OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
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OneDigital Page 7 Form ADV, Part 2A of the selected product. Those services, however, are not considered to be investment advice given to a retirement plan. When OneDigital’s employees or IARs recommend commissioned-based products in the above situations, a conflict of interest arises because the recommendation to purchase the product may have been influenced by the commission compensation to be received, rather than solely on the needs and best interests of the client. OneDigital addresses this conflict of interest by disclosing the conflict in this Disclosure Brochure and reminding clients that they are no obligation to use the brokerage or insurance services of such employees or IARs. Item 6 – Performance Based Fee and Side-by-Side Management Neither OneDigital nor any IAR of OneDigital accepts performance-based fees. Item 7 – Types of Clients OneDigital provides investment advisory and management services to the sponsors of many distinct types of retirement plans that are eligible for tax deferment under the Internal Revenue Code. It also provides investment management services to the participants of defined- contribution plans. There is no minimum amount of assets required for OneDigital to provide these services. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss For ERISA qualified, participant-directed, defined-contribution plans, OneDigital’s first concern is to ensure the plan complies with ERISA §404(c)’s requirement by offering a “broad array” of investment options to enable participants to develop a diversified portfolio. If the plan already has an IPS, OneDigital analyzes the investment options offered through the plan’s platform provider to help ensure there is adequate representation of investment categories for the plan’s participants to select from to construct a diversified portfolio. If the plan does not have an IPS, OneDigital can work with the plan to draft one to guide the plan fiduciaries’ oversight of its investment options. Once the investment categories are identified, OneDigital further refines them into the investment styles offered within each category. OneDigital then analyzes the choices available within each classification based upon investment style (including style consistency), risk and return characteristics, and performance versus the peer group median. Qualitative factors, such as the investment’s operating expenses and tenure of its investment manager are also considered. Based upon this analysis, OneDigital will recommend or select the investment options it believes are best suited to be made available to a plan’s participants. Thereafter, OneDigital scores the