As part of our ongoing commitment to transparency and regulatory compliance, we are providing you with this annual disclosure in accordance with the requirements under the Employee Retirement Income Security Act of 1974 (“ERISA”), Internal Revenue Code section 4975, and related best practices. This notice confirms and reiterates key information related to our fiduciary relationship, the services we provide, and your responsibilities as a plan fiduciary or IRA owner.
We acknowledge our status as a fiduciary with respect to the retirement assets we manage. For ERISA plans, we serve as an “investment manager” within the meaning of ERISA. For IRAs and Non-ERISA Plans, we act as a fiduciary to the extent of the assets under our management.
The plan sponsor, plan administrator, trustee, or IRA owner (“you”) has confirmed the following representations in the Investment Management Agreement and should review them annually to ensure they remain accurate:
- you have the authority to appoint us as investment manager; you have reviewed and approved the reasonableness of our fees;
- you understand and have considered the investment objectives, risks, and liquidity needs of your plan or IRA;
- you have ensured that your plan remains diversified, where applicable; and
- you agree to notify us promptly of any changes to plan information, fiduciary contacts, or investment restrictions.
Please consider these representations and ensure that your agreement is still current and accurate, as are the individuals authorized to negotiate with us on behalf of the plan and any restrictions on investing in employer or affiliate securities. If any of this information has changed or becomes outdated, please notify us promptly.
We continue to provide the investment advisory services outlined in our agreement at the fees outlined our agreement. These services and fees remain reasonable and appropriate for your retirement account, as required by ERISA or the Internal Revenue Code.
In the event of a material error or change to our arrangement, investment approach, or fee structure, you will receive written notice within 30 days of discovering any error and a disclosure update within 60 days of any material change to our fiduciary status, investment approach, or compensation practices.
If you have questions, updates, or would like to schedule a review of your retirement account and investment strategy, please contact us and we’ll be glad to review. We thank you for the trust you’ve placed in us and look forward to continuing to serve you and your retirement goals.