA does not charge any performance-based fees. Certain private fund managers and mutual funds invested in by the client may charge performance-based fees. Clients should refer to the applicable offering documents/prospectus for additional information on the investments performance-based fees. ITEM 7. TYPES OF CLIENTS NEPWA focuses on providing investment advisory and wealth management services to individuals, high-net worth individuals, trusts, estates, charitable/non-profit organizations and endowments, corporate and/or business entities, and corporate and/or business pension and profit-sharing plans, etc. NEPWA generally prefers a minimum account size of $2,000,000 for investment advisory services, however, this minimum may be negotiable. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS NEPWA will allocate a client's assets across various investments, taking into consideration discussions between NEPWA and the client regarding a number of factors, including, but not necessarily limited to, the -class preferences, time horizons, tax situation and liquidity needs. Mutual funds will be selected on the basis of any, or all of, the following criteria: the fund's performance history; manager; the fund's investment objectives; the fund's management style and philosophy; the mutual fund . Portfolio weighting between funds and market sectors will be determined by each client's specific objectives and other standards. ETFs will be selected on the basis of any, or all of, characteristics; the underlying index, if applicable; investment style and philosophy; the investment objectives; the company managing the investment; tax efficiency; and the fee structure. As is the case with mutual funds, . NEPWA may review stocks and bonds, including corporate and government bonds, and other legacy positions overall portfolio, or if requested. This involves accessing analyst reports and/or reports available on the internet. Non-publicly traded securities can be evaluated at NEPWA monitors the performance of the securities it recommends and may also monitor the performance of certain legacy positions. Clients may request to place reasonable restrictions on the types of investments which will be made on the client's behalf. NEPWA researches investment managers, mutual funds, exchange traded funds and other investments through face-to-face meetings or phone discussions with firm representatives or portfolio managers from time to time. NEPWA also subscribes to several independent, third-party research services. 9  Firm Brochure Part 2A of Form ADV September 3, 2025 Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. the risk that the value of securities, when sold or All investments present the risk of loss of principal otherwise disposed of, may be less than the price paid for the securities. The securities and instruments (including securities and instruments held by independent managers) recommended by NEPWA are subject to normal market fluctuations and other risks inherent in investing in such investments, and there can be no assurance that any appreciation in value will occur. Securities markets are volatile and can decline significantly in response to adverse issues, including political, regulatory, market or economic developments. Securities markets may also be impacted by global pandemics and natural disasters. Different parts of the market can react differently to these developments and the value of an individual security or particular type of security can be more volatile than, and can perform differently from, the market as a whole. Investing in foreign securities involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. Options Overlay Strategies involve the use of derivative instruments such as calls and puts to enhance income, manage risk, or express tactical views. These strategies may expose portfolios to increased volatility, potential losses beyond the initial investment, and complex tax implications. Options are not suitable for all investors and require a thorough understanding of the underlying mechanics and risks. Long/Short Strategies seek to generate returns by taking long positions in securities expected to appreciate and short positions in those expected to decline. While this approach can offer downside protection and diversification, it also introduces risks such as short squeeze exposure, leverage-related losses, and increased trading costs. Performance may be more volatile than traditional long-only strategies and may not correlate with broader market movements. Opportunity Zone Fund Investments are designed to provide tax incentives for investing in designated economically distressed areas. While these funds may offer attractive tax deferral and exclusion benefits, they also involve risks related to illiquidity, long holding periods, regulatory changes, and concentration in specific geographic or sector exposures. Investors should be aware that Opportunity Zone investments may not be suitable for short-term objectives and require a long-term commitment. Investments in private placements, private real estate investments, limited partnerships, limited liability companies, derivatives, interval funds and annuities involve additional risk of loss, including the risk of loss of a full investment. Because these types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, and liquidity needs. Clients need to be aware that these types of investments do not afford the same level of liquidity and/or marketability as traditional investments and may be subject to lock-ups and other liquidity restrictions. Investors in these products should refer to the applicable offering documents and prospectus for additional information on risk factors, risk of loss and liquidity. The risk of loss described herein should not be considered an exhaustive list of all the risks which clients should consider. 10  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 9. DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary events that would be material . Our firm and our personnel have no reportable disciplinary events to disclose. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS NEPWA is owned by Aspen, which is a holding company that is indirectly owned and controlled by private fund vehicles managed by Alpine Management Services III, LLC Summitry, LLC, , SKY Investment Group LLC, and MG Financial, LLC, and is expected to hold other investment advisers in the future. Alpine Investors is an investment adviser registered with the SEC that provides advisory services to various private fund clients. These affiliations create potential conflicts of interest. For instance, there is the potential for competing demands for certain investment opportunities between NEPWA and other affiliated entities of Alpine Investors, potentially leading to preferential treatment of such other affiliated entities. Alpine Investors does not provide investment advice to NEPWA or its clients. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Investment Advisers are deemed Fiduciaries. provide fair and full disclosure of all material facts. In addition, an investment adviser has a duty of utmost good faith to act solely in the best interest of each of their clients. NEPWA understands its role as a fiduciary and has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. NEPWA's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth NEPWA's practice of supervising the personal securities transactions of supervised persons with access to client information, among other things. Individuals associated with NEPWA can buy or sell public and private investments for their personal accounts identical to or different than those recommended to clients. Individuals are prohibited from purchasing individual corporate stock securities subject to certain exceptions. It is the expressed policy of NEPWA that no person employed by NEPWA shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with its Code of Ethics, NEPWA requires that anyone associated with this advisory practice provide securities holdings reports (both initially upon commencement of employment and annually thereafter) and quarterly transaction reports to the firm's Chief Compliance Officer. This relates to accounts in which the individual has trading authority and/or direct or indirect beneficial ownership. NEPWA requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. NEPWA's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to disciplinary measures. 11  Firm Brochure Part 2A of Form ADV September 3, 2025 NEPWA requires that all employees attest annually Ethics. Compliance Officer of NEPWA at (781) 416-1707 or melissa.boccaci@nepwealth.com. ITEM 12. BROKERAGE PRACTICES and Fidelity Institutional Wealth for custody and brokerage services for our clients. In certain circumstances, NEPWA may Selecting Brokerage Firms NEPWA may recommend clients use a broker- request. Factors that NEPWA considers in recommending a broker-dealer/qualified custodian to clients include pricing, historical relationship with us, financial strength, reputation, execution capabilities, research and service. NEPWA generally recommends Schwab Advisor Services Services ( utilize TIAA and Vanguard Group for brokerage and custodial services. NEPWA may negotiate a discounted commission transaction fee schedule with our recommended broker- dealers/qualified custodians for the benefit of our clients, and will provide such fee schedule to all applicable clients. Each client approves a custodian(s) and completes a separate agreement with each designated broker-dealer/custodian. Research and Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular custodian, NEPWA may receive from Schwab and Fidelity without cost, support services and/or products which assist NEPWA in monitoring and servicing the accounts held with the custodian. Schwab and Fidelity may also make available to NEPWA other products and services that benefit NEPWA but may not benefit its clients' accounts. These services and products may include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution, provide research, pricing information and other market data, facilitate payment of NEPWA's fees from its clients' accounts, and assist with back-office functions, recordkeeping, and client reporting. Many of these services generally may be used to service all or a substantial number of NEPWA's accounts. Schwab and Fidelity also make other services available to NEPWA intended to help NEPWA manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. NEPWA does not enter into any commitments with the brokers for transaction levels in exchange for any services or products from brokers. Therefore, affected as a result of these arrangements. NEPWA's request that clients maintain their assets in accounts at Schwab or Fidelity may be based in part on the benefit to NEPWA of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the brokers, which may create a potential conflict of interest. While Schwab and Fidelity are well-known national brokerage firms who provide discounted commission rates, it is possible there may be other firms who provide discounted commission rates equal to or less than Schwab and Fidelity. Additionally, while Schwab and Fidelity provide good execution services, it is possible that other firms also provide good execution services. 12  Firm Brochure Part 2A of Form ADV September 3, 2025 Best Execution In seeking best execution, the determinative factor is not always lowest possible cost, but whether the transaction represents the best qualitative execution, including the value of research provided, execution capability, commission rates, and responsiveness. In directing the use of a particular qualified custodian, it should be understood that NEPWA may not be able to negotiate commissions among various broker-dealers/qualified custodians or obtain volume discounts, and best execution may not be achieved on a trade-by-trade basis. Trade Aggregation NEPWA does not aggregate trade orders due to the nature of investment advisory services and client customized portfolios. Because we do not aggregate trades, clients may receive different execution prices. A separate account manager, in the management of NEPWA client portfolios, may aggregate transactions another client of the separate account manager who is not a NEPWA client. If a separate account manager is utilized, that manager may have different brokerage practices, and the client should review the disclosure documents and agreements of the selected separate account manager. Corporate and Business Retirement Plan Services NEPWA may consult on plans custodied outside of Schwab or Fidelity, where we do not have discretion. We cannot directly place trades in these accounts but can assist in implementing securities transactions for these plans. ITEM 13. REVIEW OF ACCOUNTS Review: Account assets are supervised by NEPWA. Accounts are reviewed in the context of each client's investment objectives. The reviewers of client relationships are the financial advisors. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, market conditions, or the political or economic environment. All clients are advised that it is their responsibility to inform NEPWA of any changes in their investment objectives and/or financial situation. Corporate and Business Retirement Plan Services Retirement plan assets are reviewed as necessary and according to the standards and situations described above for investment management accounts. Reports: Clients will receive monthly and/or quarterly statements and confirmations directly from their respective qualified custodian(s). Additionally, clients can establish online access directly with the custodian(s). NEPWA will generally provide periodic reports, which are typically a current allocation report. 13  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION We have been fortunate to receive many client referrals over the years. These referrals have come from our existing clients, estate planning attorneys, accountants, affiliates and other professional advisors. NEPWA does not compensate any third party for client referrals. It is our policy not to accept any form of compensation (for example: cash, sales awards, or prizes) from other professionals in conjunction with the services we provide to our clients. NEPWA receives no compensation from any person or entity other than our clients. . All assets are held at qualified custodians. As such, ITEM 15. CUSTODY Account Statements NEPWA does NOT physically clients will receive monthly and/or quarterly statements and confirmations directly from their respective qualified custodian(s). Advisor Review NEPWA will generally provide periodic reports, which are typically a current allocation report. Clients should carefully review all statements. NEPWA urges clients to compare statements received from their respective qualified custodian(s) with those received from NEPWA. Our statements may vary from custodial statements because of posting dates of dividends and interest, reporting dates, or valuation methodologies of certain securities. Custody Although NEPWA does not maintain physical custody of client assets, we are deemed to have custody due to cases we have access to client funds, as Ira Rapaport has been named personally as a trustee or Power of Attorney (POA) . NEPWA has engaged an independent CPA firm for the custody related surprise examinations on accounts where an employee is named as trustee or POA. The independent public accounting firm is registered with the Public Company Accounting Oversight Board. These annual exams are mandated by the SEC Custody Rule and are completed at a time that is chosen by the accountant without prior notice or announcement to NEPWA. ITEM 16. INVESTMENT DISCRETION Limited Discretionary Authority NEPWA usually receives limited discretionary authority from the client at the outset of an advisory relationship. bought or sold and the amount of the securities to be bought and sold. This authority may also include the discretion to hire or terminate a separate account investment manager. Limitations Any limitations on this discretionary authority shall be included in the client agreement. Clients can change/amend these limitations as required. Such amendments shall be submitted in writing. In all cases, however, such discretion is to be exercised in a manner consistent with the investment objectives for the particular client account. 14  Firm Brochure Part 2A of Form ADV September 3, 2025 ITEM 17. VOTING CLIENT SECURITIES As a matter of firm policy and practice, NEPWA does not accept the authority to and does not vote proxies on behalf of clients. The responsibility for receiving and voting client proxies is either retained by the client or the responsibility of the independent separate account managers. In the event any client may request assistance about the proxy voting process, NEPWA may provide information to assist the client, but the client, or independent manager, maintains the responsibility for receiving and voting any client proxies. ITEM 18. FINANCIAL INFORMATION NEPWA has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. 15