OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
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OneDigital Page 8 Form ADV, Part 2A various investment options each quarter. Those options that underperform are placed on a “watch list” and, if the underperformance continues, OneDigital may recommend or select another investment option(s). OneDigital also monitors the participants’ demographics and utilization of the selected investments to help ensure they have relevant choices and understand how to utilize those options to build a suitably diverse investment portfolio. One investment classification that is typically made available to plan participants is some type of money market or stable value fund, each of which has advantages and disadvantages. In particular, money market funds, which are designed to maintain a steady net asset value of $1 per share, provide more liquidity but lower returns than stable value funds, which invest in high quality, short- to intermediate-term bonds. In addition, because some recordkeeping platforms require the utilization of their own money market or stable value fund, OneDigital may not have the ability to recommend other alternatives without requiring that the plan switch recordkeepers. When OneDigital is managing a plan’s pooled investments, it applies Modern Portfolio Theory to develop an investment strategy that is appropriate for the plan’s objectives. Specifically, OneDigital will consider the plan’s current funding status, the demographics of its intended beneficiaries, and annual investment return needs to construct a portfolio that adequately balances the plan’s investment risks and growth requirements. For its Personalized Portfolios program, OneDigital will either utilize investment options available in the plan’s core lineup or collective investment trusts (“CITs”) it manages through Alta Trust. OneDigital then typically employs a sub-adviser to use its proprietary algorithms to construct a customized allocation for each participant based upon information (age, gender, income, current savings, etc.) provided by the plan’s recordkeeper. The CITs are not registered as mutual funds under the Investment Company Act of 1940, as amended, or as securities under the Securities Act of 1933, as amended. As a result, participants invested in those CITs are not entitled to the protections of those statutes. Instead, the CITs are regulated by state banking authorities and the Office of the Comptroller of the Currency, which is part of the U.S. Treasury. In addition, they are subject to oversight by the IRS and Department of Labor. OneDigital prefers to utilize CITs when possible because they generally charge lower fees than comparable mutual funds. Although OneDigital serves as the investment manager for those CITs, it does not receive a fee or other compensation for providing those services. Instead, the only compensation OneDigital receives for its Personalized Portfolio program is the investment management fee listed on the client’s agreement. Clients must remember that investing in securities involves risk of loss, which they should be prepared to bear. These risks include, but are not limited to, market risk, interest rate risk, currency risk, foreign investment risk, and political risk, among others. No investment strategy, nor the use of a third-party manager, can assure a profit or avoid a loss, and OneDigital does not guarantee any level of investment returns. Item 9 – Disciplinary Information Neither OneDigital nor any of its management persons have been the subject of any legal or disciplinary events that are material to an evaluation of OneDigital’s advisory business or the