NLFP offers a variety of advisory services which include financial planning, consulting and investment management.
Prior to rendering any of the foregoing advisory services, clients are required to enter into one or more written
agreements with NLFP setting forth the relevant terms and conditions of the advisory relationship (the “ Agreement ”).
NLFP provides strategic investment management and seeks to monitor and rebalance client portfolios to maintain an
efficient risk/return tradeoff and manage portfolio risk. To that end, the Firm will analyze client information to assess a
client’s current situation, define their goals and determine what should be done in order to meet those goals. Depending
on what services the Firm is engaged to provide, this could entail analyzing client assets, liabilities and cash flow, current
insurance coverage, investments, tax strategies, and other personal goals and desired outcomes. The Firm believes an
approach that carefully monitors client portfolios and leverages technology to effectively manage client assets plays a
central role in meeting client objectives.
NLFP has been an independent registered investment adviser since March, 2013 and is principally owned by Bryce P.
Carey and Eric M. Garsin.
While this brochure generally describes the business of NLFP, certain sections also discuss the activities of its
Supervised Persons , which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or
performing similar functions), employees or any other person who provides investment advice on NLFP’s behalf and is
subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
NLFP offers clients a range of financial planning and consulting services, which may include any or all of the following
functions:
● Cash Flow Planning ● Insurance Needs Analysis
● Asset Allocation ● Retirement Planning Analysis
● Estate Planning ● Risk Management
● Investment Consulting ● Retirement Income & Distribution
While each of these services are available on a stand-alone basis, certain of them may also be rendered as part of a
comprehensive client engagement (as described below). The Firm can be engaged for either Basic or Advanced
services as part of The Financial Clarity Advantage (“FCA”) process which includes financial planning and consulting.
NLFP typically will analyze and review data and documents provided by clients, evaluate a client’s ability to meet
objectives, provide observations, identify problems and recommend strategies. A client will receive a summary which
reflects their current financial circumstances, financial outlook, personal prerogatives and objectives in any one or all of
the above-mentioned function areas.
In performing these services, pursuant to the FCA process, NLFP is not required to verify any information received from
the client or from the client’s other professionals (e.g. attorneys, accountants, etc.) and is expressly authorized to rely on
such information. From time to time and when appropriate for a particular client, NLFP will recommend the services of
itself, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a
broker-dealer, and/or other professionals to implement its recommendations.
Clients are advised that there is a conflict of interest if NLFP recommends its own services for implementation. Clients
retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by NLFP under a financial planning or consulting engagement or to engage the services of any
such recommended professionals, including NLFP itself. Clients are advised that it remains their responsibility to
promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating or revising NLFP’s previous recommendations and/or services.
Investment Management Services
NLFP manages client investment portfolios primarily on a discretionary basis but may also manage portfolios on a
non-discretionary basis.
NLFP principally allocates client assets among exchange-traded index funds (“ETFs”) and may allocate assets among
mutual funds. Individual equity and debt securities may also be employed in Personalized Asset Management Accounts
(PAMA). Further, the Firm may allocate funds among the securities components of variable annuities and variable life
insurance contracts, in accordance with the investment objectives of its individual clients. In addition, NLFP may also
recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest
in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles. Where
appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client
portfolios.
Clients may also engage NLFP to advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts,
and assets held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In these situations, NLFP directs or recommends the allocation of client
assets among the various investment options available within the product. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
NLFP tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client
portfolios are managed in a manner consistent with their specific investment profiles. NLFP consults with clients on an
initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity requirements and other factors
relevant to the management of their portfolios. Clients are advised to promptly notify NLFP if there are changes in their
financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose
reasonable restrictions or mandates on the management of their accounts if NLFP determines, in its sole discretion, the
conditions would not materially impact the performance of a management strategy or prove overly burdensome to the
firm’s management efforts.
Variable Annuities
As mentioned above, NLFP may also recommend and provide ongoing advice on variable annuities. This service will be
based upon an agreement in place between NLFP and our client(s). When providing advice on variable annuities, our
advice is limited to those investment options made available by the insurance company. Further, limitations on frequency
of trading or rebalancing will vary according to each sub-account’s restrictions. We describe the fees charged below
under Item 5 – Fees and Compensation. We describe the material investment risks for many of the securities that we
utilized/recommend under Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.
Use of Independent Managers
As mentioned above, NLFP may recommend certain Independent Managers to actively manage a portion of its clients’
assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a
separate written agreement between the designated Independent Manager and either NLFP or the client . In addition to
this brochure, clients also receive the written disclosure documents of the designated Independent Managers engaged to
manage their assets.
NLFP evaluates various information about the Independent Managers chosen to manage client portfolios. The Firm
generally reviews a variety of different resources, which may include the Independent Managers ’ public disclosure
documents, materials supplied by the Independent Managers themselves, and other third-party analyses it believes are
reputable. To the extent possible, the Firm seeks to assess the Independent Managers ’ investment strategies, past
performance and risk results in relation to its clients’ individual portfolio allocations and risk exposures. NLFP also takes
into consideration each Independent Manager ’s management style, returns, reputation, financial strength, reporting,
pricing and research capabilities, among other related factors.
NLFP continues to provide services relative to the discretionary or non-discretionary selection of the Independent
Managers . On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers by reviewing the summary account statements and trade confirmations produced by the Financial Institutions ,
as well as other performance information furnished by the Independent Managers and/or other third-party providers.
NLFP seeks to ensure the Independent Managers ’ strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests.
NLFP does not participate in any wrap fee programs.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest
and not put our interest ahead of yours. Under this special rule’s provisions, we must:
● Meet a professional standard of care when making investment recommendations (give prudent advice);
● Never put our financial interests ahead of yours when making recommendations (give loyal advice);
● Avoid misleading statements about conflicts of interest, fees, and investments;
● Follow policies and procedures designed to ensure that we give advice that is in your best interest;
● Charge no more than is reasonable for our services; and
● Give you basic information about conflicts of interest.
NLFP manages the following amount of discretionary and non-discretionary client assets calculated as of December 31,
2022:
i. Discretionary: $195,892,740
ii. Non-Discretionary: $2,534,741
iii. Total: $198,427,481