OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
Open official source ↗ · Source page 21
OneDigital Page 9 Form ADV, Part 2A integrity of its management. IARs of OneDigital, including those that are management persons, who provide discretionary investment advice or meet with clients and provide non-discretionary investment advice are required to provide affected clients with a copy of their Form ADV, Part 2B (i.e., brochure supplement), which includes disclosure of any legal or disciplinary events material to a client’s or prospective client’s evaluation of the IAR. Item 10 – Other Financial Industry Activities and Affiliations Registered Representatives: Certain IARs, including OneDigital’s President, in their individual capacities separate from OneDigital, are registered representatives of broker-dealers that are unaffiliated with and independent of OneDigital (“Registered Representatives”) and, in such capacity, may recommend and/or sell certain investment products on a commission basis to clients. The receipt of commission compensation by Registered Representatives, however, creates a conflict of interest as the recommendation to purchase an investment product may have initially resulted from one or more services provided to the client by OneDigital and may have been influenced by the commission compensation to be received, rather than solely on the needs and best interests of the client. Because of this conflict of interest, neither OneDigital nor its IARs are permitted to receive any brokerage commissions generated from securities OneDigital recommended to retirement plan clients or their participants in its capacity as their investment adviser/manager, except to the extent those commissions are used to offset OneDigital’s advisory fee. Insurance Agents: OneDigital (NPN# 20712934) and some of its affiliates that either control or are under common control with OneDigital are licensed insurance agencies and IARs may be licensed insurance agents (collectively with OneDigital and its affiliated insurance agencies, “Insurance Agents”) and, in such capacities, may recommend and/or sell certain insurance products, such as fixed, variable, or group annuities, for individuals or entities on a commission basis to clients of OneDigital. The receipt of commission compensation by Insurance Agents, however, creates a conflict of interest as the recommendation to purchase an insurance 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 these conflicts of interest by disclosing them in this Disclosure Brochure and reminding clients that they are under no obligation to use the insurance services of Insurance Agents. Digital Insurance LLC (NPN# 3698440): OneDigital and/or its IARs may recommend that clients engage Digital Insurance LLC, a licensed insurance agency and parent company of OneDigital, for the provision of (1) tax, (2) corporate advisory/business consulting, and/or (3) insurance services either in conjunction with OneDigital’s service offerings as part of a comprehensive suite of services or on a stand-alone basis. As such recommendation may result in a financial benefit to OneDigital’s parent company, OneDigital and/or its IARs have a conflict of interest when recommending the services of Digital Insurance LLC to clients. Clients are reminded that they are under no obligation to utilize Digital Insurance LLC’s products and/or services. Model Managers: BlackRock Fund Advisors and/or BlackRock Investments, LLC; Fidelity Institutional Wealth Adviser LLC; Dimensional Fund Advisors LP; American Century Investment Management Inc.; T. Rowe Price Associates, Inc.; Pacific Investment Management