OneDigital - retirement Plan Investment Management Agreement - 06.01.2026 - SIGNED
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OneDigital Page 11 Form ADV, Part 2A securities transactions and holdings of its access persons for any activity that may indicate a violation of OneDigital’s Code of Ethics. Item 12 – Brokerage Practices Recommending Broker-Dealers Pursuant to ERISA, the plan’s administrator is responsible for (1) approving the party or parties that will process the participants’ trades and (2) monitoring their fees. Therefore, with the exception of newly-created plans, most retirement plan clients already have established relationships with a recordkeeper that typically provides custodial and brokerage services through a related broker-dealer, insurance company, or trust company. Similarly, for plans consisting of participant-directed investment accounts, the plan’s named fiduciaries will have sole authority to select the broker(s) that will process transactions in those accounts – even if OneDigital is managing the participants’ accounts. Therefore, unless the plan sponsor requests OneDigital’s assistance in replacing the recordkeeper, OneDigital has limited influence on the plan’s brokerage services and the plan sponsor is responsible for negotiating all terms and conditions with such recordkeeper, including any applicable brokerage commissions and/or transaction fees. For those plans that do not have these relationships in place, OneDigital will provide retirement plan clients with recommendations for vendors who can serve these needs at the plan fiduciaries’ request. In the event a broker-dealer is selected as the custodian of a retirement plan account consisting of pooled assets, OneDigital will process all trades in the account through that custodian. OneDigital will not seek best execution for the client and, consequently, clients may pay higher commissions or other transaction costs, or receive less favorable execution for their transactions, than if they shopped for a broker-dealer to handle each transaction. OneDigital has developed relationships with entities that provide brokerage, custodial, and recordkeeping services, as well as investment products, to retirement plans, which it may recommend to clients that include Charles Schwab & Co., Inc. and/or its affiliates (collectively, “Schwab”), Fidelity Brokerage Services LLC and/or its affiliates, including, but not limited to, Fidelity Institutional Wealth Adviser LLC (collectively, “Fidelity”) as well as other recordkeepers (collectively with Schwab and Fidelity, “Preferred Vendor”). Preferred Vendors may also recommend OneDigital to their clients who are searching for an investment adviser and, in some case, partner with OneDigital to submit a combined bid. Clients should be aware that many custodians or recordkeepers offer, or require retirement plan clients to utilize, their proprietary investment products (including without limitation, their stable value funds), which provide additional revenue to these companies. Research and Additional Benefits Schwab and Fidelity as well as other Preferred Vendors make available to OneDigital, without cost and/or at a discount, support services and/or products, some of which assist OneDigital in better monitoring and servicing all client accounts, some of which benefit only those clients