NEW ENGLAND PRIVATE WEALTH ADVISORS, LLC

Firm Brochure Part 2A of Form ADV February 9, 2026 ITEM 1. Cover Page New England Private Wealth Advisors, LLC Annual Disclosure Brochure Form ADV Part 2A Dated: February 09, 2026 This brochure provides information about the qualifications and business practices of New England Private Wealth Advisors, LLC (“NEPWA”). 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. The firm’s registration does not imply a certain level of skill or training. Additional information about NEPWA is also available on the SEC’s website at: www.adviserinfo.sec.gov. You can view our information on this website by searching for “New England Private Wealth Advisors”. You can also search using the firm’s CRD number, 133790. 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 February 9, 2026 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 4 and 5 have been updated to disclose our new Diversified Income SMA Model Strategies.  Item 14 has been updated to disclose certain referral fee programs that NEPWA participates in. 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 February 9, 2026 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 ............................................................................................................................ 12 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................................. 12 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..12 ITEM 12. BROKERAGE PRACTICES ................................................................................................................................ 11 ITEM 13. REVIEW OF ACCOUNTS .................................................................................................................................... 15 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................... 15 ITEM 15. CUSTODY ............................................................................................................................................................ 16 ITEM 16. INVESTMENT DISCRETION ............................................................................................................................... 17 ITEM 17. VOTING CLIENT SECURITIES ........................................................................................................................... 17 ITEM 18. FINANCIAL INFORMATION ................................................................................................................................ 17 3  Firm Brochure Part 2A of Form ADV February 9, 2026 ITEM 4. ADVISORY BUSINESS Firm Overview New England Private Wealth Advisors, LLC (“NEPWA” or “We”) is a registered investment adviser with the Securities and Exchange Commission (“SEC”). NEPWA was founded in 2005 by Ira Rapaport and was 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’s ownership is available within our Form ADV Part 1. 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. NEPWA offers continuous investment advisory and wealth management services on a fee 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. In addition to managing the client’s investment portfolio, NEPWA will consult with clients on various financial planning topics (as discussed below in more detail). NEPWA provides objective investment advice and always prioritizes the client’s interest. NEPWA is a fee based investment advisory and wealth planning firm. The firm does not sell annuities, insurance products, mutual funds, or any other commissioned product. Types of Advisory Services Wealth Management Services Initially and on a continuous basis, we consult with clients through meetings, phone calls and emails to determine the client’s investment objectives, risk tolerances, asset-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 purpose of reviewing, evaluating, or revising NEPWA’s recommendations and services. In addition to managing the client’s investment portfolio, NEPWA may consult with clients (and/or their current 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. 4  Firm Brochure Part 2A of Form ADV February 9, 2026 In performing our services, NEPWA shall not be required to verify any information received from the client or from the client’s other professional advisors and is expressly authorized to rely thereon. 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. Moreover, each client is advised that it remains the client’s responsibility to promptly notify NEPWA if there is ever any change in his/her/their financial situation or investment objectives for the purpose of reviewing/evaluating/revising NEPWA’s previous recommendations and/or services. 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. 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 mutual funds based on NEPWA’s investment analysis. NEPWA has the discretionary authority to implement changes in the client’s portfolio. 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. NEPWA can suggest allocating a portion of a client’s portfolio to be managed by an independent third-party 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 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 NEPWA retains the authority to hire and terminate third- party managers. Clients are highly encouraged to carefully review the separate account manager’s Form ADV 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), 5  Firm Brochure Part 2A of Form ADV February 9, 2026 NEPWA will suggest removing the client's assets from that investment manager(s). In most cases, NEPWA has the discretionary authority to terminate separate account investment managers on the client’s behalf. 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 can suggest qualified clients allocate a portion of their 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. Diversified Income SMA Model Strategies In addition to our Wealth Management Services noted above, NEPWA also offers separate account investment model strategies (“Model Strategies”) that differ from its traditional customized advisory services. These Model Strategies are designed to seek current income, liquidity, and tax efficiency, and are generally intended for investors seeking potential monthly income rather than long-term capital appreciation. The Model Strategies target annualized income yields generally in the range of approximately 8% to 12%, depending on the specific model selected and prevailing market conditions. Target yields are not guaranteed and may not be achieved. NEPWA currently offers three model variations of the Model Strategies: • Conservative Income • Moderate Income • Aggressive Income 6  Firm Brochure Part 2A of Form ADV February 9, 2026 Each model differs in its allocation to equity and other higher-risk asset classes, reflecting differing investor objectives, risk tolerance, and income needs. Investors should understand that higher targeted income levels typically involve higher levels of investment risk and potential volatility. NEPWA does not provide comprehensive financial planning, personalized financial advice, or individualized portfolio recommendations to clients utilizing these Model Strategies. NEPWA does not assess a client’s overall financial situation, tax circumstances, estate planning needs, or other personal financial goals when providing access to a Model Strategy. Clients are solely responsible for selecting the Model Strategy that they believe is appropriate based on their individual investment objectives, risk tolerance, and financial circumstances. Clients should carefully review the characteristics and risks of each Model Strategy prior to selection and consult with independent financial, tax, or legal professionals as they deem appropriate. The Model Strategies invest exclusively in exchange traded funds (ETFs). The strategies emphasize ETFs that may employ options-based income strategies, including ETFs that sell covered call options or otherwise utilize derivatives on underlying indices or asset classes to generate income. These options-based or “derivative income” ETFs represent a growing segment of the ETF market and are offered by a variety of issuers. The Firm selects ETFs across multiple issuers and asset classes based on its assessment of factors such as investment exposure, income characteristics, liquidity, expenses, and risk profile. Investors in these strategies do not receive financial planning services or Wealth Management services unless separately contracted for. NEPWA will provide these Model Strategies on a separate account management basis or NEPWA can provide this service as a sub-advisor. 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. ITEM 5. FEES AND COMPENSATION The specific manner in which fees are charged is established in a client’s written engagement letter with 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. 7  Firm Brochure Part 2A of Form ADV February 9, 2026 AUM Fee Calculation: Wealth Management Services: For client accounts where NEPWA is compensated on an AUM basis, NEPWA’s general fee schedule is 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. Diversified Income Model SMA Strategies Investors participating in NEPWA’s Model Strategies will be charged an annual fee of 1%. The fee will be debited directly from the account, quarterly in arrears. 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). The fixed advisory fee may be subject to an annual cost-of-living adjustment of up to three percent (3%). 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. Form of Payment: Clients provide written authorization to the custodian permitting NEPWA to debit fees from the client’s 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 the client’s investment account. 8  Firm Brochure Part 2A of Form ADV February 9, 2026 Other Fees: NEPWA clients will 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 for the client’s accounts. 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. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT NEPWA does not charge any performance-based fees. 9  Firm Brochure Part 2A of Form ADV February 9, 2026 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. For Wealth Management Services, NEPWA generally prefers a minimum account size of $2,000,000 for investment advisory services, however, this minimum may be negotiable. For the Model Strategies, NEPWA generally prefers a minimum account size of $500,000; however, this minimum can be negotiated. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS For Wealth Management Services, 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 client’s investment objectives, risk tolerances, asset-class preferences, time horizons, tax situation and liquidity needs. For the Model Strategies, the client is responsible for selecting the model strategy that aligns with their investment objectives, risk tolerance, and financial circumstances. As a result, there is a risk that a client may select a strategy that is not suitable for their needs, which could result in investment outcomes that do not align with the client’s expectations or financial goals. Mutual funds will be selected on the basis of any, or all of, the following criteria: the fund's performance history; the fund’s risk characteristics; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; the mutual fund company; the fund’s tax efficiency; and the fund's management fee structure. 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, the following criteria: the ETF’s performance history; the risk 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, portfolio weightings among ETFs in a client’s portfolio will be determined by each client’s specific situation. NEPWA may review stocks and bonds, including corporate and government bonds, and other legacy positions the client has selected or that already exist in the client’s portfolio in the process of reviewing the client’s 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 the client’s request. 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. 10  Firm Brochure Part 2A of Form ADV February 9, 2026 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. Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities, when sold or otherwise disposed of, may be less than the price paid for the securities. In addition, diversification does not ensure a profit or protect against a loss. 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 11  Firm Brochure Part 2A of Form ADV February 9, 2026 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. ITEM 9. DISCIPLINARY INFORMATION We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of NEPWA or the integrity of NEPWA’s advisory business. Our firm and our personnel have no reportable disciplinary events to disclose. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As described in “Advisory Business” above, 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 (“Alpine Investors”). Aspen is a holding company that owns registered investment advisers, including Summitry LLC, SKY Investment Group LLC, MG Financial LLC, and Martel Wealth Advisors 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 can create potential conflicts of interest for NEPWA. 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 Advisors are deemed Fiduciaries. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor 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. It 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. 12  Firm Brochure Part 2A of Form ADV February 9, 2026 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. NEPWA requires that all employees attest annually to their receipt and compliance with NEPWA’s Code of Ethics. A copy of NEPWA’s Code of Ethics may be requested by contacting Melissa Boccaci, Chief Compliance Officer of NEPWA at (781) 416-1707 or melissa.boccaci@nepwealth.com. ITEM 12. BROKERAGE PRACTICES Selecting Brokerage Firms NEPWA may recommend clients use a broker-dealer for execution and/or custodial services upon the client’s request. Factors that NEPWA considers in recommending a broker-dealer/qualified custodian to clients include pricing, historical relationship with the firm, financial strength, reputation, execution capabilities, research and service. NEPWA generally recommends Schwab Advisor Services (“Schwab”) and Fidelity Institutional Wealth Services (“Fidelity”) for custody and brokerage services for clients. In certain circumstances, NEPWA may 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. 13  Firm Brochure Part 2A of Form ADV February 9, 2026 NEPWA does not enter into any commitments with the brokers for transaction levels in exchange for any services or products from brokers. Therefore, NEPWA’s clients do not pay more for investment transactions 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. 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/Blocking Wealth Management Services: NEPWA does not aggregate trade orders for Wealth Management Services clients due to the nature of investment advisory services and client customized portfolios. Since NEPWA does not aggregate trades for these accounts, clients may receive different execution prices. Model Strategies: For certain model-based strategies offered by NEPWA, including its separately managed account Model Strategies, NEPWA generally aggregates and executes trades on a block basis for multiple client accounts participating in the same strategy, or across strategies. Block trading is used to promote administrative efficiency and, in some circumstances, may result in more favorable execution pricing or reduced transaction costs for participating clients. When trades are aggregated, NEPWA seeks to allocate securities among participating client accounts on a fair and equitable basis, consistent with each client’s investment objectives and account restrictions. NEPWA does not guarantee that all participating accounts will receive the same execution price, as prices may vary due to market conditions, partial fills, or account-specific factors. By contrast, client accounts receiving NEPWA’s traditional, non-model Wealth Management services are generally traded individually and are not aggregated or block traded with other client accounts. NEPWA’s use of block trading for model-based strategies, while trading traditional advisory accounts separately, presents potential conflicts of interest. Clients participating in block-traded model strategies may receive different execution prices or transaction timing than clients whose accounts are traded individually. NEPWA seeks to mitigate these conflicts by implementing written trade allocation policies and procedures designed to ensure that all clients are treated fairly and that no client or group of clients is systematically 14  Firm Brochure Part 2A of Form ADV February 9, 2026 favored over another. Clients should understand that differences in trading methodology may result in different investment outcomes, even when accounts have similar investment objectives. A separate account manager, in the management of NEPWA client portfolios, may aggregate transactions among accounts that it manages, in which case a NEPWA client’s orders may be aggregated with an order for 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 our primary custodians, 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). For WM clients only, NEPWA will generally provide periodic reports, which are typically a current allocation report. 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 has also entered into arrangements with unaffiliated third parties to introduce prospective clients to NEPWA in exchange for compensation. Clients are not charged any additional fees as a result of these arrangements. 15  Firm Brochure Part 2A of Form ADV February 9, 2026 Referral fee arrangements create a conflict of interest because the third party has a financial incentive to recommend NEPWA. NEPWA seeks to mitigate this conflict by requiring that all such relationships comply with applicable regulatory requirements, including appropriate disclosures to prospective clients at the time of the introduction. 1031 Real Estate Referral Program. NEPWA has entered into a referral arrangement with an unaffiliated third party, pursuant to which NEPWA can refer prospective clients to the third-party in connection with Section 1031 exchange transactions involving real property. Section 1031 of the Internal Revenue Code permits investors to defer recognition of capital gains taxes on the exchange of certain real estate property held for investment or business purposes, subject to applicable requirements and limitations. Under this arrangement, NEPWA receives a referral fee for recommending clients who are considering converting real estate holdings into potential tax-efficient investment structures through a 1031 exchange. This referral fee creates a conflict of interest because the firm has a financial incentive to recommend the third-party for these services. NEPWA seeks to mitigate this conflict by disclosing the referral arrangement and associated compensation to clients at or before the time of the referral, as required by applicable regulations. Clients are under no obligation to engage the third-party and may select any qualified 1031 exchange provider of their choosing. Clients are encouraged to consult with their independent tax and legal advisors regarding the suitability and tax consequences of any 1031 exchange. NEPWA’s role is limited to providing general information and an introduction to the third-party related to 1031 exchange option services. ITEM 15. CUSTODY Account Statements NEPWA does NOT physically hold its clients’ assets. All assets are held at qualified custodians. As such, clients will receive monthly and/or quarterly statements and confirmations directly from their respective qualified custodian(s). Advisor Review NEPWA will generally provide Wealth Management clients with 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 due to 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 (1) the ability to debit our investment management fees directly from our clients’ accounts and (2) in some cases we have access to client funds, as Ira Rapaport has been named personally as a trustee or Power of Attorney (POA) on certain clients’ trust accounts. 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. 16  Firm Brochure Part 2A of Form ADV February 9, 2026 ITEM 16. INVESTMENT DISCRETION Limited Discretionary Authority NEPWA usually receives limited discretionary authority from the client at the outset of an advisory relationship. Limited discretionary authority permits NEPWA to select, without the client’s prior approval, securities to be 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. ITEM 17. VOTING CLIENT SECURITIES As a matter of firm policy and practice, NEPWA does not accept 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. 17