OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
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OneDigital Page 14 Form ADV, Part 2A Employees of OneDigital and its affiliates, including, but not limited to Digital Insurance LLC, are also eligible to receive additional compensation when they successfully refer new clients to OneDigital. The payment of additional compensation in exchange for the successful referral of new business creates a material conflict of interest for such employees. OneDigital addresses this conflict of interest by disclosing the conflict in this Disclosure Brochure and reminding clients that they are under no obligation to engage OneDigital for services. Referral Fees Paid by Digital Insurance Employees of OneDigital are also eligible to receive additional compensation when they successfully refer new clients to Digital Insurance LLC and/or to its other affiliates. The payment of additional compensation to OneDigital employees in exchange for the successful referral of new business to Digital Insurance LLC and/or its other affiliates creates a material conflict of interest for such employees. OneDigital addresses this conflict of interest by disclosing the conflict in this Disclosure Brochure and reminding clients that they are under no obligation to utilize Digital Insurance LLC’s or its other affiliates’ products and/or services. Item 15 – Custody OneDigital does not hold custody of retirement plan clients’ assets. Instead, retirement plan clients must contract separately with a broker-dealer, insurance company, or trust company for custodial services. Pursuant to ERISA, OneDigital must be bonded when it has “control” over plan assets, which would include when it manages participants’ investments or a plan’s pooled assets. However, because it does not have authority to withdraw or transfer those assets out of the plan, OneDigital is not deemed to have “custody” of those assets under the Investment Advisers Act of 1940. Instead, most recordkeepers calculate and pay OneDigital’s fees based upon authorization provided by the retirement plan’s administrator. Item 16 – Investment Discretion OneDigital can act as either the investment adviser or investment manager for a retirement plan client. If OneDigital is acting as the investment manager for a plan consisting of pooled assets or for a participant in a participant-directed account, its agreement with the client will include a limited power of attorney granting OneDigital discretionary authority to initiate investment transactions of the plan’s or participant’s assets. If OneDigital is acting as the investment manager for a plan in which participants direct their own investments, that limited power of attorney will provide OneDigital with authority to add, remove, or replace the investment options offered through the plan without prior notification to, or the consent of, the plan’s named fiduciaries. OneDigital will make these decisions consistent with the plan’s investment objectives, as noted in its IPS or as communicated to OneDigital during its discussions with the plan’s named fiduciaries. In addition, retirement plan clients can designate specific restrictions on the investments to be held or offered through the plan on the management agreement and are