Overview New Frontier Advisors, LLC ("New Frontier", the “Firm”, “we”, “us” or “our”) is an SEC registered investment adviser with its principal place of business located in Boston, Massachusetts. New Frontier Advisors, LLC (“NFA”) was created in 1999 and primarily provided investment management, software development, and consulting services. New Frontier began conducting business in 2008 as New Frontier Management Company, LLC (“NFMC”). Prior to January 1, 2017, the principal owners listed below owned two separate registered investment advisors, NFMC and NFA. On January 1, 2017, NFA was merged into NFMC. To reflect this merger, NFMC officially changed its name to New Frontier Advisors, LLC. The Firm's principal owners are:  Richard Omer Michaud as Trustee of The Richard Michaud 2017 Trust  Robert Omer Michaud, Managing Director Investment Advisory Services New Frontier provides investment advisory services in the form of domestic and global multi-asset allocation model portfolios. We approach investments from a quantitative perspective. A disciplined application of cutting-edge research and technology helps to mitigate human biases and error in investment management. The four stages of our investment process are: Asset Universe and Fund Selection, Risk and Return Estimation, Portfolio Construction, and Portfolio Monitoring and Rebalancing. New Frontier attempts to add value at all four stages with institutional expertise and patented technologies. A full description of this process can be found under Item 8. By utilizing this process, New Frontier offers range of model portfolios that fall into the following categories: The Firm has offered the New Frontier Global Core Multi-Asset Portfolios since it was established in 2004. The New Frontier U.S. Core Multi-Asset Portfolios were launched in 2019. These ETF portfolios are well-diversified and designed for long term total return. Both strategies are available at six risk levels: Income, Balanced Income, Balanced, Balanced Growth, Growth, and Equity. The New Frontier ETF Global Income Tax-Sensitive Portfolios were also established in 2004. The portfolios are a risk- targeted core investment, consisting of ETF funds optimized relative to a 20/80 stock/bond ratio. This portfolio is designed for investors seeking current income in a taxable account in a global asset allocation strategy. The strategy invests in fifteen to thirty exchange traded funds. Taxes are considered at every step of our portfolio construction process, from ETF universe to optimization to trading decisions. They are available at six risk levels: Income, Balanced Income, Balanced, Balanced Growth, Growth, and Equity. The New Frontier Multi-Asset Income Portfolios are globally diversified ETF portfolios that seek to provide a sustainable source of income for investors. Launched in 2012, the portfolios are constructed to capture both market returns and income. They contain dividend-income-oriented ETFs as well as ETFs that offer significant diversification and risk management benefits. The resulting portfolios provide the opportunity to benefit from long-term price appreciation and enhanced income. They are available at three risk levels: Conservative, Balanced, and Growth. How to Access the New Frontier Model Portfolios To access the New Frontier model portfolios, an individual retail investor must engage a representative of a broker- dealer or registered investment advisory firm to serve as their adviser (henceforth, the “Financial Advisors”). The retail investor’s Financial Advisor will then have the ability to access the New Frontier model portfolios by participating in one of the following ways. Sponsor Firm Model New Frontier model portfolios are available to Financial Advisors and their clients through turnkey asset management programs which are sponsored by various third-party investment advisory firms (the “Sponsor Firms”). Sponsor Firms provide independent Financial Advisors the ability to access the New Frontier model portfolios as well as various other asset allocation strategies. Your Financial Advisor will help you determine the appropriate model portfolios to invest in. The Sponsor Firm monitors and evaluates New Frontier’s performance and provides custodial and execution services for the underlying client’s accounts. New Frontier provides the buy and sell signals to the Sponsor Firm who then determines if the trades should be executed. An underlying client’s account may be modified by the Sponsor Firm or Financial Advisor for certain client-imposed restrictions. When model portfolios are accessed via Sponsor Firms, New Frontier does not have any direct agreement with the underlying client. As such, New Frontier does not provide investment advisory services directly to the underlying client and does not have discretionary authority to effect trades on behalf of the underlying client accounts. Under the Sponsor Firm Model, New Frontier acts solely as a strategist, model provider, and/or model manager to Sponsor Firms. Tax Management Services for Sponsor Firm Models New Frontier also offers customized, manager-traded Strategies to Financial Advisors through the Sponsor Firms. All Sponsor Firms do not offer this service. All directives as to customized portfolios will be facilitated by the Sponsor Firm. New Frontier will work with the Financial Advisor and Sponsor Firm to implement the customized portfolio. New Frontier performs tax loss harvesting in connection with taxable assets, on a discretionary

basis subject to any reasonable parameters provided by the Advisor, within these customized portfolios. Direct Model New Frontier model portfolios are also available directly to Financial Advisors and their Clients (“Direct Clients”) directly through select qualified custodians. Under the Direct Model, New Frontier model portfolios are available directly with a Financial Advisor. The Financial Advisor engages New Frontier to serve as a sub-advisor to Direct Client accounts. The Direct Client executes an investment advisory agreement with New Frontier as well as their Financial Advisor. Under the investment advisory agreement, New Frontier has direct access to trade and rebalance client accounts according the model portfolios parameters. Direct Clients must work with their Financial Advisor to access the models and then select the appropriate model portfolio for their accounts. The Financial Advisor has the discretion to select the model portfolios to be implemented in a Direct Client’s accounts. As such, New Frontier does not provide investment advisory services tailored to the individual needs and objectives of any Direct Client. New Frontier has discretion over the management of the portfolios (but not the selection or recommendation of those portfolios), sending trade orders to the custodian selected by the Financial Advisor, and overseeing the execution of those trades. Direct Clients should consult their Financial Advisor for more information. Tax Management Services for Direct Models For accounts in the Direct Model, New Frontier can be engaged to perform tax loss harvesting in connection with taxable assets. This service is on a discretionary basis and subject to any reasonable parameters provided by the Advisor. As Tax Services are optional, there is additional fee of 10 basis points per year for accounts in the Direct Model if engaged by the Advisor unless otherwise negotiated. For clients who engage New Frontier’s Tax Management Services, we may work with the Advisor to transition the account to the New Frontier portfolio appropriately and/or perform an annual consultation with the advisor in addition to ongoing tax loss harvesting. New Frontier does not provide legal or tax advice to any client. The client should consult an attorney or tax advisor regarding their specific tax situation. Security Selection and Recommendation Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Our investment recommendations are typically implemented using index-based Exchange Traded Funds ("ETFs"). These ETFs cover major asset classes and styles, such as fixed income (government, corporate, tax-exempt, international), equities (large cap, small cap, value, growth, international, emerging markets) and may also include limited holdings of other ETFs or assets including gold and real estate, for example. The majority of our portfolios are exclusively invested in ETFs, but our portfolios may also be implemented with active and index mutual funds. The securities selected are primarily based upon quantitative factors such as index representation, transparency, liquidity, expense ratio, tracking error, and potential tax efficiency. Other qualitative factors are also considered including track record, client opinion, and seasoning. For a discussion of risk factors related to our security selection and recommendation process, please see Item 8 of this brochure. New Frontier’s investment recommendations are not limited to any specific product and may include advice regarding the following types of securities: exchange-listed securities, securities traded over- the-counter, foreign issuers, corporate debt securities (other than commercial paper), commodities, municipal securities, mutual fund (institutional shares), United States governmental securities, options, and/or alternative investments. Because some types of investments involve certain additional degrees of risk, it is the responsibility of the client’s Financial Adviser to determine if the investment is consistent with their client's stated investment objectives, tolerance for risk, liquidity, and suitability. Past performance is no indication of future results. Diversification does not ensure a profit or protect against a loss. Client Specific Rollover Advice A transfer of assets from a retirement account to an IRA, commonly known as a “rollover”, comes with advantages and disadvantages. Whether rolling over from an employer plan such as a 401(k) or 403(b) or from another type of IRA, it is important to consider all factors when deciding whether to leave assets in a current plan, roll to a new employer’s plan, roll to an IRA, or just liquidate the account assets. Among the things to consider are tax benefits and consequences, protection from creditors, differing products and services between relationships, withdrawal requirements and ages, and fees and costs of each type of account. New Frontier does not provide client specific advice regarding the transfer of client retirement assets to or from one account to another for client’s that access our portfolios through a Sponsor Firm Model or the Direct Model. Amount of Managed Assets As of 12/31/2023, New Frontier was actively managing $3,658,884,462 of assets invested in model portfolios on a non-discretionary basis through third-party Sponsor Firms. In the Direct Model, New Frontier was actively managing $79,392,967 on a discretionary basis.