NORTHEAST ADVISERS INC

Form ADV Part 2A Disclosure Brochure Contact Information: Michael Devine Rebecca Proetto, CPA, CFP® 610-240-7955 Toll Free: 800-971-7039 advice@northeastadvisers.com www.northeastadvisers.com 163 W. Lancaster Ave. Paoli, PA 19301 March 2025 Disclaimer: This brochure provides information about the qualifications and business practices of Northeast Advisers, Inc. If you have any questions about the contents of this brochure, please contact us at the number or email listed above. 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. Northeast Advisers, Inc. is a Registered Investment Advisor. Registration does not imply a certain level of skill or training. Additional information about Northeast Advisers, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Free and simple tools are available to you to review Northeast Advisers, Inc. and its financial professionals at Investor.gov/CRS, which also provides free educational materials about broker-dealers, investment advisers, and investing.  F O R M A D V Part II - Page 2 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 2. Material Changes This Form ADV Part 2A brochure (“Brochure”) is provided to inform our current and prospective clients of Northeast Advisers, Inc.’s (“NAI”) business policies, practices and potential conflicts of interest. We encourage you to contact us with any questions about this Brochure. Since NAI’s last annual update of the Brochure in March of 2024, the firm has made no material changes. This item discusses only specific material changes that are made to the Brochure since its last update. Minor updates and clarifications occur throughout this document and we encourage you to review the full Brochure. NAI will distribute to clients a summary of any material changes to its Brochure promptly as necessary. A current Brochure and/or Form CRS may be requested, free of charge, by contacting us by phone at 800-971-7039 or via email at advice@northeastadvisers.com. Additional information about NAI and its employees is available on the SEC’s websites adviserinfo.sec.gov and Investor.gov/CRS.  F O R M A D V Part II - Page 3 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 TABLE OF CONTENTS Item Page Item Number ADV Part 2A Firm Brochure 1 2 3 4 5 6 7 8 9 10 11 Cover 2 3 4 5 6 6 7 10 10 11 12 13 14 15 16 17 18 19 Cover Page Material Changes Table of Contents Advisory Business Fees and Compensation Performance-Based Fees and Side-By-Side Management Types of Clients Methods of Analysis, Investment Strategies and Risk of Loss Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Brokerage Practices Review of Accounts Client Referrals and Other Compensation Custody Investment Discretion Voting Client Securities Financial Information Privacy Notice 11 12 13 14 15 15 15 15 ADV Part 2B Brochure Supplement J. Michael Devine Eric J. Bleiler, CPA1/PFS2, CFP®3 Rebecca Proetto, CPA1, CFP®3 Sarah Cardamone Footnotes 17 18 19 20 21 22  F O R M A D V Part II - Page 4 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 4. Advisory Business Northeast Advisers, Inc. (“NAI”) is an independent Registered Investment Adviser (RIA) based in Paoli, Pennsylvania providing investment advisory and financial planning services. Michael Devine owns 80% of the Firm. Rebecca Proetto and Eric Bleiler each own 10%. NAI has been in existence since June 2000. Our goal is simple—to help you achieve yours. As an independent firm, we strive to represent our clients’ best interests. This independence allows us to employ the very same processes used by many of the nation’s largest asset pools and take a best of breed approach to investment and administrative services. Our compensation structure allows that our interests are aligned with our clients’. We are able to leverage experience and relationships and seek to deliver a “highly functioning” investment program. We define highly functioning as striving to have fully disclosed, low cost and transparent investment solutions with key elements such as plan design, plan administration and low-cost investments. We develop investment strategies designed to meet our clients' goals. Investment strategies are implemented seeking a "best of breed" approach and our client portfolios typically include select no-load mutual funds. We also use exchange traded funds and individual securities, when appropriate. This means we believe that we are totally objective and are free to make unbiased recommendations. In all cases, costs are taken into consideration along with performance, management and suitability. Careful portfolio structure and emphasis on understanding our clients’ objectives distinguishes NAI. We employ a disciplined process that many sophisticated institutional investors have followed for decades managing their investments. This includes the development of a written Statement of Investment Policy. Each client’s plan is designed based on a detailed understanding of their objectives. Additionally, we work closely with our clients’ other advisors or may recommend specialists as appropriate. NAI uses third-party service providers to perform certain services, as applicable for a client’s account. We use Orion Advisor Services (Orion) for performance reporting and billing. Clients are able to directly view their accounts through the Orion portal as well as through the custodian’s portal. In providing our services, we acknowledge that we are a fiduciary and charged with acting in our clients’ best interests. We help retirement plan sponsors and other trustees manage fiduciary responsibility, minimize costs, maximize plan design and monitor performance.  F O R M A D V Part II - Page 5 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 We design investment menus and communications about the investment choices for retirement plan participants. We stay involved and encourage participants to call anytime with investment questions. Our independent Registered Investment Advisory services are designed to strive to keep your portfolio moving in the right direction. NAI has $576,435,000 client assets under advisement as of December 31st 2024. These services are provided on a non-discretionary basis. 5. Fees and Compensation Northeast Advisers, Inc. provides fee-only investment advisory consulting services utilizing a four-step investment advisory process: 1. Analyze Current Portfolio 2. Design Investment Policy Statement (IPS) 3. Implement Investment Strategy 4. Monitor and Supervise Portfolio As stated in our firm’s Advisory Services Agreement, NAI will accept no commission or undisclosed remuneration. In consideration of the services to be performed, NAI shall be paid quarterly, in arrears, an amount based on the total market value of the account assets as of the last day of the previous calendar quarter on an annual percentage rate. This fee may be negotiable depending on the characteristics and particular circumstance of the client. Fees may be reduced or waived entirely for NAI associates, employees, family, directors and securities holders, or others as deemed appropriate by NAI. Services begin with the effective date of the Agreement. Fees for the initial quarter will be adjusted pro rata based upon the number of calendar days in the calendar quarter that the Agreement is effective. Fees will also be pro-rated for the portion of a quarter in which an account is terminated. The client has the right to terminate at any time by submission of written notice to the Adviser and the custodian. NAI fees are typically deducted directly from Client accounts. Custodians will provide the client with a monthly or quarterly statement showing an inventory of the investments and transactions, which includes fees automatically deducted from their accounts. In some cases, clients are billed directly by NAI via first class mail. These invoices reflect the amount of the fee, the value of the Client’s Account on which the fee was based, and the specific manner in which NAI’s fee was calculated.  F O R M A D V Part II - Page 6 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Fees are normally based on a sliding scale or on a flat percentage basis or may also be engaged on a financial planning or project consulting basis for a flat fee. The sliding scale is as follows: Account Size Up to $999,999 $1,000,000 to $1,499,999 $1,500,000 to $1,999,999 Over $2,000,000 Fee 1.00% 0.85% 0.75% Negotiable (Multiple accounts from the same investor may be combined for fee purposes at NAI’s discretion.) NAI also provides fee-based financial planning services. Financial Planning fees are billed at an hourly rate, not to exceed $200 per hour. Clients receive a fee estimate and a full description of services to be provided as part of the Financial Planning Agreement. Financial planning costs may be waived for investment clients. No minimums are required for financial planning services. Clients should be aware that they are assessed additional fees by money management firms which may include separate account money managers’ fees, mutual fund internal expenses, 12b-1 fees, platform fees, and transfer fees, in addition to advisory fees charged under our Advisory Agreement. The custodian and/or trading brokerage charge a separate transaction-based fee on some mutual funds. These fees are automatically deducted from the client’s account. NAI will not receive any portion of these charges. NAI has entered into a service agreement with Orion Advisor Services (Orion) for back office and certain administrative services. NAI pays Orion directly for performance reporting and billing services. 6. Performance-Based Fees and Side-By-Side Management NAI does not charge performance-based fees. We do not accept commissions. We do not manufacture products; and therefore, our fee structure seeks to avoid conflicts of interest. 7. Types of Clients NAI provides investment advice and financial planning services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and corporations. NAI’s relationships are often initiated by referrals from professionals or existing clients. Our diverse client base includes: individual investors who are accumulating and protecting  F O R M A D V Part II - Page 7 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 wealth and understand the benefits of a written game plan, consolidated reporting, and an ongoing advisory relationship that places their interests first; families that employ financial and estate plans designed to shepherd their assets across generations; businesses who sponsor retirement plans that seek a highly functioning suite of services, including an adviser acting as a co-fiduciary; retirement plan clients seeking design, plan administration, and participant education on an ongoing basis; and institutions seeking responsible stewardship of their financial resources. This includes working with the boards of foundations and endowments to meet their goals while adhering to the highest fiduciary standard. For advisory services, NAI’s requires a minimum aggregate relationship size of $250,000 in assets under advisement. However, the minimum may be waived by NAI subject to consideration of anticipated future contributions or other factors. No minimum value is required for financial planning services. 8. Methods of Analysis, Investment Strategies and Risk of Loss The first step we take with any client is to develop a written Statement of Investment Policy (IPS). The IPS is a guide for the design, implementation and monitoring of client portfolios. It is prepared with our clients’ specific circumstances in mind including objectives, tolerance for risk and the clients’ investment time horizon. We invite our clients and prospective clients to provide a complete inventory of all of their investment positions so that they can be taken into account on developing recommendations and investment review for the assets entrusted to NAI’s care. This is also important for assuring adequate diversification. Positions in the portfolios are recommended based on due diligence that considers the investment’s management, performance and expenses. We are mindful of expenses as it has an effect on long-term performance. Risks All investing involves a risk of loss. Our process attempts to take into account the elements required for long-term success in achieving financial goals. The list of risk factors below is not a complete enumeration or explanation of the risks involved in an investment through NAI or any of the client portfolios it manages. It is possible that some of the investment vehicles and direct investments selected by NAI will not meet all the above criteria, and that some or all the investments selected by NAI will not  F O R M A D V Part II - Page 8 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 perform as anticipated. Depending on conditions and trends in the financial and securities markets and the economy in general, NAI may pursue any objectives, employ any investment techniques or purchase any type of security that it considers appropriate and in the best interests of clients that may not be described, subject to restrictions imposed by clients. There can be no assurance that the NAI’s investment strategy will achieve profitable results, and results may vary substantially over time. Past performance of a portfolio or past performance of NAI or its affiliates are not indicative of future results. Investors risk the loss of their entire investment. Note that the risks below are also applicable to the extent that a mutual fund recommended by NAI holds the types of securities described below. The risks associated with mutual fund positions are disclosed in the mutual fund prospectus prepared by the fund companies and provided to clients by NAI with the initial investment recommendation. Common Stock Risk. Common stock risks include the financial risk of selecting individual companies that do not perform as anticipated, the risk that the stock markets in which a portfolio invests may experience periods of turbulence or instability, and the general risk that domestic and global economies may go through periods of decline and cyclical change. Small and Mid-Cap Stocks Risk. Companies with small and medium market capitalizations are relatively small compared to large-capitalization companies; they may be engaged in business mostly within their own geographic region; and may be less well known to the investment community. Also, these companies often have less liquidity, less management depth, narrower market penetrations, less diverse product lines and fewer resources than larger companies. As a result of these factors, small and mid- capitalization stock prices have greater volatility than large company securities. Growth Stock Risk. NAI may invests in companies or mutual funds that contain what appear to be growth-oriented companies. If perceptions of a company’s growth potential are wrong, the securities purchased may not perform as expected, reducing a client portfolio’s return. Foreign Securities Risk. Investments in foreign securities involve greater risks compared to domestic in- vestments for the following reasons: foreign companies may not be subject to the regulatory requirements of United States companies, so there may be less publicly available information about foreign issuers than United States companies; foreign companies generally are not subject to uniform accounting, auditing and financial reporting standards; dividends and interest on foreign securities may be subject to foreign withholding taxes and such taxes may reduce the net return to client accounts; and foreign securities are often denominated in a currency other than the United States dollar. Accordingly, client portfolios will be subject to the risks associated with fluctuations in currency values. Issuers of foreign securities may still be subject to the risk of expropriation,  F O R M A D V Part II - Page 9 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 confiscation, taxation, currency block- age, or political or social instability, any of which could negatively affect client portfolios. Emerging Markets Risk. Investments in developing countries may experience high rates of inflation or sharply devalue their currencies against the United States dollar, causing the value of investments in companies located in those countries to decline. Transaction costs are often higher in developing countries, and there may be delays in the settlement process. Portfolio Turnover Risk. A mutual fund selected by NAI may engage in aggressive portfolio trading, and could, thus, experience high turnover. A high rate of portfolio turnover in any year may increase brokerage commissions paid and could generate greater taxes for client portfolios on realized investment gains. Investment Concentration. At times, a substantial portion of a portfolio’s assets may be invested in the securities of a limited number of issuers, including mutual funds. Investing a significant portion of a portfolio’s assets in a single issuer will make the portfolio susceptible to a greater degree than would otherwise be the case to risks affecting investments in such issuer. Such concentration of investments will increase the volatility of the value of the portfolio’s portfolio investments. Management Risk. Client portfolios are subject to management risk because they are actively managed by investment managers via mutual funds or separate accounts. These managers will apply their investment techniques and risk analyses in making investment decisions for client portfolios, but there is no guarantee that their decisions will produce the intended result. Risks Related to Regulation. Laws and regulations affecting our business change from time to time, and we are currently operating in an environment of significant regulatory reform, both in the U.S. and globally. We cannot predict the effects, if any, of future legal and regulatory changes on our business or the services we provide. Risks Related to Technology and Cyber Security. We and our clients depend heavily on telecommunication, information technology and other operational systems, whether ours or those of others (such as custodians, financial intermediaries and other parties to which we or they outsource the provision of services or business operations). These systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond our or their control. Further, despite implementation of a variety of risk management and security measures, our information technology and other systems, and those of others, could be subject to physical or electronic break-ins, unauthorized tampering or other security breaches, resulting in a failure to maintain the security, availability, integrity and confidentiality of data assets. Technology failures or cyber security breaches, whether deliberate or unintentional, including those arising from use of third-  F O R M A D V Part II - Page 10 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 party service providers or client usage of systems to access accounts, could have a material adverse effect on our business or our clients and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to transact business. Business Continuity Risk – NAI has a business continuity plan (“BCP”) that was designed to address interruptions in our normal business operations. While we believe our BCP is adequate to allow for the continued operations of our business, there is a risk that certain natural or other events that have not been anticipated may impact our operations for a period of time, where NAI is unable to provide continuous investment advisory services. Such examples include but are not limited to terrorist attacks and global pandemics. 9. Disciplinary Information NAI, acting as a fiduciary, has an obligation to disclose disciplinary events to clients. NAI has had no disciplinary events. This includes our firm’s employees, officers, partners, and all persons directly or indirectly controlling or controlled by the firm. 10. Other Financial Industry Activities and Affiliations Neither NAI nor any of its supervised persons are registered or pending registration as a futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of these entities. NAI does not participate in any commission-based compensation. Mr. Bleiler is the owner and president of Eric J. Bleiler, CPA & Co., LLC accounting firm. At Eric J. Bleiler, CPA & Co, he is compensated for his accounting and insurance services by way of his ownership interest. NAI does not receive a portion of this compensation or have any ownership or control of this entity. The payment of a referral fee to a Promoter (formerly Solicitor) will not result in the client being charged an investment advisory fee any greater than the fee charged any other client of the Adviser for comparable services obtained without the use of a Promoter. NAI will share with the Promoter a portion of the fees collected from the client. For additional information regarding Promoters and client referrals, see Item 14.  F O R M A D V Part II - Page 11 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The NAI Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of the employees and owners of NAI do not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. In addition, the Code of Ethics describes NAI’s standard of business conduct and fiduciary duty to its clients. It includes provisions relating to the confidentiality of client information, a prohibition on insider trading, preclearance of certain securities, reporting of securities holdings and transactions, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, among other things. NAI and its principals may, from time to time, buy or sell the same securities recommended to clients in their own account(s). All related persons are required to submit personal securities logs every quarter for review by Compliance. Any conflicting transactions of a related person are denied. A copy of NAI’s Code of Ethics is available upon request by phone at 610-240-7955, or toll free at 1-800-971-7039 and by email at advice@northeastadvisers.com. 12. Brokerage Practices Clients will pre-approve all purchases and sales made to implement the client’s investment strategy in advance of the transaction. Such authorization will identify the brokerage firm where the transaction will take place. This will generally be market orders placed at the custodian. Occasionally, we may suggest a brokerage firm where different types of orders are indicated as being in the client’s best interest. Such transactions will be pre-approved by the client. When recommending broker-dealers to clients, NAI is charged with seeking best execution. When reviewing best execution of a Custodian’s broker-dealer, NAI will consider the full range of services including execution capability, financial responsibility, commission rates, the value of research provided, and responsiveness to the adviser. While NAI seeks to recommend brokerage services that include competitive or best rates, we do not select broker-dealers solely on the basis of cost but on the best overall quality of execution. Other broker-dealers may offer the same services at a lower overall cost. NAI participates in the Charles Schwab & Co. (“Schwab”) Institutional program. Schwab is an independent and unaffiliated SEC-registered broker-dealer. Schwab offers to independent investment advisors, services which include custody of securities, trade execution, clearance, and settlement of transactions. NAI receives benefits from Schwab through its participation in the program. These benefits include the following products and services  F O R M A D V Part II - Page 12 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to trading desk serving NAI participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and compliance, marketing, research, technology, and practice management products or service provided to NAI by third party vendors without cost or at a discount. Please see the disclosure under Item 14 for additional information. Schwab also has paid for business consulting and professional services received by NAI’s related persons. Some of the products and services made available by Schwab through the program may benefit NAI but may not benefit its Client accounts. These products or services may assist NAI in managing and administering Client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help NAI manage and further develop its business enterprise. The benefits received by NAI or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients, NAI endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by NAI or its related persons in and of itself creates a potential conflict of interest and may indirectly influence NAI’s choice of Schwab for custody and brokerage services. It is the Adviser’s policy to ensure that any trade error is identified and corrected in an expeditious manner, and that reasonable steps be taken to mitigate the consequences to the affected Client. When an error is made on behalf of a Client account, the Adviser will use its best efforts to break or otherwise correct the trade. It is also the Adviser’s policy to net the gains and losses from trade errors applicable to an affected Client. Trade errors that result in a loss to the Client will be indemnified by the Adviser. 13. Review of Accounts Client accounts are reviewed relative to the clients’ investment objectives and the established investment policy. Such services are undertaken on a routine basis or because of changes in market conditions, changes to security positions or changes in investment goals or polices. NAI currently has four client account reviewers with an average of over ten years of experience. Please see Part 2B for a list of our advisors and their qualifications.  F O R M A D V Part II - Page 13 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Clients may elect to receive monthly and quarterly reports outlining cost and market value of all assets. Certain broker-dealers maintain custodial platforms that offer additional reporting as part of their services. Performance reports for other custodians are prepared by NAI through Orion, reflecting independent feeds from the respective custodians. Orion provides performance, holdings statements, administrative services such as fee calculations, billing reports, a client portal, and other reports for client accounts. Clients receive a copy or an electronic notice of the availability of the report if they’ve elected electronic delivery. Clients also receive custodial statements directly from their custodians at least quarterly. All clients are urged to compare information provided in their performance statements to the information provided by their qualified custodian. 14. Client Referrals and Other Compensation Supervised persons of NAI are employed by a certified public accounting and consulting firm as disclosed in Item 10. NAI does not participate in compensation that a client may pay for accounting, consulting, or insurance services. NAI has entered into written agreements with other individuals (hereinafter referred to as promoters) under which promoters will refer clients to NAI and NAI will provide such clients with financial services for its customary fees. Promoters will be paid fees, commonly referred to as finder’s fees, for such referrals by NAI. The amount is based on a percentage of fees received by NAI from the accounts they introduce. The payment of such fees does not result in additional costs to the client and will be in compliance with federal regulations as set forth in Rule 206(4)-1 of the Investment Advisers Act of 1940 - at the time of the initial referral, the promoter will disclose   the nature of the relationship between their practice and NAI; the material terms of their agreement with NAI, including the terms of compensation; and  any other material conflicts of interest on the part of the promoter resulting from their relationship with NAI and/or the compensation arrangement. The promoter will then provide the prospective client with a written disclosure of their referral relationship with NAI and will seek to obtain a written acknowledgement of such disclosure from the prospective client prior to NAI’s entering into an advisory contract. NAI will provide this Brochure and Form CRS. As disclosed under Item 12 above, NAI participates in Schwab’s institutional customer program and NAI may recommend Schwab to Clients for custody and brokerage services. There is no direct link between NAI’s participation in the program and the investment  F O R M A D V Part II - Page 14 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 advice it gives to its Clients, although NAI receives economic benefits through its participation that are typically not available to Schwab retail investors. These benefits include the use of products and services provided without cost or at a discount as detailed above. Schwab also has paid for business consulting and professional services received by NAI’s related persons. Some of the products and services made available by Schwab through the program may benefit NAI but may not benefit its Client accounts. These products or services may assist NAI in managing and administering Client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help NAI manage and further develop its business enterprise. The benefits received by NAI or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients, NAI endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by NAI or its related persons in and of itself creates a potential conflict of interest and may indirectly influence NAI’s choice of Schwab for custody and brokerage services. 15. Custody NAI does not maintain physical custody of any client funds or securities. However, the Firm is deemed to have custody of client assets despite not having physical custody in certain instances. For example, if clients authorize the Firm to deduct advisory fees directly from client accounts or clients establish certain standing letters of authorization (SLOAs) for the Firm to move money from an advisory account to a different account, NAI is deemed to have custody. NAI complies with certain safe harbor provisions that exempts the Firm from the annual surprise custody examination requirement for advisers that have custody due to the existence of SLOAs. Client assets are held by independent, third party custodians. Based on a client’s particular situation, NAI will recommend client assets be held at such organizations as SEI Private Trust, Charles Schwab & Co. and Vanguard because of their dedication to low transactional fees and high levels of client service. Clients may also elect to utilize another custody platform of their own choosing. Recommendation of custodial services is closely related to brokerage selection. Please see Items 12 and 14 for additional information.  F O R M A D V Part II - Page 15 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 16. Investment Discretion Consistent with Advisory Service Agreements executed with Clients, NAI will not execute a trade without a client’s prior authorization. 17. Voting Client Securities NAI does not vote client proxies. NAI may offer assistance to clients upon request. However, voting authority remains with the client. Clients receive proxies and other solicitations directly from their custodian for the securities held in the client’s account. 18. Financial Information NAI does not collect advisory fees in advance. We do not have discretionary authority over client assets. This means that any transactions are made with the client’s advance permission. NAI does not have custody of client funds or securities. Client assets are held in safekeeping at an independent custodian. Client statements and performance reports are also prepared by the independent third party custodian or service providers such as Orion. 19. Privacy Notice We are committed to maintaining the confidentiality of your private and confidential information and ensuring their secure safekeeping. We are providing this information to you in order that you may understand how we use your personal and financial information that you have provided to us. Specifically, we wish to inform you as to how we collect, share and protect your confidential information. How we collect and types of information we collect about you We collect certain information when you provide information to us or your custodian or other service providers provide information to us. We collect this information from you for our discussions with you, from documents that you may deliver to us and in the ordinary course of providing advisory services for you. This information may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, net worth, sources of your wealth, income, employment information, wire transfer instructions, investment experience, and risk tolerance. How we handle your personal information  F O R M A D V Part II - Page 16 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 We do not disclose any nonpublic personal information about our clients to any affiliates or nonaffiliated third parties except disclosures for everyday business purposes, such as to process transactions for your account, to maintain your accounts, as authorized by you, or as permitted or required by law. We may also disclose nonpublic personal information to the following nonaffiliated third party service providers in order for them to provide their services to us: ● administrators ● regulatory compliance consultant ● a(cid:425)orneys ● accountants We require such nonaffiliated third parties to protect the confidentiality of your nonpublic personal information and to use the information only for purposes for which it is disclosed to them. How we safeguard your personal information We restrict access to information about you to those Supervised Persons and service providers who need to know the information in order to provide services to you. To protect your nonpublic personal information, we maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your information. We adhere to the policies and practices described herein regardless of whether you are a current or former client. Can you limit how we share your information? Given we only provide information to those parties you have authorized, are necessary service providers, or as required by law, you cannot limit how we share your information although you can instruct us in writing to cease sharing information with any party you previously authorized. It is necessary for us to share your nonpublic information in order to effectively service your account. Questions? If you have any questions concerning any information in this privacy notice or how we collect, share or protect your information, please call Michael Devine or Rebecca Proetto at 610-240-7955 or email at advice@northeastadvisers.com.  F O R M A D V Part II - Page 17 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Form ADV Part 2B Brochure Supplement March 2025 Advisers: J. Michael Devine Eric J. Bleiler, CPA/PFS CFP® Rebecca Proetto, CPA, CFP® Sarah Cardamone Contact Information: Northeast Advisers, Inc. 163 W. Lancaster Ave. Paoli, PA 19301 610-240-7955 Toll Free: 800-971-7039 advice@northeastadvisers.com www.northeastadvisers.com Education and business standards have been established by NAI for those individuals involved in determining investment advice provided to clients. Requirements may include successful completion of FINRA Series 65, Series 7, and/or Series 63 examinations, typically 5 years of investment experience, and/or attainment or pursuit of professional designations including MSFS, CPA, or CFP®. This brochure supplement provides information about the individuals above that supplements Northeast Advisers, Inc. (NAI)’s ADV Part 2A. You should have received a copy of that brochure. Please contact Michael Devine, President and CEO of NAI at 610-240-7955 if you did not receive Northeast Advisers, Inc. brochure (Part 2A), or if you have any questions about the contents of this supplement. Additional information about our advisory representatives is available on the SEC’s website at www.adviserinfo.sec.gov. Free and simple tools are available to you to review Northeast Advisers, Inc. and its financial professionals at Investor.gov/CRS, which also provides free education materials about broker-dealers, investment advisers, and investing.  F O R M A D V Part II - Page 18 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 J. Michael Devine Educational Background and Business Experience Year of Birth: Education: 1955 St. Joseph’s University, 1977, BS College for Financial Planning, 1993, MS Finance, MS Retirement Planning Center for Fiduciary Studies, Accredited Investment Fiduciary®4, 2016 Business Background: Northeast Advisers, Inc., President and CEO, June 2000-Present Disciplinary Information There are no legal or disciplinary events to report. To verify disciplinary history, please see http://www.adviserinfo.sec.gov/. Other Business Activities No other business activities. Additional Compensation Michael Devine does not receive bonuses based on sales or new accounts and does not receive any additional compensation for advisory services other than the compensation paid by Northeast Advisers, Inc. Supervision Michael Devine is President and CEO of NAI. Rebecca Proetto and Michael Devine supervise other advisors associated with our firm. This is conducted by quarterly compliance reports, personal transaction reports and annual holdings reports. Mr. Devine also monitors advice provided to clients by constant communications (via phone, email, fax) with the supervised persons, keeping in mind the client’s objectives and investment goals. Mr. Devine’s compliance reports, personal transactions and annual holdings are reviewed by Rebecca Proetto, CPA, CFP®, Chief Compliance Officer and an advisory representative of NAI. Mrs. Proetto can be reached at 610-240-7955.  F O R M A D V Part II - Page 19 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Eric J. Bleiler, CPA1/PFS2, CFP®3 Educational Background and Business Experience Year of Birth: Education: 1975 Bloomsburg University, 1998, BS-Business Administration/Accounting, BS-Political Science American College, 2005, CFP® Business Background: Eric J. Bleiler, CPA & Co., LLC, 2018 - Present CERTIFIED FINANCIAL PLANNER® practitioner, 2003 – Present Northeast Advisers, Inc, 2022- Present JK Financial Advisory Services, CERTIFIED FINANCIAL PLANNER® Practitioner, 2010 – 2020 JonesKohanski & Co., P.C., Certified Public Accountant, 2002 – 2018, Disciplinary Information There are no legal or disciplinary events to report. To verify disciplinary history, please see http://www.adviserinfo.sec.gov/. Other Business Activities Mr. Bleiler is the owner and president of Eric J. Bleiler, CPA & Co., LLC accounting firm. At Eric J. Bleiler, CPA & Co., he is compensated for his accounting and insurance services by way of his ownership interest. NAI does not receive a portion of this compensation or have any ownership or control of this entity. Additional Compensation Mr. Bleiler is compensated as a salaried employee by Northeast Advisers, Inc. for his work as an IAR. Mr. Bleiler does not receive bonuses based on sales or new accounts and does not receive any additional compensation for advisory services other than the compensation paid by NAI. Supervision Mr. Bleiler is supervised by Rebecca Proetto, CPA, CFP®, Chief Compliance Officer of Northeast Advisers, Inc. This is conducted by quarterly compliance reports, personal transaction reports and annual holdings reports. Mr. Devine also monitors advice provided to clients by constant communications (via phone, email, fax) with Mr. Bleiler, keeping in mind the client’s objectives and investment goals. Mr. Devine and Mrs. Proetto can be reached at 610-240-7955.  F O R M A D V Part II - Page 20 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Rebecca Proetto, CPA1, CFP®3 Educational Background and Business Experience Year of Birth: Education: 1988 The Pennsylvania State University, 2012, BS – Accounting, BS – Finance, Masters – Accounting Center for Fiduciary Studies, Accredited Investment Fiduciary®4, 2016 Business Background: KPMG, Senior Associate, 2012-2015 Northeast Advisers, Inc., Chief Compliance Officer, Director of Client Services, June 2015 – Present CERTIFIED FINANCIAL PLANNER® practitioner, 2018 – Present Disciplinary Information There are no legal or disciplinary events to report. To verify disciplinary history, please see http://www.adviserinfo.sec.gov/. Other Business Activities No other business activities. Additional Compensation Mrs. Proetto is compensated as a salaried employee by Northeast Advisers, Inc. She does not receive bonuses based on sales or new accounts and does not receive any additional compensation for advisory services other than the compensation paid by NAI. Supervision Mrs. Proetto is supervised by Michael Devine, President and CEO of Northeast Advisers, Inc. This is conducted by quarterly compliance reports, personal transaction reports and annual holdings reports. Mr. Devine also monitors advice provided to clients by constant communications with Mrs. Proetto, keeping in mind the client’s objectives and investment goals. Mr. Devine can be reached at 610-240-7955.  F O R M A D V Part II - Page 21 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Sarah Cardamone Educational Background and Business Experience Year of Birth: Education: 1992 College of Charleston, 2014 BS- Business Administration with a Marketing Concentration College of Charleston, 2016 Masters- Communication Business Background: Charleston Battery, Director of Marketing & Public Relations, 2015-2019 United Soccer League, Communications & Public Relations Manager, 2019-2020 Northeast Advisers, Client Service Associate, 2021- Present Disciplinary Information There are no legal or disciplinary events to report. To verify disciplinary history, please see http://www.adviserinfo.sec.gov/. Other Business Activities No other business activities. Additional Compensation Ms. Cardamone is compensated as a salaried employee by Northeast Advisers, Inc. She does not receive bonuses based on sales or new accounts and does not receive any additional compensation for advisory services other than the compensation paid by NAI. Supervision Ms. Cardamone is supervised by Rebecca Proetto, CPA, CFP® Chief Compliance Officer of Northeast Advisers, Inc. This is conducted by quarterly compliance reports, personal transaction reports and annual holdings reports. Mr. Devine also monitors advice provided to clients by constant communications with Ms. Cardamone, keeping in mind the client’s objectives and investment goals. Mr. Devine and Mrs. Proetto can be reached at 610-240-7955.  F O R M A D V Part II - Page 22 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 Footnotes 1Certified Public Accountant (CPA) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education, minimum experience levels, and successful passage of the Uniform CPA Examination. Both Mr. Bleiler and Mrs. Proetto are licensed in Pennsylvania (PA) by the Pennsylvania State Board of Accountancy. Mr. Bleiler was required to have a minimum of 120 bachelor degree hours with at least 24 credits in accounting, business law, finance, micro or macroeconomics, or tax subjects sanctioned by the Pennsylvania State Board of Accountancy; complete two years (3,200 hours) of work experience through employment in government, industry, academia, or public practice; and pass the uniform CPA exam. Mrs. Proetto was required to have a minimum of 150 bachelor degree hours with at least 24 credits in accounting, business law, finance, micro or macroeconomics, or tax subjects sanctioned by the Pennsylvania State Board of Accountancy; complete one year (1,600 hours) of work experience through employment in government, industry, academia, or public practice; and pass the uniform CPA exam. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two year period or 120 hours over a three year period). The Pennsylvania State Board of Accountancy requires 80 hours over a two year period, with a minimum of 20 hours per year and 4 hours in Ethics. If you provide attest services, 24 hours must be in A&A. All American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. 120 continuing education hours must be completed over a rolling 3 year period. In addition to the Code of Professional Conduct, AICPA members who provide personal financial planning services are required to follow the Statement on Standards in Personal Financial Planning Services (SSPFPS). There are no continuing education requirements for the Pennsylvania Institute of Certified Public Accountants (PICPA). 2Personal Financial Specialist (PFS) The PFS credential demonstrates that an individual has met the minimum education, experience and testing required of a CPA in addition to a minimum level of expertise in personal financial planning. To attain the PFS credential, a candidate must hold an unrevoked CPA license, certificate, or permit, none of which are in inactive status; fulfill 3,000 hours of personal financial planning business experience; complete 75 hours of personal financial planning CPE credits; pass a comprehensive financial planning exam and be an active member of the AICPA. A PFS credential holder is required to adhere to AICPA’s Code of Professional Conduct and the Statement on Standards in Personal Financial Planning Services, when providing personal financial planning services. To maintain their PFS credential, the recipient must complete 60 hours of financial planning CPE credits every three years. The PFS credential is administered through the AICPA. 3CFP® The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States.  F O R M A D V Part II - Page 23 SEC File Number: 801-57720 Applicant: Northeast Advisers, Inc. Date: March 2025 To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. 4Accredited Investment Fiduciary® (AIF®) The AIF Designation certifies that the recipient has specialized knowledge of fiduciary standards of care and their application to the investment management process. To receive the AIF Designation, the individual must meet prerequisite criteria based on a combination of education, relevant industry experience, and/or ongoing professional development, complete a training program, successfully pass a comprehensive, closed-book final examination under the supervision of a proctor and agree to abide by the Code of Ethics and Conduct Standards. In order to maintain the AIF Designation, the individual must annually attest to the Code of Ethics and Conduct Standards, and accrue and report a minimum of six hours of continuing education. The Designation is administered by the Center for Fiduciary Studies, the standards-setting body of fi360.