Newfront Retirement Services, Inc.

• A percentage of assets under your management
• Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

Account minimum: None

As stated in the firm's Form ADV Part 2A brochure dated August 4, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$1,038,896,040 as of October 2026, filing dated September 30, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Pension consulting services

Also doing business as

WILLIS TOWERS WATSON ("WTW")

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2014 (12 years)

Employees

Total: 30. Performing investment advisory functions: 26.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Empower Financial Services, Inc.Fidelity Management Trust Company

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

2 other offices, as of the October 2026 filing

San Francisco, CAWalnut Creek, CA

States registered or notice-filed

17 states or jurisdictions

AZCACODEFLGAILMANHNVNYPASCTXUTVAWA

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $125,000,000 in the October 2021 data and $1,038,896,040 in the October 2026 data, up 731%.

Total employees: 16 in October 2021 and 30 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. October 2026
   • Added the business name Willis Towers Watson ("WTW").
2. September 2026
   • Updated its list of owners and control persons (Schedule A).
3. August 2026
   • Employees performing advisory functions went from 25 to 26.
   • Registered or notice-filed in GA, PA.
   • Updated its list of owners and control persons (Schedule A).
4. March 2026
   • Employees performing advisory functions went from 19 to 25.
   • Regulatory assets under management went from $649,333,744 to $1,038,896,040 (+60%).
   • Added an office in San Francisco, CA.
   • No longer lists an office in Roseville, CA.
   • Registered or notice-filed in NV.
   • Updated its list of owners and control persons (Schedule A).
5. January 2026
   • No longer registered or notice-filed in TN.
6. December 2025
   • Registered or notice-filed in DE, IL.
7. November 2025
   • Added an office in Roseville, CA.
   • No longer lists an office in Irvine, CA.
   • No longer lists an office in New York, NY.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.