Firm Description New England Investment Consultants, Ltd hereafter referred to as “NEIC” provides personalized confidential financial planning and investment management to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate-planning. Firm Principal Owners Sergio A DeCurtis MBA, ARPS, AIF President, Owner & CCO of New England Investment Consultants, Ltd. (NEIC) an investment advisory firm founded in 2006. Type of Advisory Services NEIC is a fee based financial planning and investment management firm. NEIC will typically create a portfolio of no-load mutual funds, index funds, ETFs, or no-load annuities, and may use model portfolios if the models match the client’s investment asset allocation strategy. NEIC will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Investment advice is provided, with the client making the final decision on investment selection. NEIC does not act as a custodian of client assets. The client always maintains asset control. A written evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. NEIC provides investment supervisory services, also known as asset management services and furnishes financial planning and investment advice through consultations. On more than an occasional basis, NEIC furnishes advice to clients on matters not involving securities, such as taxation issues and trust services that often include estate planning. ASSET MANAGEMENT New England Investment Consultants,Ltd. principal service is providing investment advisory services based on the client’s specific investment objectives, goals and financial situation. The advisor practices custom management of portfolios, on a non-discretionary basis, and has capability to provide discretionary management if requested according to the client’s objectives. The advisor will look at mutual funds, stocks, foreign issuers, municipal, government and corporate debt securities, real estate and oil & gas interests, and CD’s when tailoring a financial plan. NEIC primarily recommends portfolios consisting of no-load mutual funds offered by Dimensional Fund Advisors (DFA) and Vanguard. DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, the client will compensate NEIC on an hourly fee or negotiable fixed fee basis described in detail under “Fees and Compensation” section of this brochure. The advisor may employ several different strategies, including: long-term purchases and short-term purchases. All of these strategies may be used at various times as a possible hedge against market movement which may adversely affect the client’s portfolio. The advisor may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of the client or any risk deemed unacceptable for the client’s risk tolerance. Representatives of NEIC may also provide general non-securities advice on topics including estate planning, retirement planning, and mortgage consulting. Fees are billed at an hourly

rate, negotiated in advance and paid as services are rendered. The non-securities financial planning will not exceed 50% of the firm’s billings. ADVISORY SERVICES to RETIREMENT PLANS and PLAN PARTICIPANTS New England Investment Consultants,Ltd. offers various levels of advisory and consulting services to employee benefit plans and to the participants of such plans (Participants). The services are designed to assist plan sponsors (Plan Sponsors) in meeting their management and fiduciary obligations to the Participants under the Employee Retirement Income Securities Act (ERISA) and the Pension Protection Act of 2006 (PPA). New England Investment Consultants,Ltd. will provide services to Plan Sponsors and their Participants as described below. Generally, investment advice provided to Plan Sponsors and Participants is regulated under ERISA and the PPA. Plan Sponsors must make the ultimate decision to retain New England Investment Consultants, Ltd. for pension consulting and other advisory services including, but not limited to, services at the participant level. The Plan Sponsor is free to seek independent advice about the appropriateness of any recommended services for the plan. New England Investment Consultants, Ltd. develops an Investment Policy Statement for each plan, which may include some or all of the following areas: overview, investor circumstances, tax policy, reviews, diversification and investment constraints, selection/retention criteria for investments, investment monitoring and control procedures and duties and responsibilities. Services include: Management of vendor relationships; Request for Proposals (RFPs); Assistance on plan design strategies; Fiduciary consulting and oversight; Investment Management; and Employee Education and Communication Services. Advisory services provided to retirement plans may be solely provided by Investment Adviser Representatives (IARs), or in combination with third parties and their retirement plan services. Client Tailored Services and Client Imposed Restrictions New England Investment Consultants, Ltd. tailors investment advisory services to the individual needs of the client. New England Investment Consultants, Ltd. clients can impose restrictions on the investments in their account. New England Investment Consultants, Ltd. may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to New England Investment Consultants, Ltd. in writing. The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Fiduciary Statement New England Investment Consultants, Ltd. and its employees are fiduciaries who must take into consideration the best interests of its clients. New England Investment Consultants, Ltd. will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients. New England Investment Consultants, Ltd. will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. As a fiduciary, New England Investment Consultants, Ltd. has the obligation to deal fairly with clients. New England Investment Consultants, Ltd. has the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client's needs, financial circumstances and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead; To have reasonable basis, information, and understanding of the facts to provide appropriate recommendations and representations; Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Wrap Fee Programs NEIC does not participate in wrap fee programs. Client Assets under Management As of December 31st, 2022, NEIC has $ 1,013,287,743,client assets under management on a non-discretionary basis.