General Information Newton One Investments, LLC (DBA N1 Advisors) was formed in 2014 and provides financial planning, portfolio management and pension consulting services to its clients. Prior to 2014, Newton One Investments LLC operated as Newton One Advisors, LLC which was established in 2001. At the outset of each advisory client relationship, N1 Advisors spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying a client’s financial goals and objectives. N1 Advisors provides portfolio management services based on the information gathered from clients. N1 Advisors generally develops with each client:
• investment portfolio for the client based on the client’s financial circumstances and risk tolerance level (the “Client Profile”);
• the client’s investment goals and/or objectives (the “Investment Objective Confirmation [IOC]”). The Client Profile is a reflection of information as described above. The IOC outlines the types of investments N1 Advisors will make on behalf of the client to achieve their goals and/or objectives. The Profile and the Investment Plan are discussed regularly with each client, but are not necessarily written documents. Portfolio Management At the beginning of a client relationship, N1 Advisors meets with the client, gathers information and performs research and analysis as necessary to develop the client’s IOC. The IOC will be updated from time to time when requested by the client, or when determined to be necessary or advisable by N1 Advisors based on updates to the client’s financial or other circumstances. To implement the client’s IOC, N1 Advisors will manage the client’s investment portfolio on a discretionary basis. As a discretionary investment adviser, N1 Advisors will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain reasonable written restrictions on N1 Advisors in the management of their investment portfolios, such as prohibiting specific security positions in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolios. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of N1 Advisors. N1 Advisors’ annual investment advisory fee shall generally (exceptions can occur-see below) include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of N1 Advisors), N1 Advisors may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Financial Planning, as furnished as part of an investment management engagement, may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation, financial planning may include some or all of the following:
• Conducting retirement plan analysis
• Gathering information concerning the client's personal and financial situation
• Assisting the client in establishing financial goals and objectives
• Making recommendations to help achieve retirement plan goals and objectives
• Reviewing goals and objectives and measuring progress toward these goals
• Designing an investment portfolio to help meet the goals and objectives of the client
• Providing estate planning
• Assessing risk and reviewing long-term care, life, and disability insurance needs Retirement Plans At the beginning of a client relationship, N1 Advisors meets with the client, gathers information N1 Advisors provides advisory services to various types of qualified retirement plans, including:
• Trustee Directed Plans. N1 Advisors may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, N1 Advisors will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). N1 Advisors will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm.
• Participant Directed Retirement Plans. N1 Advisors may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between N1 Advisors and the plan. For such engagements, N1 Advisors shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process.
• Client Retirement Plan Assets. If requested to do so, N1 Advisors shall provide investment advisory services relative to the client’s 401(k) plan assets. In such event, N1 Advisors shall recommend that the client allocate the retirement account assets among the investment options available on the 401(k) platform. The client is exclusively responsible for making all transactions. N1 Advisors’ ability shall be limited to making recommendations regarding the allocation of the assets among the investment alternatives available through the plan. N1 Advisors will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify N1 Advisors of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Principal Owners Scott Snyder and Eric Pressler are the principal owners of N1 Advisors. Please see their respective Brochure Supplements for more information on Mr. Snyder and Mr. Pressler, as well as other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. Miscellaneous Disclosures Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested by the client, N1 Advisors may also provide consulting services regarding matters such as estate planning and insurance, etc. N1 Advisors may provide such consulting services inclusive of its advisory fee set forth under the Fees and Compensation heading below (exceptions may occur based upon assets under management, extraordinary services, special projects, etc. for which Firm may charge a separate fee, or a stand-alone consulting engagement). Please Note: If N1 includes financial planning as part of its investment advisory fee as set forth at Item 5 below, N1’s advisory fee will remain the same regardless of whether or not the client determines to address financial planning issues with N1. Please Also Note: N1 Advisors does not serve as an attorney or accountant, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from N1 Advisors and/or its representatives. Please Further Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, etc.), and not N1 Advisors, shall be responsible for the quality and competency of the services provided. ANY QUESTIONS: N1 Advisors’ Chief Compliance Officer, Scott Snyder, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If N1 Advisors recommends that a client roll over their retirement plan assets into an account to be managed

by N1 Advisors, such a recommendation creates a conflict of interest if N1 Advisors will earn new (or increase its current) compensation as a result of the rollover. If N1 Advisors provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), N1 Advisors is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to rollover retirement plan assets to an account managed by N1 Advisors, whether it is from an employer’s plan or an existing IRA. N1 Advisors’ Chief Compliance Officer, Scott Snyder remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Use of Mutual Funds and Exchange Traded Funds: N1 Advisors utilizes mutual funds and exchange traded funds for its client portfolios. In addition to N1 Advisors’ investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The mutual funds and exchange traded funds utilized by N1 Advisors are generally available directly to the public. Thus, a client can generally obtain the funds recommended and/or utilized by N1 Advisors independent of engaging N1 Advisors as an investment advisor. However, if a prospective client does so, then they will not receive N1 Advisors' initial and ongoing investment advisory services. N1 Advisors’ Chief Compliance Officer, Scott Snyder, remains available to address any questions that a client or prospective client may have regarding the above. Schwab. As discussed below at “Brokerage Practices,” N1 Advisors recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions, others do). Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. In addition to N1 Advisors’ investment management fee, and transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The fees charged by Schwab, as well as the charges imposed at the mutual fund and exchange traded fund level, are in addition to N1 Advisors’ advisory fee referenced in “Fees and Compensation” below. Cybersecurity Risk. The information technology systems and networks that N1 and its third- party service providers use to provide services to N1’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in N1’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and N1 are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although N1 has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that N1 does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cash Positions. N1 continues to treat cash as an asset class. As such, unless determined to the contrary by N1, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating N1’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), N1 may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, N1’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: N1’s Chief Compliance Officer, Scott Snyder, remains available to address any questions that a client or prospective may have regarding the above fee billing practice Portfolio Activity. N1 Advisors has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, N1 Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, mutual fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when N1 Advisors determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described under the Fees and Compensation heading below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by N1 Advisors will be profitable or equal any specific performance level(s). Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of N1 Advisors. Generally, with potential exceptions, N1 Advisors does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by N1 Advisors will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by N1 Advisors) will be profitable or equal any specific performance level(s). In addition, there may be other securities and/or accounts owned by the client for which N1 Advisors does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which N1 Advisors does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by N1 Advisors, N1 Advisors shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent; (3) shall generally consider these securities as part of the client’s overall asset allocation; (4) report on such securities/accounts as part of regular reports that may be provided by N1 Advisors; and, (5) include the market value of all such securities for purposes of calculating advisory fee. ANY QUESTIONS: N1 Advisors’ Chief Compliance Officer, Scott Snyder, remains available to address any questions regarding the above. Client Obligations. In performing our services, N1 Advisors shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify N1 Advisors if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by N1 Advisors) will be profitable or equal any specific performance level(s). Disclosure Brochure. A copy of N1 Advisors’ written disclosure Brochure as set forth on Part 2 of Form ADV, along with N1’s Form CRS (Relationship Summary) shall be provided to each client before, or contemporaneously with, the execution of the Investment Advisory Agreement. Type and Value of Assets Currently Managed. As of December 31, 2023, N1 Advisors managed $346,289,540 on a discretionary basis.