NewSquare became registered with the Securities and Exchange Commission on January 13, 2010 and commenced business as an investment adviser on that date. NewSquare’s Principal Owners are as follows: Joseph Vincent Naselli The Eleanor Mae Daniels Trust Gary Earl Daniels Trustee Jesse Hart Daniels Trustee Claire Daniels Trustee The managers of NewSquare are as follows: Joseph S. Rizzello, Chief Executive Officer Mr. Rizzello brings substantial industry experience and expertise to the NewSquare Capital organization. He’s been instrumental in NewSquare’s growth. Joseph is recognized as an industry innovator and was prominent in the lead- up to the creation of exchange-traded funds (ETFs), a security type that continues to experience substantial growth. As NewSquare Capital’s Chairman, Mr. Rizzello caps a distinguished 40+ year career in financial services, including senior positions with top-tier organizations that include: CEO, Board Chairman of the National Stock Exchange, Jersey City: co- founder of The Mind Capital Group, Philadelphia; President of Pershing Trading Company, Jersey City; a principal in charge of Vanguard Brokerage Services, Malvern Pa; and Executive Vice President of the Philadelphia Stock Exchange. Christy L Hart, Director of Operations In her former role as a Client Experience Consultant at Creative Financial, Christy worked with high-net-worth clients and businesses, tailoring each service plan to build and sustain strong client relationships. She was integral in many areas, including identifying and addressing client needs, connecting clients to thought leadership and events, and implementing firm- wide project management. Christy is a graduate of West Chester University where she earned Bachelors of Science Degree in Elementary Education. Ryan Kirk, CFA, President and Head of Portfolio Management Ryan is in charge of the day-to-day trade management of all NewSquare Portfolios. He works closely with all team members supporting the daily management of all accounts. Other responsibilities include monitoring asset allocation, monitoring cash balances, account rebalancing and trade execution, account reporting, and research. Ryan has over 15 years of experience in the financial industry. Prior to joining NewSquare Capital, he gained his initial experience at Aberdeen Asset Management. He holds a BS in Business Management from the University of Scranton. He has earned the Chartered Financial Analyst (CFA) designation and is a member of the CFA Society of Philadelphia. Lee S. Grout, CFA, Senior Portfolio Manager With 30+ years in the investment industry, Lee joined NewSquare at the end of 2019. As the portfolio manager for several of NewSquare’s portfolios, Lee oversees both investment research and portfolio management for solutions that are designed to meet a wide range of investor needs. Lee was most recently Portfolio Manager at Chartwell Investment Partners, Berwyn, Pennsylvania. Prior to that, he spent 14 years as Portfolio Manager and Head of Investment Research at the Killen Group, Inc., also in Berwyn. He served as Secretary of the Board of Directors and held an ownership interest in the firm. Lee’s investment research career dates from 1994, when he joined McCabe Capital Managers, King of Prussia, Pennsylvania, as a research analyst. He started his investment industry career in 1993 as a Mutual Fund Accountant with SEI Corporation in Oaks, Pennsylvania. Lee is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of Philadelphia. He earned a Bachelor of Business Administration degree in Finance from Bishop’s University, Lennoxville, Quebec. Miguel L. Biamon, Senior Fixed Income Portfolio Manager Miguel started with NewSquare in July 2018 and brings with him over 25+ years of industry experience. He manages our fixed income portfolios as well as bond trading. Miguel previously worked at M&T Bank, Bryn Mawr Trust and Blue Bell Private Wealth Management. Matthew Wilson, Chief Compliance Officer Matt Wilson has been the NewSquare CCO since April 1, 2016. He succeeded William R. Meck who had previously served as CCO. Matt served as assistant CCO since the founding of NewSquare in 2010. He attended Pennsylvania State University and received a Bachelor of Science Degree (Finance) in 2000. Matt is responsible for the top- down design of all RIA-related compliance procedures and their implementation. *Please Note: Limitations. The achievement of any professional designation, certification, degree, or license, membership in any professional organization, or any amount of prior experience or success, should not be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results or satisfaction if NewSquare is engaged, or continues to be engaged, to provide investment advisory services. NewSquare’s advisory services are provided as part of a wrap fee program (the “Program”) and are mainly focused around designing and implementing diversified portfolios of primarily exchange traded funds, individual equity securities and selected fixed income securities. These services are designed to be consistent with to each client’s designated goals and objectives. The Portfolios are strategic asset allocation portfolios with global diversification. Considerations include risk tolerance, time horizon, income needs, liquidity needs, tax sensitivity, and other factors. NewSquare will offer clients the ability to engage NewSquare on a discretionary basis in portfolios of primarily exchange traded funds, individual equity securities and fixed income securities. In conjunction with the client’s MMLIS representative (see below), each client will receive individual service based on their needs and risk tolerances. Clients may impose restrictions on investing in certain securities or types of securities. NewSquare will manage client’s assets consistent with one or more of its asset allocation strategies. Under the Program, assets are held in a brokerage account at Schwab Advisor Services (“Schwab”), or Fidelity Brokerage Services, LLC (“Fidelity”). This account shall be known as the Program Account. Beginning in 2017, NewSquare underwent a transition of custodians. Accounts were transitioned from MML Investor Services (“MMLIS”) to Schwab. All new accounts will be opened at Schwab or Fidelity. Any account that remained at MMLIS after March 31, 2018 was transitioned to a standard brokerage account that is no longer managed by NewSquare Capital. As part of the Program, NewSquare has entered into a co-advisory agreement with MMLIS pursuant to which the two companies act as co- advisors to clients who open investment advisory accounts at NewSquare. Per the terms of the Co- Investment Advisory Agreement, MMLIS is generally responsible for the initial and ongoing day-to-day relationship with the client, including the initial and ongoing determination of client suitability for NewSquare’s asset allocation strategies. In such co-advisory engagements, NewSquare is responsible for managing the client’s assets consistent with one or more of its asset allocation strategy(ies), as communicated to by MMLIS. This Brochure describes NewSquare’s duties and responsibilities. For a description of MMLIS’ duties and responsibilities, please see MMLIS’ Form ADV 2A Brochure. The client relationship is typically managed by Investment Adviser Representatives (“IARs”) of MMLIS. IARs (with the assistance of NewSquare management or employees if requested), generally meet with clients, discuss the clients’ goals and objectives and assist the clients in the development, management and implementation of the clients’ wealth management program. IARs do not, however, manage NewSquare portfolios for clients. Rather, NewSquare portfolios are managed by Portfolio Managers of NewSquare. In limited instances, NewSquare could determine to permit the client to retain NewSquare directly (separate from MMLIS Co-Advisory Agreement) to manage client’s assets, on a discretionary basis consistent the client’s goals, objectives, and risk tolerance. In such relationships, the client would execute a Discretionary Investment Management Agreement with NewSquare and a Brokerage Account Agreement with Schwab or Fidelity (Program Account). In such limited circumstances, client portfolios will be managed by NewSquare, on a discretionary basis. NewSquare is both the sponsor and the portfolio manager of the Program and the Program is structured as a wrap account. A wrap account is a type of individually managed account in which most expenses that are typical of a managed account are combined into one (a wrap) fee. This includes the management fee, the brokerage commissions, custodial fee and other expenses. The wrap fee does not cover certain fees such as markup/markdowns, transfer of asset fees, reorganization fees, wire or check fees. ERISA PLANS: NewSquare may be directly engaged by Plan sponsors to provide non- discretionary and discretionary advisory services to ERISA retirement plans. In such event, NewSquare would serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”)-either a 3(21) fiduciary for non- discretionary engagements or a 3(38) fiduciary for discretionary engagements. In either engagement, NewSquare will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement or a Retirement Plan Services Agreement between the Plan and NewSquare. CONFLICTS OF INTEREST AND MISCELLANEOUS DISCLOSURES: NewSquare may perform advisory services for various clients and may give advice or take actions for another client that differs from the advice given or the timing or the nature of any action taken for the Account. Incentive Units and Other Benefits: Conflicts of Interest: Regardless of whether a client engages NewSquare directly, or, in its co- advisory capacity with MMLIS, the client’s MMLIS IAR is compensated with a portion of the Program fee. In addition to a portion of the Program fee, the IAR can also receive Sale of Company incentive units from NewSquare (the “Units”). The Units provide the IAR with non- voting, company liquidation participation units, upon the sale of NewSquare or the IAR’s death, disability, or retirement. The receipt of the Units provide the IAR with an economic incentive to allocate client assets to the Program. Because of this economic incentive, the IAR has a conflict of interest when allocating assets to the Program. In addition, MMLIS IARs who allocate more than $25million of assets to the Program qualify to receive bonus compensation from NewSquare. The amount of bonus compensation increases with the amount of assets allocated to the Program. The bonus can be as high as a thirty percent (30%) discount of the NewSquare portion of the Program Fee. The IAR shall retain such bonus rather than utilize same to reduce the client’s Program fee. The potential for receipt of bonus compensation presents an added conflict of interest by providing the IAR with an incentive to allocate more assets to the Program. Separate from the Units, NewSquare can, from time to time, provide additional benefits to the IARs, the providing of which by NewSquare, and receipt of which by the IARs, also presents a conflict of interest. The benefits can include occasional business entertainment including meals, invitations to sporting events, including golf tournaments and other forms of entertainment, some of which can accompany educational opportunities or guest speaker events. Please Note: No prospective client is required to allocate assets to the Program. ANY QUESTIONS: NewSquare’s Chief Compliance

Officer, Matthew Wilson, remains available to address any questions regarding the above conflict of interest. PLEASE also see disclosure set forth on MMLIS’s written disclosure Brochure (Part 2A of Form ADV) regarding incentives provided to its IARs. Wrap Program-Conflict of Interest. NewSquare provides services on a wrap fee basis as a wrap program sponsor. Under NewSquare’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. When managing a client’s account on a wrap fee basis, NewSquare shall receive as payment for its investment advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee have been deducted. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in NewSquare’s Wrap Fee Program Brochure. Conflict of Interest: Because wrap program transaction fees and/or commissions are being paid by NewSquare to the account custodian/broker-dealer, NewSquare could have an economic incentive to minimize the number of trades in the client's account. See separate Wrap Fee Program Brochure. Please Note: This conflict of interest does not apply to accounts managed under an Asset-Based Pricing Arrangement, as further detailed below. At this time, NewSquare has all accounts setup as Transaction-Based Pricing due to zero cost commission / transaction fees with the custodians. Although the recommended custodians do not currently charge commission/transaction fees for the types of securities purchased by NewSquare for client accounts, NewSquare does incur other types of transaction-related fees payable to the account custodian that are absorbed by NewSquare as part of the wrap program fee. 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 NewSquare recommends that a client roll over their retirement plan assets into an account to be managed by NewSquare, such a recommendation creates a conflict of interest if NewSquare will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by NewSquare. Please Note: NewSquare does not generally recommend rollovers. However, its co- adviser (MMLIS see below) could make a rollover recommendation (the suitability of which for the client shall be determined by MMLIS), as the result of which NewSquare could be engaged to manage the rollover assets. In the unlikely event that NewSquare makes a rollover recommendation, NewSquare 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 Financial Planning or Non-Investment Consulting/Implementation Services. NewSquare does not provide financial planning or related consulting services matters such as estate planning, tax planning, insurance, etc. NewSquare does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents, tax returns or sell insurance products. Sub-Advisor / Separate Account Manager Services: NewSquare may be engaged to serve as a: (1) sub-adviser to unaffiliated registered investment advisers; and/or (2) as a separate account manager on a custodian’s investment platform. With respect to these two types of engagements, the unaffiliated investment advisers that engage NewSquare’s sub-advisory services and/or assist their clients in selecting NewSquare as a separate account manager, maintain both the initial and ongoing day-to-day relationship with the underlying client, including the initial and ongoing determination of client suitability for NewSquare’s investment strategies. NewSquare’s obligation shall be to manage the client’s account consistent with the investment strategy designated by the unaffiliated investment adviser. In addition, for all such engagements, NewSquare does not generally have the ability to choose and/or determine: (1) the custodian and/or broker-dealer for the client’s account; (2) whether the services are part of a wrap program or provided on an unbundled basis; or (3) program and/or transaction cost pricing. As a result, clients may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by NewSquare. Higher fees and transaction costs adversely impact account performance. Unaffiliated Wrap/Separate Managed Account programs services: NewSquare may be engaged to provide investment advisory services as part of an unaffiliated wrap-fee program/managed account platform, In these type of engagements, the unaffiliated investment advisers that engage NewSquare's services shall maintain both the initial and ongoing day-to-day relationship with the underlying investor, including initial and ongoing determination of the of the investor’s suitability for NewSquare's designated investment strategies. In addition, since the custodian/broker-dealer is determined by the unaffiliated program/platform sponsor, NewSquare will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, the investor could pay higher commissions or other transaction costs. Higher transaction costs adversely impact account performance. PCS Affiliation/Conflict of Interest: NewSquare representative, Timothy Chisolm, is also an employee and owner of PCS, a retirement plan platform provider. Mr. Chisolm, and other NewSquare representatives based upon the quality of the PCS platform, recommend PCS to retirement plan clients for their consideration. No client is under any obligation to engage PCS. In the event that a NewSquare client engages PCS, no portion of PCS’ fees are shared by PCS with NewSquare. However, given Mr. Chisolm’s affiliation with PCS, he has an economic incentive to recommend PCS’ services. This incentive presents a conflict of interest, since both PCS and Mr. Chisolm will benefit from such an engagement. ANY QUESTIONS: NewSquare’s Chief Compliance Officer, Matthew Wilson, remains available to address any questions regarding the above conflict of interest. Portfolio Activity. NewSquare has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, NewSquare 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, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when NewSquare determines that changes to a client’s portfolio are neither necessary, nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by NewSquare will be profitable or equal any specific performance level(s). Please Note: Cash Positions. NewSquare continues to treat cash as an asset class. As such, unless determined to the contrary by NewSquare, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating NewSquare’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), NewSquare 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, NewSquare’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: NewSquare’s Chief Compliance Officer, Matthew Wilson, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Donor-Advised Funds. NewSquare may provide advisory services to donor-advised funds through an arrangement with Schwab Charitable™, an unaffiliated non-profit organization. Donor- advised funds allow clients to contribute assets to a charitable account which may provide tax benefits to the client and allow for the client to support their preferred charity(ies). The client will be responsible for certain administrative fees charged by Schwab Charitable™ and will be informed of any advisory fees charged against the donor-advised fund prior to NewSquare assuming management of the account. NewSquare does not provide tax, legal, or accounting advice. Clients are advised to speak with the professional(s) of their choosing prior to directing NewSquare to contribute assets to a donor-advised fund. More information on Schwab Charitable™ can be found at www.schwabcharitable.org. Transaction-Fee Pricing Arrangements and Limitations. NewSquare charges an all-inclusive wrap fee to clients. NewSquare can set an account either as “Asset-Based” or “Transaction-Based” pricing with the broker-dealer/custodian, and the cost of either is paid for by NewSquare and is part of the all-inclusive wrap fee charged to the client. Under an “Asset-Based” pricing arrangement, the broker-dealer/custodian will charge a fixed fee to NewSquare for all account commissions/transactions. In the alternative, the broker-dealer/custodian could charge a separate commission/transaction for the execution of each account transaction. This is referred to as a “Transaction-Based” pricing arrangement. Transaction fees paid will vary depending upon the number of and type of transactions that are placed for the account. For Program Accounts, regardless of whether there is an Asset-Based or Transaction-Based pricing, arrangement, transaction fees and/or commissions are being absorbed and paid by NewSquare to the account custodian/broker-dealer. In a Transaction Based arrangement, NewSquare could have an economic incentive to minimize the number of trades in the client's account, thereby creating a conflict of interest-see below. Currently, as the result of the continued determination by account custodians utilized by NewSqaure to not charge on trading fees on individual equity transactions, including ETFs (NewSquare’s primary trading vehicle), New Squared has opted for Transaction-Based pricing. Account investment decisions are driven by security selection and anticipated market conditions, as opposed to the amount of commission/transaction fees payable to the account broker-dealer/custodian. NewSquare charges an all-inclusive wrap fee and may request at any time to switch between Asset- Based pricing and Transaction-Based pricing arrangements with the broker-dealer/custodian, however, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Therefore, given the variances in trading volume and pricing arrangements, any decision by NewSquare to switch between Asset- Based or Transaction-Based pricing could prove to be economically disadvantageous, but that cost is the responsibility of NewSquare. Assets under Management are calculated as of December 31, 2023. Discretionary Assets: $1,559,189,717 Non-Discretionary Assets: None Total Assets: $1,559,189,717