Novem Group

Form ADV Part 2A – Firm Brochure Novem Group CRD #158964 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9525 www.novemgroup.com Updated: 02/27/2026 This document provides information about Novem Group. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have any questions on the contents of this document. Novem Group, is an SEC- Registered Investment Adviser and is notice-filed in the following states: AZ, CA, CO, CT, DC, FL, GA, IA, IL, KS, LA, MA, MD, ME, MI, NC, ND, NE, NH, NJ, NY, OH, OR, PA, RI, SC, TN, TX, VA, VT, WA. Additional information on Novem Group is available on the SEC’s website at www.adviserinfo.sec.gov. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. 1  Item 2: Material Changes Novem Group would like to report the following changes to this document since the firm’s most recent ADV amendment filed on 2/27/2026: E. Assets Under Management As of 1/1/2026, Novem Group has the following assets under management: Total Discretionary $1,454,929,528 Total Non-Discretionary $262,714,408 Total Assets Under Management $1,717,643,936 2  Item 3: Table of Contents 1 2 3 4 Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business A. Firm Description B. Types of Advisory Services C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs E. Assets Under Management Item 5: Fees and Compensation 5 A. Fee Schedule and Types of Fees B. Payment of Fees C. Clients are Responsible for Third Party Fees D. Prepayment of Fees E. Outside Compensation for the Sale of Securities to Clients a. Conflicts of Interest b. Advisory Fees in Addition to Commissions/Markups Item 6: Performance-Based Fees and Side-by-Side Management Item 7: Types of Clients Item 8: Methods of Analysis and Investment Strategies 6 7 7 A. Methods of Analysis B. Investment Strategies Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations 7 7 A. Registration as a Broker-Dealer or a Broker-Dealer Representative or Dual-Affiliation as an Investment Adviser Representative B. Registration Relationships Material to this Advisory Business C. Selection of Other Advisers or Managers Item 11: Code of Ethics, Participation/Interest in Client Transactions, Personal Trading 8 Investing Personal Money in the Same Securities as Clients A. Code of Ethics B. Recommendations Involving Material Financial Interests C. Item 12: Brokerage Practices 8 Investment Discretion A. Factors Used to Select Custodians B. Research and Soft-Dollar Benefits C. Block Trading D. Item 13: Review of Accounts 9 A. Frequency and Nature of Periodic Reviews B. Factors that will Trigger a Non-Periodic Review C. Regular Reports to Clients Item 14: Client Referrals and Other Compensation 9 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients B. Compensation to Solicitors for Client Referrals Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 10 10 10 10 A. Balance Sheet and Financial Conditions 3  Item 4: Advisory Business A. Firm Description Novem Group is organized as a corporation in the state of New York. The date of its inception is August of 2011, and the principal owner is Robert J. Bartolotta. B. Types of Advisory Services Novem Group offers the following services to its advisory clients: Investment Supervisory Services Includes ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Novem Group’s Investment Policy Statement within the client contract outlines the client’s current situation and allows the representative to construct a plan to aid in the selection of a portfolio to correspond with that client’s risk tolerance, time horizon, and investment objectives. Additional services include, but are not limited to, determining risk tolerance, developing investment strategies and asset allocations, and regular monitoring of accounts and portfolios. The current investments of each client are evaluated with respect to the client’s risk tolerance, investment time horizon, and other information related to suitability. Discretionary authority may be requested from clients in order to select securities and execute transactions without permission from the client beforehand. Representatives use tools and programs to determine a client’s risk tolerance and to run investment proposals. Financial Planning Financial planning may include, but is not limited to, investment planning, retirement planning, college planning, debt and credit planning, discussing tax concerns, and evaluating life insurance and assets outside of the management of the representative. The services and fee structures, if applicable, are outlined in Novem Group’s Advisory Services Agreement. Available fee structures include a flat fee (dollar amount or percentage of assets), an hourly rate, or a tiered fee schedule with a floating flat rate percentage based on an account/portfolio value. Selection of Other Advisers Novem Group may direct clients to third party money managers. This relationship will be disclosed in the contract between Novem Group and the third party. Novem Group will be compensated via a fee share from the manager to which it directs clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisers for clients, Novem Group will ensure the other adviser is properly licensed or registered. Services Limited to Specific Types of Investments Novem Group limits its investment advice and money management to mutual funds, ETFs, equities, bonds, fixed income, debt securities, options, REITs, and insurance products including annuities. Novem Group may use other securities to help diversify a portfolio. 4  C. Client Tailored Services and Client Imposed Restrictions Novem Group offers the same services to all its clients; however, specific client financial plans and their implementation are dependent upon the client’s contract. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs; however, if the restrictions prevent Novem Group or its representatives from properly servicing the account, or if the restrictions require Novem Group to deviate from its standard services, Novem Group reserves the right to end the relationship. D. Wrap Fee Program A wrap fee program is an investment program where the investor pays one stated fee that includes all management fees, transaction costs, fund expenses, and any other administrative fees. Novem Group sponsors a wrap fee program and offers both non-wrap and wrap portfolio management. The maximum total fee schedule is listed in Item 5.A. Clients who participate in the wrap fee program will not have to pay for transaction or trading fees of the custodian; however, clients are still responsible for all other fees. Compensation of Client Participation Other than advisory fees, Novem Group nor its representatives receive any additional compensation for the participant of clients in the wrap fee program. Compensation received may be more than what would have been received if the client paid separately for investment advice and other services; therefore, Novem Group and its representatives may have a financial incentive to recommend a wrap fee program. This relationship is reviewed periodically by the representative and the firm for suitability. E. Assets Under Management As of 1/1/2026, Novem Group has the following assets under management: Total Discretionary $1,454,929,528 Total Non-Discretionary $262,714,408 Total Assets Under Management $1,717,643,936 Item 5: Fees and Compensation A. Fee Schedule and Types of Fees Maximum Fee Schedule Total Assets Under Management Up to $250,000 $250,001 - $500,000 $500,001 - $1,000,000 $1,000,001 - $5,000,000 Over $5,000,0001 Maximum Annual Fee 2.50% 2.25% 2.00% 1.75% 1.50% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the actual fee is indicated in the client’s contract. Fees are paid quarterly in advance or in arrears, and clients may terminate their contracts with written notice at any time. Refunds are given on a pro-rated basis if possible and are based on the number of days remaining in a quarter at the point of termination. This may not be possible with outgoing transfers and will be reviewed on a case-by-case basis. 5  A client may terminate their contract, without penalty and for a full refund, within 5 business days of signing the contract. Types of Fees Available fee structures for financial planning include a flat fee (dollar amount or percentage of assets), an hourly rate, or a tiered fee schedule with a floating flat rate percentage based on an account/portfolio value. The type of fee structure depends upon the complexity of the situation and the needs of the client. B. Payment of Fees Advisory fees are withdrawn directly from the client’s account or invoiced to the client with client written authorization found in the client’s contract. Fees are paid quarterly in advance or in arrears. C. Clients are Responsible for Third Party Fees Clients are responsible for the payment of all third-party fees (e.g., custodial/vendor fees, brokerage fees, mutual funds fee, transaction fees, etc.). These fees are separate and distinct from the fees charged by Novem Group and its representatives. D. Prepayment of Fees Novem Group collects fees in advance or in arrears. Fees that were collected in advance will be refunded based on the prorated amount of work completed at the point of termination and/or the total days left in the billing period once the contract has been terminated. Any fee owed to the client will be returned to the client by check or deposited in an active investment account, depending on how the original fee was collected and if it is determined to be possible. E. Outside Compensation for the Sale of Securities to Clients a. Conflict of Interest Novem Group and its representatives will accept compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of funds to its clients. This presents a conflict of interest and gives the representative and Novem Group an incentive to recommend products based on the compensation received. When recommending the sale of securities or products for which Novem Group or its representatives receive compensation, the representative will document the conflict of interest in the client file and inform the client. Novem Group and its representatives have a fiduciary duty to keep the client’s best interest in mind. b. Advisory Fees in Addition to Commissions/Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-by-Side Management Novem Group does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation on the assets of a client. 6  Item 7: Types of Clients Novem Group provides investment advice and/or supervisory services to the following types of clients: Individuals Pension plans and profit-sharing plans Charitable organizations State or municipal government entities - - High net worth individuals - - - - Other Investment Advisers Item 8: Methods of Analysis and Investment Strategies A. Methods of Analysis Fundamental analysis - Involves the analysis of a company’s financial statements, financial health, and/or the analysis of management or competitive advantages, etc. to attempt to determine a company’s value and expected future earnings. This strategy may encourage trading in stocks that are undervalued. The risk assumed is that the market will fail to reach the expectation of the stock’s perceived value. Cyclical analysis - Involves the analysis of business cycles to attempt to determine favorable conditions for buying/selling a security. It assumes the markets react in cyclical patterns which, once identified, can be leveraged to provide positive performance. The risks associated with this strategy include that the markets do not always repeat cyclical patterns and if too many investors begin to implement it, the cycles may change. Technical analysis - Involves the analysis of statistics generated by market activity to identify patterns. Technical analysts do not attempt to measure a security’s intrinsic value, but instead use charts and other tools to identify the patterns to suggest future activity. The risks associated with this strategy include that if investors begin to use similar tools and follow the same concepts, it may lead to the prices moving in the predicted direction. Investment Strategies B. Novem Group and its representatives use long-term trading, short-term trading, and options trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Long-term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs. Short- term trading and options trading generally hold greater risk than long-term trading. Item 9: Disciplinary Information Novem Group does not have any criminal or civil actions, administrative proceedings, or self-regulatory organization proceedings to report. Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for more information. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or a Broker-Dealer Representative or Dual-Affiliation as an Investment Adviser Representative Investment Adviser Representatives of Novem Group may also be Registered Representatives of Osaic Wealth, Inc. and/or Investment Adviser Representatives of Osaic Advisory Services, LLC. 7  Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for more information. B. Registration Relationships Material to this Advisory Business Investment Adviser Representatives of Novem Group may also be Registered Representatives of Osaic Wealth, Inc., Investment Adviser Representatives of Osaic Advisory Services, LLC, and/or licensed insurance agents. From time to time, they will offer clients advice or products from these activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a Registered Investment Adviser. Novem Group and its representatives always act in the best interest of the client. Clients are in no way required to utilize the services of a representative of Novem Group in their outside capacities or outside business activities. Please refer to your representative’s Novem Group ADV Part 2B Individual Disclosure Brochure, the FINRA BrokerCheck website, and the SEC IAPD website for moreinformation. C. Selection of Other Advisers or Managers Novem Group may direct clients to third party money managers and this relationship will be disclosed in the contract between Novem Group and the third party. Novem Group will be compensated via a fee share from the manager to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. These fees are negotiable depending upon the needs of the client and the complexity of the situation. Fees are paid quarterly in advance or in arrears, and clients may terminate their contracts with written notice at any time. Item 11: Code of Ethics, Participation/Interest in Client Transactions, Personal Trading A. Code of Ethics Novem Group has a written Code of Ethics, which is available upon request. B. Recommendations Involving Material Financial Interests Novem Group does not recommend that clients buy or sell any security in which a related person to Novem Group or that Novem Group has a material financial interest in. Investing Personal Money in the Same Securities as Clients C. From time to time, representatives of Novem Group may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity to buy or sell the same securities before or after recommending them to clients, which may result in a profit from the recommendation provided to the client. Such transactions create a conflict of interest. Novem Group will document any transaction that may be construed as a conflict of interest and will ensure client business is transacted before the representative’s business when the same securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians The following factors are used when Novem Group selects a custodian: Capability to execute, clear, and settle trades or to facilitate this service Capability to facilitate timely transfers and payments to and from accounts Capability to assist with back-office functions, recordkeeping, and client reporting Availability of investment research and tools to assist in making investment decisions - - - - - Quality of service - Competitiveness of the price of services and willingness to negotiate the price 8  Reputation, financial strength, and stability Availability of educational conferences and events Consulting on technology, compliance, legal, and practice management - - - B. Research and Soft-Dollar Benefits Novem Group does not currently receive any soft-dollar benefits. Novem Group receives no referrals from a broker/dealer or other third party in exchange for using that broker/dealer or third party. Novem Group will not allow clients to direct Novem Group to use a specific broker/dealer to execute transactions. Clients must use the custodian recommended by Novem Group and its representatives. C. Block Trading Novem Group maintains the ability to block trade across accounts. Block trading may benefit a large group of clients by providing Novem Group with the ability to purchase larger blocks, which may result in a lower transaction cost to the client. Investment Discretion D. Novem Group has discretionary authority to determine securities and the dollar amount of securities to be bought or sold in a client’s account. This is indicated in the client’s contract. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews Accounts are reviewed at least semi-annually by Robert J. Bartolotta, Chief Executive Officer of Novem Group, with regard to the information indicated on the Investment Advisory Contract. Transactions are captured both by Schwab and Transaction Review Preparation (TR Prep or TRP), a platform of Osaic Wealth, Inc., and reviewed daily by the Investment Adviser Representative’s Principal. If unavailable, client statements are reviewed. B. Factors that will Trigger a Non-Periodic Review Non-periodic reviews may be triggered by material market, economic, or political events, or by changes in the client’s financial situation, such as retirement, termination of employment, inheritance, etc. C. Regular Reports to Clients Each client will receive a report at least quarterly from the custodian. This report details the client’s account(s), including assets held, asset value, and transaction history. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Novem Group receives an economic benefit from Schwab in the form of the support products and services it makes available to Novem Group and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which Novem Group would otherwise have to pay, including reimbursing termination fees when certain clients transfer assets to Schwab. Novem Group clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, Novem Group benefits from the arrangement because the cost of these services would otherwise be borne directly by Novem Group. Clients should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit Novem Group, and the related conflicts of interest are described 9  above see Item 12— Brokerage Practices. B. Compensation to Solicitors for Client Referrals Novem Group compensates other Investment Adviser Representatives for client referrals and a Solicitor’s Agreement will be provided when this occurs. Novem Group requires clients to sign the Notification of Solicitor’s Agreement form to acknowledge receipt of the agreement in place. Item 15: Custody Novem Group, with client written authority, has limited custody of client’s assets through direct fee deduction of fees only. If the client chooses to be billed directly to the custodian, Novem Group would have constructive custody over that account and will have written authority from the client to do so. Clients will receive account statements, which should be carefully reviewed for completeness and accuracy. Item 16: Investment Discretion For the client accounts where Novem Group provides ongoing supervision, the client has given Novem Group written discretionary authority over the accounts with respect to the securities to be bought or sold and the dollar amount of securities to be bought or sold. The details of this relationship are fully disclosed to the client before any advisory relationship has begun and this is indicated in the client’s contract. Item 17: Voting Client Securities Novem Group will not ask for, nor accept, voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet and Financial Conditions Novem Group does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Neither Novem Group nor any of its management have any financial conditions that may reasonably impair the ability to meet contractual commitments to its clients. Novem Group has not been the subject of a bankruptcy petition in the last ten years. 10 

Form ADV Part 2B – Individual Disclosure Brochure Kevin G. Albrecht Investment Adviser Representative CRD #1446140 Novem Group 1200 Route 22, Suite 2000 Bridgewater, NJ 08807 908-203-4641 kalbrecht@novemgroup.com Updated: 9/22/2025 This document provides information about Kevin G. Albrecht that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Kevin Albrecht is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Kevin G. Albrecht Born: 1962 Education: Ramapo College Bachelor of Science, Management Information Systems - 1985 Business Background (past 5 years) 5/2022 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealth, Inc. 4/2022 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 7/2021 – 4/2022 Registered Representative LPL Financial, LLC 12/2020 – 12/2021 Owner KAS Association Corporation 6/2020 – 7/2021 Associated Person/Insurance Agent Waddell & Reed, Inc 1/2014 – 6/2020 Investment Adviser Representative Cetera Investment Advisers, LLC Certifications SIE Series 7 Series 63 Series 65 Series 66 Securities Industry Essentials Examination General Securities Representative Examination Uniform Agent State Law Examination Uniform Investment Adviser Law Examination Uniform Combined State Law Exam Other Business Activities Kevin G. Albrecht is a Registered Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Additional Compensation Kevin G. Albrecht does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group.  Supervision As an Investment Adviser Representative, Kevin G. Albrecht works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Kevin Albrecht adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information Reporting Source: Firm Name: Termination Type: Termination Date: Allegations: Product Type: Individual LPL Financial, LLC Discharged 6/28/2022 Represented himself as clients on calls to annuity company to initiate contract distributions and revise distribution amount, with clients’ authorization. Annuity-Variable 

Form ADV Part 2B – Individual Disclosure Brochure Jeffrey B. Altieri Investment Adviser Representative CRD #862821 Novem Group 350 Linden Oaks, Ste 140 Rochester, NY 14625 585-203-1984 jaltieri@novemgroup.com 585-203-1984 Updated: 11/7/2025 This document provides information about Jeffrey B. Altieri that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Jeffrey B. Altieri is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Jeffrey B. Altieri Born: 1956 Business Background (past 5 years) 2/2021 – Present Investment Adviser Representative & Portfolio Manager Novem Group 5/2009 – 2/2021 Senior Vice President & Portfolio Manager RBC Capital Markets, LLC Certifications Series 65 – Uniform Investment Adviser Law Examination Other Business Activities Jeffrey B. Altieri is on the Board of Directors at Penfield Country Club. Additional Compensation Jeffrey B. Altieri does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Jeffrey B. Altieri works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Jeffrey B. Altieri adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information Reporting Source: Employing firm when occurred: Allegations: Product Type: Is this an arbitration? Docket/Case #: Filing date: Date Complaint Received: Complaint Pending? Status: Status Date: Settlement Amount: Individual Contribution Amount: Broker RBC Capital Markets, LLC Claimants allege they purchased unsuitable Puerto Rico bonds based on RBC’s misrepresentation, and were overcharged commissions on bonds, resulting in damages. Debt-Municipal Yes 20-00654 3/2/2020 9/20/2019 No Settled 10/13/2021 $199,000.00 $0.00 

Form ADV Part 2B – Individual Disclosure Brochure Robert J. Bartolotta Investment Adviser Representative CRD #1943239 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9521 rbartolotta@novemgroup.com Updated: 2/04/2026 This document provides information about Robert J. Bartolotta that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Robert J. Bartolotta is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Robert J. Bartolotta Born: 1966 Education: Cornell University Bachelor of Science, 1988 Business Background (past 5 years) 10/2024 – Present Investment Adviser Representative Osaic Wealth, Inc. 10/2024 – Present Senior Managing Partner, Registered Principal & Registered Representative Osaic Wealth, Inc. 3/2012 – Present Investment Adviser Representative Novem Group 8/2011 – Present Owner & CEO Novem Group 1/2007 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 9/2001 – 10/2024 Senior Managing Partner, Registered Principal & Registered Representative American Portfolios Financial Services, Inc. 1/1994 – Present Insurance Agent APFS Rochester, Inc. Certifications Series 6 Series 22 Series 24 Series 26 Series 51 Series 52 Series 62 Series 63 Series 65 Series 72 Series 82 Investment Company Products/Variable Contracts Representative Exam Direct Participation Programs Representative Exam General Securities Principal Exam Investment Company Products/Variable Contracts Principal Exam Municipal Fund Securities Principal Exam Municipal Securities Representative Exam Corporate Securities Limited Representative Exam Uniform Securities Agent State Law Exam Uniform Investment Adviser Law Exam Government Securities Representative Exam Limited Representative – Private Securities Offerings Other Business Activities Robert J. Bartolotta is a Senior Managing Partner, Registered Principal, Registered Representative, and an Investment Adviser Representative of Osaic Wealth, Inc., a licensed Insurance Agent of APFS Rochester, Inc. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent.  Robert J. Bartolotta is a board member of the Novem Foundation. Robert J. Bartolotta also owns rental properties. Additional Compensation Robert J. Bartolotta does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Robert J. Bartolotta works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Robert J. Bartolotta adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Thomas C. Burke Investment Adviser Representative CRD #1217162 Novem Group 350 Linden Oaks Suite 140 Rochester, NY 14625 (585) 419-2312 tburke@novemgroup.com Updated: 2/04/2026 This document provides information about Thomas C. Burke that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Thomas C. Burke is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Thomas C. Burke Born: 1961 Education: Cornell University Bachelor of Science in Applied Economics, 1983 Business Background 6/2016 – Present Investment Adviser Representative Novem Group 12/2014 – 10/2024 Non-Registered Assistant American Portfolios Financial Services, Inc. 6/2015 – 6/2016 VP of New Business Development APFS Wealth Management, Inc. 7/2009 – 12/2014 Self-employed 1/2003 – 7/2009 Registered Representative American Portfolios Financial Services, Inc. 2/1995 – 12/2002 Registered Representative Nathan & Lewis Securities, Inc. 12/1994 – 12/2001 Representative Aetna Investment Services, LLC 10/1993 – 3/1994 Representative Aetna Investment Services, Inc. 12/1983 – 10/1993 Agent Aetna Life Insurance & Annuity Co. Certifications Series 65 Uniform Investment Adviser Law Examination Series 66 Uniform Combined State Law Examination  Additional Compensation Thomas C. Burke does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Thomas C. Burke works closely with their supervisor and all advice provided to clients and account-related transactions is reviewed by their supervisor. Thomas C. Burke adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information Reporting Source: Firm Name: Inc. Product Type: Termination Type: Termination Date: Details: Individual American Portfolios Financial Services, No Product Voluntary Resignation 7/20/2009 The voluntary resignation was accepted while the representative’s files were under review for alleged discrepancies in client signatures 

Form ADV Part 2B – Individual Disclosure Brochure Cynthia M. Deal Investment Adviser Representative CRD #5138926 Novem Group 7 Grove Street, Ste 301 Topsfield, MA 01983 cdeal@topsfieldfinancial.com 978-887-6778 Updated: 02/10/2026 This document provides information about Cynthia M. Deal that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Cynthia M. Deal is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Cynthia M. Deal (Cyndi Deal) Born: 1962 Education: Boston University Bachelor of Science in Business Administration, 1984 Business Background (past 5 years) 10/2015 – Present Investment Advisor Representative Novem Group 10/2024 – 12/2024 Non-Registered Assistant Osaic Wealth, Inc. 11/2014 – 10/2015 Non-Registered Assistant Novem Group 11/2006 – 11/2014 Non- Registered Assistant American Portfolios Advisors, Inc 1/2006 – 10/2024 Non- Registered Assistant American Portfolios Financial Services, Inc. Certifications Series 65 Uniform Investment Adviser Law Exam Designations CFP® - Certified Financial Planner 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 83,000 individuals have obtained CFP® certification in the United States. • • 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. i. ii. 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. 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. Other Business Activities Cyndi Deal is an employee of Topsfield Financial Group. Cyndi Deal is also a volunteer of Generous Gardeners. Additional Compensation Cyndi Deal does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Cyndi Deal works closely with their supervisors and all advice provided to clients and account-related transactions are reviewed by their supervisors. Cyndi Deal adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Amanda R. Esteves Investment Adviser Representative CRD #5597000 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 aesteves@novemgroup.com Updated:02/10/2026 This document provides information about Amanda R. Esteves that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Compliance Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Amanda R. Esteves is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Amanda R. Esteves Born: 1984 Business Background (past 5 years) 10/2024 – Present Registered Principal & Registered Representative Osaic Wealth, Inc. 10/2013 – Present Investment Adviser Representative Novem Group 11/2019 – 10/2024 Chief Compliance Officer Novem Group 3/2015 – 10/2024 Registered Principal & Registered Representative American Portfolios Financial Services, Inc. Certifications Series 4 Series 7 Series 24 Series 63 Series 66 Registered Options Principal Exam General Securities Representative Exam General Securities Principal Examination Uniform Securities Agent State Law Examination Uniform Combined State Law Exam Other Business Activities Amanda R. Esteves is a Registered Principal and Registered Representative of Osaic Wealth, Inc., and a licensed insurance agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed insurance agent. Amanda R. Esteves is a current member of the Board of Directors of Novem Foundation. Additional Compensation Amanda R. Esteves does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Amanda R. Esteves works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Amanda R. Esteves adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements.  Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Thomas C. Froehlich Investment Adviser Representative CRD #1635098 Novem Group 900 Highway 71, Suite 2 Spring Lake Heights, NJ 07762 tom@froehlichfinancial.com 732-974-3770 Updated: 10/23/2025 This document provides information about Thomas C. Froehlich that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Thomas C. Froehlich is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Thomas C. Froehlich Born: 1957 Business Background (past 5 years) 10/2024– Present Investment Adviser Representative Osaic Wealth, Inc. 10/2024 – Present Registered Representative & Registered Principal Osaic Wealth, Inc. 7/2020 – Present Investment Adviser Representative Novem Group 3/2007 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 5/2005 – 10/2024 Registered Representative & Registered Principal American Portfolios Financial Services, Inc. 1/1997 – 11/2020 Owner and Principal Froehlich Financial Group, LTD Certifications Series 7 – General Securities Representative Examination Series 24 – General Securities Principal Examination Series 63 – Uniform Securities Agent State Law Examination Series 65 – Uniform Investment Adviser Law Examination Other Business Activities Thomas C. Froehlich is a Registered Representative and Registered Principal of Osaic Wealth, Inc. and an Investment Adviser Representative of Osaic Wealth, Inc. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or Investment Adviser Representative of another firm. Thomas C. Froehlich outsources group health insurance and P&C insurance services. Additional Compensation Thomas C. Froehlich does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Thomas C. Froehlich works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Thomas C. Froehlich adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies  and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information Reporting Source: Regulator Regulatory Action Initiated By: State of Wisconsin Securities Commissioner Date Initiated: Product Type: Allegations: Current Status: Resolution: Resolution Date: Sanctions Ordered: Sanction Details: Regulator Statement: Broker Statement: 3/9/1995 No product Failure to pay licensing fee Final Decision 3/9/1995 Suspension Summary suspension of securities agent license Wisconsin securities agent license was suspended on 3/9/95 for non-payment of the required $30 fee when the agent transferred to another Broker-Dealer. The fee was paid on 4/10/95 and the suspension was lifted. My agent license was suspended due to non-payment of agent licensing fees. Josephthal Lyon & Ross did not send in the payment in a timely fashion to the state hence my licensing suspension. 

Form ADV Part 2B – Individual Disclosure Brochure Mark P. Gatti Investment Adviser Representative CRD #1027529 Novem Group 7 Grove Street, Suite 301 Topsfield, MA 01983 mgatti@topsfieldfinancial.com 978-887-9546 Updated: 02/10/2026 This document provides information about Mark P. Gatti that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Mark P. Gatti is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Mark P. Gatti Born: 1956 Education: Fitchburg State University Bachelor of Science in Education, 1978 Business Background 11/2020 – Present Investment Adviser Representative Novem Group 1/1986 – Present Owner & Agent Mark Gatti DBA T&FM Group 10/2024 – 12/2024 Registered Representative Osaic Wealth, Inc. 1/2002 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 2/2002 – 5/2021 Investment Adviser Representative American Portfolios Advisors, Inc. Certifications Series 6 – Investment Company Products/Variable Contracts Representative Examination Series 7 – General Securities Representative Examination Series 63 – Uniformed Securities Agent State Law Examination Designations CFP® - Certified Financial Planner 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 83,000 individuals have obtained CFP® certification in the United States. • 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. i. ii. 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. 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. Other Business Activities Mark P. Gatti offers tax preparation services through his own business, and is an Enrolled Agent, which is an IRS designation allowing representation of clients. Additional Compensation Mark P. Gatti does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Mark P. Gatti works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Mark P. Gatti adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Andrew L. Gentile Investment Adviser Representative CRD #1199626 Novem Group 601 Heritage Drive Suite 220 Jupiter, FL 33458 (585) 348-9525 agentile@novemgroup.com Updated: 12/31/2025 This document provides information about Andrew L. Gentile that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Compliance Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Andrew L. Gentile is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Andrew L. Gentile Born: 1961 Education: Fordham University Bachelor of Arts in Economics, 1983 Business Background (past 5 years) 4/2019 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealth, Inc. 4/2019 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 2/2010 – 4/2019 Registered Representative The Leaders Group, Inc. 2/2010 – 4/2019 Investment Adviser Representative TLG Advisors, Inc. Certifications SIE Series 6 Series 7 Series 22 Series 24 Series 51 Series 63 Series 65 Securities Industry Essentials Exam Investment Company Products/Variable Contracts Representative Exam General Securities Representative Exam Direct Participation Programs Representative Exam General Securities Principal Exam Municipal Fund Securities Principal Exam Uniform Securities Agent State Law Exam Uniform Investment Adviser Law Exam Designations ChFC® – Chartered Financial Consultant The ChFC® designation is offered by The American College of Financial Services. To receive the ChFC® designation, an individual must successfully complete all courses and exams, meet experience requirements and ethics standards, and agree to comply with The American College Code of Ethics and Procedures. Participation in the Professional Recertification Program is also required. CFP® - Certified Financial Planner 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 62,000 individuals have obtained CFP® certification in the United States. 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, administered in 10 hours over a two-day period, 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: i. ii. 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. 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. Other Business Activities Andrew L. Gentile is a Registered Representative of Osaic Wealth, Inc., and a licensed Insurance Agent, placing insurance and annuity business through Millenium Brokerage Group, Pinnacle Insurance, and Advisors Academy. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Andrew L. Gentile is the owner of Fair Share Divorce Solutions, a divorce consulting business. Andrew L. Gentile serves as a Finance Committee Member at Tequesta Country Club. Andrew L. Gentile is a board member of the Fellowship of Christian Athletes (FCA). Additional Compensation Andrew L. Gentile does not receive any economic benefit from any person, company, or organization, other than  Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Andrew L. Gentile works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Andrew L. Gentile adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information Regulatory – Final (1 of 1) Broker Reporting Source: Regulatory Action Initiated By: Florida Office of Financial Regulation Cease and Desist; Denial Sanction(s) Sought: 4/10/2019 Date Initiated: 92741-SR Docket/Case Number: Employing firm when activity occurred which led to the regulatory action: TLG Advisors, Inc. No Product Failure to disclose a reportable event on the U4 when applying for a Florida Final Order Product Type: Allegations: investment advisor registration Current Status: Resolution: Does the order constitute a final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Resolution Date: Sanctions Ordered: Broker Statement: No 4/10/2019 Cease and Desist; Denial Due to an administrative error on my part, I did not disclose my felony arrest. I was given incorrect information from my former broker-dealers chief compliance officer. After denial, I immediately disclosed the event as required on my U4 and I was permitted to reapply for my Florida investment advisor registration. Criminal – Final Disposition (1 of 1) Broker Reporting Source: Formal Charges were brought in: State Court Gwinnet County Lawrenceville, GA 2018D-03389-1 8/28/2017 Criminal Damage to Property 1 Felony None – Trial Diversion Reduced 4/11/2018 Name of Court: Location of Court: Docket/Case #: Charge Date: Formal Charge/Description: No of Counts: Felony or Misdemeanor: Plea for each charge: Disposition of charge: Date of Amended Charge: Charge was Amended or reduced to: Misdemeanor – Criminal damage to property in second degree 1 None – Trial Diversion Amended No of Counts: Amended Plea: Disposition of Amended Charge:  Current Status: Status Date: Disposition Date: Sentence/Penalty: Broker Statement: Pre-trial Intervention Final 9/10/2018 9/10/2018 Pre-trial diversion My wife and I were arguing over a cell phone and whose was it. A stranger witnessed the situation and called the police. The phone’s screen broke, and I was charged with a felony for criminal damage to property because the phone was valued over $500.00. I should have not been charged with any offenses as I owned the phone and it cost $115.00 to repair. The charge was dropped to a misdemeanor and was expunged from my record. It was an unfortunate situation which resulted in me having to report it on my U4. Financial – Final (1 of 1) Broker Compromise 5/1/2018 No Discharged 8/28/2017 SPS Mortgage $1,140,000.00 Reporting Source: Action Type: Action Date: Action Pending? Disposition: Disposition Date: Name of Creditor: Original Amount Owed: Terms Reached with Creditor: None Broker Statement: An unwanted divorce led to a forced sale of the home and the mortgage was greater than the home value and we were forced to foreclose. We had previously used $500,000 of the equity to pay for my wife’s chronic disease treatments which were not covered by our insurance. In addition, the home was valued at $1,700,000 in 2006, $850,000 in 2009 and was sold by Bank for 884,000. The large home market in Atlanta never recovered. 

Form ADV Part 2B – Individual Disclosure Brochure Timothy D. Gerlach Investment Adviser Representative CRD #5798376 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 tgerlach@novemgroup.com Updated: 9/22/2025 This document provides information about Timothy D. Gerlach that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Timothy D. Gerlach is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Timothy D. Gerlach Born: 1989 Education: Pennsylvania State University Bachelor of Science, Finance, 2010 Master of Science, Finance, 2014 Business Background (past 5 years) 05/2023 – Present Portfolio Manager Novem Group 11/2018 – 05/2023 Director of Asset Management & Investment Adviser Representative Novem Group 1/2015 – 11/2018 Deloitte Consulting, LLP Senior Consultant Certifications Series 65 Uniform Investment Adviser Law Exam Other Business Activities Timothy D. Gerlach is affiliated with Osaic, Inc. as a Non-Registered Assistant. Additional Compensation Timothy D. Gerlach does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Timothy D. Gerlach works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Timothy D. Gerlach adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Torrey J. Giancursio Investment Adviser Representative CRD #5877096 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 tgiancursio@fourbridgesfinancial.com Updated: 9/22/2025 This document provides information about Torrey J. Giancursio that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Torrey J. Giancursio is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Torrey J. Giancursio Born: 1986 Business Background (past 5 years) 3/2022 – Present Investment Adviser Representative Novem Group 10/2024 – Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 7/2016 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 7/2016 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 6 Series 7 (SIE) Series 63 Series 65 Investment Company Products/Variable Contracts Representative Examination General Securities Representative Exam (Securities Industry Essentials Examination) Uniform Securities Agent State Law Examination Uniform Investment Adviser Law Examination Other Business Activities Torrey J. Giancursio is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Torrey J. Giancursio is the owner of FourBridges Financial Services. Torrey J. Giancursio is the owner of Giancursio Farms, Inc. Torrey J. Giancursio is the owner of Giancursio Excavating, Inc. Additional Compensation Torrey J. Giancursio does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Torrey J. Giancursio works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Torrey J. Giancursio adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements.  Disciplinary Information Reporting Source: Judgment/Lien Holder: Judgment/Lien Amount: Judgment/Lien Type: Date Filed with Court? Date Individual Learned: Type of Court: Name of Court: Location of Court: Docket/Case#: Judgment/Lien Outstanding? Broker Statement: Individual New York State $85,777.06 Tax 3/25/2025 3/31/2025 State Court New York State, Monroe County Monroe County, NY E-045828139-NCOS-E Yes Notified by debt collector. Supposedly certified mail was sent to an address I haven’t lived at since 7 tax returns ago. I am contesting the tax lien because the amount I paid matches the tax return I filed on time for year 2020. 

Form ADV Part 2B – Individual Disclosure Brochure Catherine E. Gueli Investment Adviser Representative CRD #7058910 Novem Group 350 Linden Oaks Suite 140 Rochester, NY 14625 (585) 348-9227 cgueli@novemgroup.com Updated: 02/23/2026 This document provides information about Catherine E. Gueli that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Catherine E. Gueli is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Catherine E. Gueli (Cathy Gueli) Born: 1966 Education: Boston University Bachelor of Science, Aerospace Engineering, 1988 University of Dayton Master of Business Administration, 1992 Business Background (past 5 years) 9/2024 – Present Investment Adviser Representative Novem Group 06/2019 – 09/2024 Employee of an affiliate City National Bank 03/2019 – 09/2024 Investment Adviser Representative RBC Capital Markets, LLC 02/2019 – 09/2024 Registered Representative RBC Capital Markets, LLC. 12/1998 – 12/2018 Vice President of Strategy Xerox Corporation Certifications SIE Series 7TO Series 66 Securities Industry Essentials Examination General Securities Representative Examination Uniform Combined State Law Examination Designations CFP® - Certified Financial Planner 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 62,000 individuals have obtained CFP® certification in the United States. 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, administered in 10 hours over a two-day period, 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: i. ii. 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. 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. Other Business Activities Catherine E. Gueli owns an Airbnb rental property that she handles the booking requests for. Catherine E. Gueli is a member of the Board of Directors for the Rochester Philharmonic Orchestra. Catherine E. Gueli is the Secretary for the Board of Directors for Full Circle Home. Additional Compensation Catherine E. Gueli does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Catherine E. Gueli works closely with their supervisor and all advice provided to clients and account-related transactions is reviewed by their supervisor. Catherine E. Gueli adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Charles G. Herendeen Investment Adviser Representative CRD #2786225 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 cherendeen@novemgroup.com Updated: 9/30/2025 This document provides information about Charles G. Herendeen that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Charles G. Herendeen is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Charles G. Herendeen Born: 1972 Education: State University of New York at Geneseo Bachelor of Science in Accounting, 1995 Business Background (past 5 years) 10/2024 – Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 8/2011 – Present Investment Adviser Representative Novem Group 11/2009 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 3/2006 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 6 Series 63 Series 65 Investment Company Products/Variable Contracts Representative Exam Uniform Securities Agent State Law Exam Uniform Investment Adviser Law Exam Designations AIF® - Accredited Investment Fiduciary Advisors who have earned the Accredited Investment Fiduciary designation are able to immediately show that they are interested in and working towards the best interests of their clients. They have gone through training, met the qualifications, and passed the exam allowing use of the AIF® designation. Qualifications: There are four requirements for attaining the AIF® designation: 1.Enroll in and complete the AIF® Training 2.Pass the AIF® Examination The examination is a computer-based, timed, closed-book assessment that must be attempted unaided in the presence of a proctor. The designation examinations consist of: •AIF® examination consists of sixty (60) multiple choice questions with a time-limit of ninety (90) minutes. A paper-based examination is available upon prior arrangement by Fi360 or the exam taker, and may only be proctored by Fi360 personnel. 3.Meet the experience requirement One of the following combinations of education, industry experience, and/or professional development is required to meet the experience requirement for the AIF® designation. Relevant experience is that which has been accrued in a non-clerical role within the financial services (or a related) industry. •Minimum of two (2) years of relevant experience; a bachelor’s degree (or higher); and a professional credential. •Minimum of five (5) years of relevant experience; a bachelor’s degree (or higher) or a  professional credential. •Minimum of eight (8) years of relevant experience. 4.Submit the application and dues Included in the application are sections to attest to both the Code of Ethics and Conduct Standards. The Code of Ethics consists of the tenets of ethical conduct expected of all credential holders, while the Conducts Standards pertain to any past criminal and civil litigation, regulatory events, and personal and professional conduct. Continuing Education Requirement: AIF® designees must accrue a minimum of six hours of continuing education annually. The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. Other Business Activities Charles G. Herendeen is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed insurance agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed insurance agent. Charles G. Herendeen is currently a board member for the New York Employee Benefits Conference (NYEBC). Additional Compensation Charles G. Herendeen does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Charles G. Herendeen works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Charles G. Herendeen adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Kimberley Kosko Investment Adviser Representative CRD #7246418 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9542 kkosko@novemgroup.com Updated: 5/30/2025 This document provides information about Kimberley Kosko that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Kimberley Kosko is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Kimberley Kosko Born: 1987 Education: Kimberley Kosko has not received any higher education degrees after high school. Business Background (past 5 years) 03/2025 – Present Investment Advisor Representative Novem Group Non-Registered Assistant 10/2024 – Present Osaic Wealth, Inc. Certifications Series 65 Uniform Investment Adviser Law Exam Other Business Activities Kimberley Kosko is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Kimberley Kosko does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Kimberley Kosko works closely with their supervisors and all advice provided to clients and account-related transactions are reviewed by their supervisors. Kimberley Kosko adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Bruce T. Lear Investment Adviser Representative CRD #2512908 Novem Group 2032 Brentwood Boulevard Grand Island, NE 68801 308-698-2041 blear@5pointsfinancial.com Updated: 02/10/2026 This document provides information about Bruce T. Lear that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Bruce T. Lear is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Bruce T. Lear Born: 1966 Education: University of Nebraska Bachelor of Arts in University Studies, 1989 Business Background (past 5 years) 1/2019 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealth, Inc. 1/2019 – Present Employee Five Points Bank & Five Points Financial Services 1/2012 – Present Insurance Agent 1/2019 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 4/2012 – 1/2019 Investment Advisor Securities America Advisors, Inc. 4/2012 – 1/2019 Registered Representative Securities America, Inc. Certifications Series 7 Series 66 General Securities Representative Exam Uniform Combined State Law Exam Other Business Activities Bruce T. Lear is a Registered Representative of Osaic Welath, Inc. and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Bruce T. Lear is an employee of Five Points Bank and Five Points Financial Services. He is a Youth Coach for the Kearney Soccer Club, and a Coach for the Kearney Catholic High School Girls’ Soccer. Additional Compensation Bruce T. Lear does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group.  Supervision As an Investment Adviser Representative, Bruce T. Lear works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Bruce T. Lear adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisor’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Patrick D. Manuel Investment Adviser Representative CRD #5198707 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 pmanuel@novemgroup.com Updated: 9/29/2025 This document provides information about Patrick D. Manuel that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Patrick D. Manuel is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Patrick D. Manuel Born: 1984 Education: University of Rochester Bachelor of Arts in Economics, 2006 Business Background (past 5 years) 10/2024 – Present Registered Representative Osaic Wealth, Inc. 1/2014 – Present Investment Adviser Representative Novem Group 10/2013 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 7 Series 66 General Securities Representative Exam Uniform Combined State Law Exam Designations AIF® - Accredited Investment Fiduciary Advisors who have earned the Accredited Investment Fiduciary designation are able to immediately show that they are interested in and working towards the best interests of their clients. They have gone through training, met the qualifications, and passed the exam allowing use of the AIF® designation. Qualifications: There are four requirements for attaining the AIF® designation: 1.Enroll in and complete the AIF® Training 2.Pass the AIF® Examination The examination is a computer-based, timed, closed-book assessment that must be attempted unaided in the presence of a proctor. The designation examinations consist of: •AIF® examination consists of sixty (60) multiple choice questions with a time-limit of ninety (90) minutes. A paper-based examination is available upon prior arrangement by Fi360 or the exam taker and may only be proctored by Fi360 personnel. 3.Meet the experience requirement One of the following combinations of education, industry experience, and/or professional development is required to meet the experience requirement for the AIF® designation. Relevant experience is that which has been accrued in a non-clerical role within the financial services (or a related) industry. •Minimum of two (2) years of relevant experience; a bachelor’s degree (or higher); and a professional credential. •Minimum of five (5) years of relevant experience; a bachelor’s degree (or higher) or a professional credential. •Minimum of eight (8) years of relevant experience. 4.Submit the application and dues Included in the application are sections to attest to both the Code of Ethics and Conduct Standards. The Code of  Ethics consists of the tenets of ethical conduct expected of all credential holders, while the Conducts Standards pertain to any past criminal and civil litigation, regulatory events, and personal and professional conduct. Continuing Education Requirement: AIF® designees must accrue a minimum of six hours of continuing education annually. The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. Other Business Activities Patrick D. Manuel is a Registered Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a registered representative or licensed insurance agent. Patrick D. Manuel is on the Board of Directors and Chair of the Finance Committee for CDS Monarch and CDS Life Transitions. He is also a Board Member on the Italian Heritage Foundation and Novem Group Foundation. He is also a member of ADK Guys, LLC in furniture sales. Additional Compensation Patrick D. Manuel does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Patrick D. Manuel works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Patrick D. Manuel adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Joseph G. McPherson Investment Adviser Representative CRD #1278496 Novem Group 5135 Transit Rd Suite 2 Depew, NY 14043 716-684-5855 jmcpherson@OsaicWM.com Updated: 9/19/2025 This document provides information about Joseph G. McPherson that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Joseph G. McPherson is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Joseph G. McPherson (Joe McPherson) Born: 1960 Business Background (past 5 years) 9/2024 – Present Investment Adviser Representative Novem Group 10/2024 – Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 4/1996 – Present Insurance Agent McPherson Financial Services 3/2010 – 10/2024 Investment Adviser Representative American Portfolios Advisors 2/2004 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications SIE Series 6 Series 62 Series 63 Securities Industry Essentials Examination Investment Company Products/Variable Contracts Representative Exam Corporate Securities Limited Representative Examination Uniform Securities Agent State Law Examination Designations ChFC® – Chartered Financial Consultant The ChFC® designation is offered by The American College of Financial Services. To receive the ChFC® designation, an individual must successfully complete all courses and exams, meet experience requirements and ethics standards, and agree to comply with The American College Code of Ethics and Procedures. Participation in the Professional Recertification Program is also required. CFP® - Certified Financial Planner 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 62,000 individuals have obtained CFP® certification in the United States.  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, administered in 10 hours over a two-day period, 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: i. ii. 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. 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. Other Business Activities Joseph G. McPherson is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed Insurance Agent with McPherson Financial Services, placing fixed life, annuity, and long-term care insurance through various companies. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Joseph G. McPherson is a tax practitioner at A/C Associates. Additional Compensation Joseph G. McPherson does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group.  Supervision As an Investment Adviser Representative, Joseph G. McPherson works closely with their supervisors and all advice provided to clients and account-related transactions are reviewed by their supervisors. Joseph G. McPherson adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Adam C. Morgan Investment Adviser Representative CRD #5473273 Novem Group 2300 Buffalo Road Bldg 500A Rochester, NY 14624 (585) 348-9537 amorgan@novemgroup.com Updated: 5/23/2025 This document provides information about Adam C. Morgan that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Adam C. Morgan is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Adam C. Morgan Born: 1984 Education: Alfred University Bachelor of Science in Mechanical Engineering and Business Administration, 2006 Business Background (past 5 years) 10/2014 – Present Investment Adviser Representative Novem Group 10/2024 – Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 10/2014 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 10/2014 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 7 Series 66 General Securities Representative Exam Uniform Combined State Law Exam Designations CFP® - Certified Financial Planner 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 62,000 individuals have obtained CFP® certification in the United States. • • • • 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, administered in 10 hours over a two-day period, 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.  i. ii. 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. 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. Other Business Activities Adam C. Morgan is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a registered representative or licensed Insurance Agent. Adam C. Morgan is the owner of Millennial Wealth, Inc., which is used for business expenses and accounting purposes as well as a conduit for himself when placing fixed life, disability and long-term care insurance as a licensed insurance agent. He is a member of KI & Morgan, LLC., which owns real estate property. Additional Compensation Adam C. Morgan does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Adam C. Morgan works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Adam C. Morgan adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Colin J. Murray Investment Adviser Representative CRD #7374714 Novem Group 2032 Brentwood Boulevard Grand Island, NE 68801 308-698-2041 cmurray@5pointsfinancial.com Updated: 10/23/2025 This document provides information about Colin J. Murray that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Colin J. Murray is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Colin J. Murray Born: 2001 Education: University of Nebraska at Kearney Business Administration, 2023 Business Background (past 5 years) 2/2023 – Present Investment Adviser Representative Novem Group 10/2024 - Present Registered Representative Osaic Wealth, Inc. 2/2023 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 8/2020 – 1/2024 Student University of Nebraska at Kearney 6/2020 – 1/2024 Intern Five Points Bank & Five Points Financial Services 8/2016 – 5/2020 Student Kearney High School Certifications SIE S7TO Series 63 Series 66 Securities Industries Essentials Exam Series 7 Top Off Exam Uniform Securities Agent State Law Exam Uniform Combined State Law Exam Other Business Activities Colin J. Murray is a Registered Representative of Osaic Wealth, Inc. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or bank intern. Additional Compensation Colin J. Murray does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Colin J. Murray works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Colin J. Murray adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements.  Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Vincent J. Palumbos Investment Adviser Representative CRD #3220021 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9423 vpalumbos@novemgroup.com Updated: 11/20/2025 This document provides information about Vincent J. Palumbos that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Vincent J. Palumbos is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Vincent J. Palumbos Born: 1944 Education: Cambridge College, 1987 Master of Education Business Background (past 5 years) 11/2017 – Present Investment Adviser Representative Novem Group 8/2016 – 12/2023 Investment Adviser Representative American Portfolios Advisors, Inc. 8/2016 – 12/2023 Registered Representative American Portfolios Financial Services, Inc. Certifications SIE Series 7 Series 24 Series 63 Series 65 Securities Industry Essentials Examination General Securities Representative Examination General Securities Principal Examination Uniform Securities Agent State Law Examination Uniform Investment Adviser Law Examination Other Business Activities Vincent J. Palumbos is also a Pilot and Safety Officer with the Civil Air Patrol. Additional Compensation Vincent J. Palumbos does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Vincent J. Palumbos works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Vincent J. Palumbos adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Jeremy T. Raco Investment Adviser Representative CRD #2641148 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 jraco@novemgroup.com Updated: 9/22/2025 This document provides information about Jeremy T. Raco that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Jeremy T. Raco is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Jeremy T. Raco Born: 1969 Business Background 2/2013 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealth, Inc. 2/2013 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 6 Series 63 Investment Company Products/Variable Contracts Representative Exam Uniform Securities Agent State Law Exam Other Business Activities Jeremy T. Raco is a Registered Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Additional Compensation Jeremy T. Raco does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Jeremy T. Raco works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Jeremy T. Raco adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Jordan A. Reinertson Investment Adviser Representative CRD #7639069 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 jreinertson@5pointsfinancial.com Updated: 02/10/2026 This document provides information about Jordan A. Reinertson that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Jordan A. Reinertson is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Born: Education: Jordan Reinertson 1989 University of Nebraska-Lincoln, 2013 Bachelor of Science in Business Administration Bachelor of Science in Education and Human Sciences Business Background (past 5 years) 9/2022 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealh, Inc. 8/2022 – Present Financial Advisor Five Points Bank 9/2022 – 10/2024 Registered Representative American Portfolios Advisors, Inc. 8/2020 - 7/2022 High School Business Teacher Kearney Public School District 8/2015 – 7/2020 High School Business Teacher Minden Public School District Certifications Series 7TO & SIE Series 66 General Securities Representative & Securities Industry Essentials Examinations Uniform Securities Agent State Law Examination Other Business Activities Jordan A. Reinertson is a Registered Representative of Osaic Wealth, Inc., and employee of Five Points Bank. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative. Jordan A. Reinertson is also a High School Basketball Official and Golf Instructor. Additional Compensation Jordan A. Reinertson does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Jordan A. Reinertson works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Jordan A. Reinertson adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements.  Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Stephen G. Roehrig Investment Adviser Representative CRD #2826376 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 sroehrig@novemgroup.com Updated: 9/29/2025 This document provides information about Stephen G. Roehrig that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Stephen G. Roehrig is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Stephen G. Roehrig Born: 1973 Education: Le Moyne College Bachelor of Science in Finance/Economics, 1996 Business Background 10/2024 – Present Registered Representative Osaic Wealth, Inc. 5/2013 – Present Investment Adviser Representative Novem Group 4/2008 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 4/2008 – 9/2013 Investment Adviser Representative American Portfolios Advisors, Inc. Certifications Series 7 Series 63 Series 65 General Securities Representative Exam Uniform Securities Agent State Law Exam Uniform Investment Adviser Law Exam Other Business Activities Stephen G. Roehrig is a Registered Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Stephen G. Roehrig is an LLC Member as a Passive Investor at Gem Creek Brewery, LLC. Additional Compensation Stephen G. Roehrig does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Stephen G. Roehrig works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Stephen G. Roehrig adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements.  Disciplinary Information* Regulatory Event: In January of 2001, Stephen G. Roehrig was involved in a customer dispute, without admitting or denying the allegations, the respondent consented to the entry of findings that he recommended and effected transactions in the accounts of a public customer without reasonable grounds for believing that the recommendations and resultant transactions were suitable for the customer based on his financial situation and needs. In connection therewith, Stephen G. Roehrig was also fined an amount of $1,000, suspended from association with any NASD member in any capacity for 10 business days and finally, Stephen G. Roehrig’s application for registration was denied in the state of Illinois pursuant to section 8.E(1)(J) of the Illinois Securities law. Customer Dispute: Reporting Source: Firm Name: Allegations: Product Type: Status: Status Date: Broker Statement: Individual American Portfolios Financial Services, Inc. The claimants allege aiding and abetting securities laws violations, negligence, and breach of contract for allowing a security previously sold to be held in an IRA account at American Portfolios Financial Services, Inc. Promissory Note Settled 1/10/2016 This claim is totally without merit. Each claimant signed a statement that this security was not directly or indirectly solicited by American Portfolios Financial Services, Inc. and that American Portfolios Financial Services, Inc. would not be held liable for its purchase. In the end, the decision to settle this claim was strictly a business decision based upon the estimated cost of litigation. *Please refer to the SEC website at https://www.adviserinfo.sec.gov/ for more information 

Form ADV Part 2B – Individual Disclosure Brochure Paula Rogala Investment Adviser Representative CRD #1453356 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 (585) 348-9525 progala@fourbridgesfinancial.com Updated: 9/29/2025 This document provides information about Paula Rogala that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Paula Rogala is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Paula Rogala Born: 1955 Education: Nazareth College of Rochester, B.S., M.S., 2002-2005 M.C.C., 2000-2002 Business Background (past 5 years) 10/2024 – Present Investment Adviser Representative Novem Group 10/2024– Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 7/2016– 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 7/2016 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 05/2009-07/2016 Financial Advisor Waddell & Reed Certifications Series 6 Series 63 Series 7 (SIE) Series 65 Investment Company Products/Variable Contracts Representative Examination Uniform Securities Agent State Law Examination General Securities Representative Exam (Securities Industry Essentials Examination) Uniform Investment Adviser Law Examination Designations CFP® - Certified Financial Planner 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 83,000 individuals have obtained CFP® certification in the United States. • • 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. i. ii. 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. 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. Other Business Activities Paula Rogala is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Paula Rogala is currently a Financial Advisor for Genworth Life Insurance and Fourbridges Financial Group, she is a General Agent for insurance at KAFL and is currently an artist. Additional Compensation Paula Rogala does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Paula Rogala works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Paula Rogala adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Anthony L. Simonetti Investment Adviser Representative CRD #5592155 Novem Group 2300 Buffalo Road Bldg 500A Rochester, NY 14624 (585) 348-9540 asimonetti@novemgroup.com Updated: 5/20/2025 This document provides information about Anthony L. Simonetti that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Anthony L. Simonetti is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Anthony L. Simonetti Born: 1986 Education: Providence College Bachelor of Science in Finance, 2008 Business Background (past 5 years) 2/2015 – Present Investment Adviser Representative Novem Group 10/2024 – Present Investment Adviser Representative & Registered Representative Osaic Wealth, Inc. 11/2014 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 10/2014 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. Certifications Series 7 Series 66 General Securities Representative Exam Uniform Combined State Law Exam Other Business Activities Anthony L. Simonetti is a Registered Representative and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed insurance agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Anthony L. Simonetti is engaged in business with AM Ginsburg Advisory Group and Mass Mutual for life and health insurance products. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative, Investment Adviser Representative, or licensed insurance agent. Anthony L. Simonetti is the President of the Just Breathe Foundation, a charitable organization. He is also a landlord/member of Rosepark Properties and receives investment income from apartment rentals. Additional Compensation Anthony L. Simonetti does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Anthony L. Simonetti works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Anthony L. Simonetti  adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Matthew Ryan Spilfogel Investment Adviser Representative CRD #7801557 Novem Group 601 Heritage Dr 225 Jupiter, FL 33458 (561) 677-8097 mspilfogel@novemgroup.com Updated: 5/28/2025 This document provides information about Matthew Ryan Spilfogel that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Matthew Ryan Spilfogel is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Matthew Ryan Spilfogel Born: 1985 Education: Columbia Southern University Bachelor of Science Business Administration, 2014 Business Background (past 5 years) Operations Associate 10/2021 - Present Novem Group Non-Registered Assistant 10/2024 – Present Osaic Wealth, Inc. Certifications Series 65 Uniform Investment Adviser Law Exam Other Business Activities Matthew Ryan Spilfogel is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Matthew Ryan Spilfogel does not receive any economic benefit from any person, company, or organization, other than Novem Group in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Matthew Ryan Spilfogel works closely with their supervisors and all advice provided to clients and account-related transactions are reviewed by their supervisors. Matthew Ryan Spilfogel adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Mackenzi E. Springer Investment Adviser Representative CRD #6939365 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 mspringer@novemgroup.com 585-348-9525 Updated: 8/20/2025 This document provides information about Mackenzi E. Springer that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Mackenzi E. Springer is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Mackenzi E. Springer Born: 1995 Education: St. John Fisher College Bachelor of Arts in Media & Communications, 2017 Business Background (past 5 years) 2/2020 – Present Investment Adviser Representative Novem Group 10/2024 – Present Registered Representative Osaic Wealth, Inc. 6/2020 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 1/2020 – 6/2020 Registered Assistant American Portfolios Financial Services, Inc. 4/2018 – 1/2020 Investment Assistant Novem Group 4/2018 – 1/2020 Non-Registered Assistant American Portfolios Financial Services, Inc. 2/2017 – 4/2018 Marketing Coordinator Studco Building Systems Certifications SIE & S7TO – Securities Industry Essentials & Series 7 Top Off Examinations Series 63 – Uniform Securities Agent State Law Examination Series 65 – Uniform Investment Adviser Law Examination Designations AIF® - Accredited Investment Fiduciary Advisors who have earned the Accredited Investment Fiduciary designation are able to immediately show that they are interested in and working towards the best interests of their clients. They have gone through training, met the qualifications, and passed the exam allowing use of the AIF® designation. Qualifications: There are four requirements for attaining the AIF® designation: 1. Enroll in and complete the AIF® Training 2.Pass the AIF® Examination The examination is a computer-based, timed, closed-book assessment that must be attempted unaided in the presence of a proctor. The designation examinations consist of: • AIF® examination consists of sixty (60) multiple choice questions with a time-limit of ninety (90) minutes. A paper-based examination is available upon prior arrangement by Fi360 or the exam taker and may only be proctored by Fi360 personnel. 3. Meet the experience requirement  One of the following combinations of education, industry experience, and/or professional development is required to meet the experience requirement for the AIF® designation. Relevant experience is that which has been accrued in a non-clerical role within the financial services (or a related) industry. •Minimum of two (2) years of relevant experience; a bachelor’s degree (or higher); and a professional credential. •Minimum of five (5) years of relevant experience; a bachelor’s degree (or higher) or a professional credential. •Minimum of eight (8) years of relevant experience. 4. Submit the application and dues Included in the application are sections to attest to both the Code of Ethics and Conduct Standards. The Code of Ethics consists of the tenets of ethical conduct expected of all credential holders, while the Conducts Standards pertain to any past criminal and civil litigation, regulatory events, and personal and professional conduct. Continuing Education Requirement: AIF® designees must accrue a minimum of six hours of continuing education annually. The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. CFP® - Certified Financial Planner 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 62,000 individuals have obtained CFP® certification in the United States. 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, administered in 10 hours over a two-day period, 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: i. 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 ii. 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.  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. Other Business Activities Mackenzi E. Springer is a Registered Representative of Osaic Wealth, Inc. and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Additional Compensation Mackenzi E. Springer does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Mackenzi E. Springer works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Mackenzi E. Springer adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Ronald J. Taylor Investment Adviser Representative CRD #2904604 Novem Group 400 S. Syracuse St. Denver, CO 80237 rtaylor@americanportfoliosdenver.com Updated: 02/10/2026 This document provides information about Ronald J. Taylor that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Ronald J. Taylor is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Ronald J. Taylor Born: 1967 Education: Wake Forest University Bachelor of Arts – English, 1990 Business Background (past 5 years) 4/2022 – Present Investment Adviser Representative Novem Group 10/2024– Present Investment Adviser Representative & Registered Principal Osaic Wealth, Inc. 10/2016 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. 10/2016 – 10/2024 Registered Principal American Portfolios Financial Services, Inc. Certifications SIE Series 7 Series 24 Series 63 Series 65 Securities Industry Essentials Examination General Securities Representative Examination General Securities Principal Examination Uniform Securities Agent State Law Examination Uniform Investment Adviser Law Examination Other Business Activities Ronald J. Taylor is an Investment Adviser Representative and a Registered Principal of Osaic Wealth, Inc. in a supervisory role. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as an Investment Adviser Representative or Registered Representative of another firm. Additional Compensation Ronald J. Taylor does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Ronald J. Taylor works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Ronald J. Taylor adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Kris E. Tower Investment Adviser Representative CRD #2765979 Novem Group 4700 South Syracuse Street Suite 830 Denver, CO 8237 (303) 850-4867 ktower@americanportfoliosdenver.com Updated: 02/10/2026 This document provides information about Kris E. Tower that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Kris E. Tower is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Kris E. Tower Born: 1972 Education: University of Wyoming Bachelor of Science in Business Administration, 1996 Business Background (past 5 years) 1/2015 – Present Investment Adviser Representative Novem Group 10/2024 – Present OSJ, Registered Representative & Investment Adviser Representative Osaic Wealth, Inc. 2/2006 – 10/2024 OSJ & Registered Representative American Portfolios Financial Services, Inc. 2/2006 – 10/2024 Investment Adviser Representative American Portfolios Advisors, Inc. Certifications Series 7 Series 9 Series 10 Series 24 Series 52 Series 63 Series 65 General Securities Representative Exam General Securities Sales Supervisor – Options Module Examination General Securities Sales Supervisor – General Module Examination General Securities Principal Examination Municipal Securities Representative Examination Uniform Securities Agent State Law Examination Uniform Investment Adviser Law Exam Designations CFP® - Certified Financial Planner 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 83,000 individuals have obtained CFP® certification in the United States. • 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. i. ii. 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. 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. AIF® - Accredited Investment Fiduciary Advisors who have earned the Accredited Investment Fiduciary designation are able to immediately show that they are interested in and working towards the best interests of their clients. They have gone through training, met the qualifications, and passed the exam allowing use of the AIF® designation. Qualifications: There are four requirements for attaining the AIF® designation: 1. Enroll in and complete the AIF® Training 2. Pass the AIF® Examination The examination is a computer-based, timed, closed-book assessment that must be attempted unaided in the presence of a proctor. The designation examinations consist of: • AIF® examination consists of sixty (60) multiple choice questions with a time-limit of ninety (90) minutes. A paper-based examination is available upon prior arrangement by Fi360 or the exam taker, and may only be proctored by Fi360 personnel. 3. Meet the experience requirement One of the following combinations of education, industry experience, and/or professional development is required to meet the experience requirement for the AIF® designation. Relevant experience is that which has been accrued in a non-clerical role within the financial services (or a related) industry. •Minimum of two (2) years of relevant experience; a bachelor’s degree (or higher); and a professional credential. •Minimum of five (5) years of relevant experience; a bachelor’s degree (or higher) or a professional credential. •Minimum of eight (8) years of relevant experience. 4. Submit the application and dues Included in the application are sections to attest to both the Code of Ethics and Conduct Standards. The Code of Ethics consists of the tenets of ethical conduct expected of all credential holders, while the Conducts Standards pertain to any past criminal and civil litigation, regulatory events, and personal and professional conduct. Continuing Education Requirement:  AIF® designees must accrue a minimum of six hours of continuing education annually. The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. Other Business Activities Kris E. Tower is a Registered Principal, Registered Representative, and an Investment Adviser Representative of Osaic Wealth, Inc., and a licensed Insurance Agent. From time to time, the representative may offer clients advice or products from these activities. Clients should be aware that these services may pay a commission and may involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of an Investment Adviser Representative. Novem Group always acts in the best interest of the client including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any Investment Adviser Representative of Novem Group in their capacity as a Registered Representative or licensed Insurance Agent. Kris E. Tower engages in fixed insurance sales through and is the President of AP Denver, Inc. He is also an expert witness on behalf of AP Denver, Inc. Kris E. Tower is a board member of the FPA PAC Political Action Committee of Financial Planning Associates. Additional Compensation Kris E. Tower does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Kris E. Tower works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Kris E. Tower adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Gavin J. Ugone Investment Adviser Representative CRD #7352007 Novem Group 7 Grove Street, Ste 301 Topsfield, MA 01983 gugone@topsfieldfinancial.com 978-887-6778 Updated: 02/10/2026 This document provides information about Gavin J. Ugone that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Gavin J. Ugone is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Gavin J. Ugone Born: 1994 Education: Trinity College Bachelor of Arts in Economics, May 2017 Business Background (past 5 years) 8/2021 – Present Investment Adviser Representative Novem Group 10/2024 – 12/2024 Non-Registered Assistant Osaic Wealth, Inc. 3/2021 – 10/2024 Non-Registered Assistant American Portfolios Financial Services, Inc. 3/2021 –8/2021 Non-Registered Assistant Novem Group Certifications Series 65 – Uniform Investment Adviser Law Examination Designations CFP® - Certified Financial Planner 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 83,000 individuals have obtained CFP® certification in the United States. • 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. i. ii. 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. 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. Other Business Activities Gavin J. Ugone is an employee of Topsfield Financial Group. Additional Compensation Gavin J. Ugone does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision Gavin J. Ugone works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. Gavin J. Ugone adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures manual, including the Code of Ethics, and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure James W. Ugone Investment Adviser Representative CRD #2699708 Novem Group 7 Grove Street Suite 301 Topsfield, MA 01983 978-887-6778 jugone@topsfieldfinancial.com Updated: 02/10/2026 This document provides information about James W. Ugone that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you did not receive a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on James W. Ugone is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: James W. Ugone Born: 1957 Education: University of New Hampshire Master’s in Occupational Education, 1987 University of Massachusetts Bachelor of Arts in Education, 1980 Stockbridge School of Agriculture Associates Degree in Science Horticulture, 1978 Business Background 11/2014 – Present Investment Adviser Representative Novem Group 10/2024 – 12/2024 Registered Representative Osaic Wealth, Inc. 1/2002 – 10/2024 Registered Representative American Portfolios Financial Services, Inc. 11/2006 – 12/2014 Investment Adviser Representative American Portfolios Advisors, Inc. 9/1989 – 9/2006 Regional Manager Farm Family Life Insurance Company 1/1996 – 1/2002 Registered Representative Commonwealth Equity Services, Inc. Certifications Series 6 Series 63 Series 65 Investment Company Products & Variable Contracts Representative Examination Uniform Securities Agent State Law Examination Uniform Investment Adviser Law Exam Other Business Activities James W. Ugone is a licensed insurance agent, as required by the state of Massachusetts, in order to be a fee-based advisor on variable annuities through Novem Group. This insurance license is not used to sell other commission- based insurance-related products. James W. Ugone is an employee of Topsfield Financial Group.  Additional Compensation James W. Ugone does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, James W. Ugone works closely with their supervisor and all advice provided to clients and account-related transactions are reviewed by their supervisor. James W. Ugone adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business. 

Form ADV Part 2B – Individual Disclosure Brochure Daniel Robert Williams Investment Adviser Representative CRD #7682411 Novem Group 350 Linden Oaks, Suite 140 Rochester, NY 14625 585-348-9456 dwilliams@novemgroup.com Updated: 5/30/2025 This document provides information about Daniel Robert Williams that supplements the Novem Group Firm Brochure, which you should have received a copy of. Please contact Robert J. Bartolotta, Chief Executive Officer of Novem Group, if you have not received a copy of the Firm Brochure or if you have any questions on the contents of this document. Additional information on Daniel Robert Williams is available on the SEC’s website at www.adviserinfo.sec.gov.  Personal Information Name: Daniel Robert Williams Born: 2001 Education: St. John Fisher University Bachelor of Science Finance (financial planning path), 2022 Business Background (past 5 years) Investment Assistant 12/2022 – Present Novem Group Non-Registered Assistant 10/2024 – Present Osaic Wealth, Inc. 01/2017 - 01/2023 Customer Service Team Member Wegmans Food Markets Certifications Series 65 Uniform Investment Adviser Law Exam Other Business Activities Daniel Robert Williams is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Daniel Robert Williams does not receive any economic benefit from any person, company, or organization, other than Novem Group, in exchange for providing clients advisory services through Novem Group. Supervision As an Investment Adviser Representative, Daniel Robert Williams works closely with their supervisors and all advice provided to clients and account-related transactions are reviewed by their supervisors. Daniel Robert Williams adheres to all required regulations regarding the activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s Written Supervisory Procedures and Code of Ethics and regulatory requirements. Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this representative’s business.