Description of the Advisory Firm Human Interest Advisors LLC (hereinafter “Adviser”) is a Limited Liability Company organized in Delaware in June 2015. Adviser is a wholly owned subsidiary of Human Interest Inc. (“Recordkeeper”).
Adviser provides investment advisory services to employer-sponsored retirement plans (“Plans”) and plan participants (“Participants”). Adviser will provide either (i) fiduciary investment advice to the Plan to assist the Plan in developing and monitoring a menu of investment options as a 3(21) investment adviser or (ii) investment management services to the Plan to select, monitor, and revise the menu of investment options for the Plan as a 3(38) investment manager, each of these terms as defined under the Employee Retirement Income Security Act of 1976 (“ERISA”). In connection with the Adviser’s appointment to provide such services, the Adviser also agrees with Plan sponsors to make available its investment advisory services to Participants, who can opt to invest in a Model Portfolio (as defined below) that the Adviser recommends or select on their own from the Plan’s available investments (“Participant Selected Portfolio”). For Participants who do not make one of these selections, the Adviser will select a Default Allocation (as defined below). Participants will use an online platform to provide information about themselves and accept the Adviser's services.
Recordkeeper provides a digital platform that enables small and medium sized businesses to offer defined contribution retirement plans, such as 401(k) plans and 403(b) plans, to their employees. The digital platform is offered in multiple service levels, each with different administrative servicing features. Recordkeeper also provides recordkeeping and administrative services to the Plan as an agent of its sponsor (e.g., set-up, onboarding, payroll sync, and recordkeeping/administration). If a Plan engages Recordkeeper for its recordkeeping and administration services, then the Plan and its Participants also receive Adviser’s investment advisory services.
Types of Advisory Services Adviser provides investment advice with respect to limited types of investments, which currently are open-end mutual funds and cash equivalents, but which also may include exchange-traded funds, money market funds or similar investment vehicles, as well as separate accounts, collective investment trusts and other investments (“Investment Vehicles”), and its advice is limited to recommending these types of Investment Vehicles to Plans and Participants. The Adviser generates model portfolios that consist of target percentages for investment in certain of these Investment Vehicles (each a “Model Portfolio”). Except for Participant Selected Portfolios, every Participant will be invested in a Model Portfolio as recommended by the Adviser where once each quarter, Adviser will determine whether to rebalance Participant’s account based on the applicable Model Portfolio.
Plans The Adviser works with each Plan to develop the group of Investment Vehicles that become the investment menu for that Plan.
If a Plan chooses Adviser to act as an investment adviser under 3(21) of ERISA (“3(21) Fiduciary”), Adviser will assist the Plan to develop a menu of Investment Vehicles, and the Plan will make the investment menu available to Participants. When acting as a 3(21) Fiduciary, Adviser does not have the discretion to change the Plan’s investment menu. The investment menu developed by the Plan with the assistance of the Adviser will include the Investment Vehicles of the Model Portfolios as well as other Investment Vehicles chosen by the Plan. The Adviser will assist in monitoring the Advisers recommended Investment Vehicles, but will not provide monitoring and advice on Investment Vehicles not recommended by Adviser. The Plan retains all authority and responsibility to select the available Investment Vehicles. Participants are able to select their investments from their Plan’s investment menu, select from the available Model Portfolios, or use the Default Allocation.
If a Plan chooses Adviser to act as a fiduciary to the Plan pursuant to 3(38) of ERISA (“3(38) Fiduciary”), Adviser will develop and select a menu of Investment Vehicles to be provided to the Plan and therefore Participants. Adviser has discretionary authority to change the menu of Investment Vehicles and will monitor the Investment Vehicles. The investment menu developed by Adviser for the Plan will include the Investment Vehicles of the Model Portfolios, as well as other Investment Vehicles for the Participants, typically an additional 20-25 open-end mutual funds. Participants are able to select their investments from their Plan’s investment menu, select from the available Model Portfolios, or use the Default Allocation.
Participants Participants receive discretionary investment advisory services through investments in Model Portfolios, unless they choose a Participant Selected Portfolio. Participants can: (1) accept the Adviser’s recommended Model Portfolio based on information provided by the Plan and Participant, e.g., current age, and assumptions that Adviser makes regarding a Participant’s financial circumstances and preferred risk level; (2) complete or update such information, in which case the Adviser could recommend a different Model

Portfolio that the Participant can accept; (3) choose a Model Portfolio by indicating their risk tolerance; or (4) choose their own investments (a Participant Selected Portfolio). Not engaging on the platform to accept the Adviser’s recommended Model Portfolio or to select a Participant Selected Portfolio will result in a Participant receiving the Model Portfolio selected by the Adviser, i.e., the Default Allocation (discussed below).
For all but Participant Selected Portfolios, once each quarter, the Adviser will determine whether to rebalance Participant’s account to be aligned with the applicable Model Portfolio. Additionally, except for Participant Selected Portfolios and accounts of those that opt-out on the platform, Participants’ accounts will be opted into a “glide path,” which will result in the Participant’s Model Portfolio being adjusted to another Model Portfolio, with the goal of gradually reducing the expected risk of the Participant’s account as the Participant ages; the Adviser will then rebalance the account based on the replacement Model Portfolio, in the Adviser’s discretion. In reducing the risk of a Participant’s account, investment returns can also be reduced. The glide path is based on age bands selected by the Adviser from time to time, taking into account any risk information the Participant has provided, but such adjustment will not reflect an assessment of the Participant’s investment objectives or financial condition at the time.
Other than through this feature, the Adviser will not review the Participant’s account to determine whether a Model Portfolio continues to be appropriate or assess if another Model Portfolio would be better. However, a Participant can use the platform to update their information, and this process will result in the Adviser recommending a Model Portfolio.
For Participants who accept the Adviser’s recommended Model Portfolio, their portfolio will be rebalanced pursuant to the discretionary trading authority granted to Adviser.
Rebalancing is intended to assure that portfolios remain aligned with the Model Portfolio’s underlying allocation when Adviser can identify sufficient rebalancing opportunities (i.e., trades) to realign the actual Participant portfolio to the Model Portfolio’s allocation targets.
Participants are not required to accept any Model Portfolio that Adviser recommends and can choose their own investments by selecting from the available investment options in a Plan’s investment menu, i.e., the Participant Selected Portfolio.
Each Plan has designated the Adviser to provide investment advisory services as the qualified default investment alternative (“QDIA”) for the Plan. Thus, if a Participant has not engaged with the platform to accept a recommended Model Portfolio or to select a Participant Selected Portfolio, then the Adviser will manage a Participant’s account in accordance with a default Model Portfolio that the Adviser selects for a Participant based on the Participant’s current age (“Default Allocation”). The Adviser has the discretion to rebalance the Participant’s account to the Default Allocation as described above.
Client Tailored Services and Client Imposed Restrictions Plans If a Plan selects the Adviser to serve as a 3(38) fiduciary, Adviser selects the Plans’ Model Portfolios and other Investment Vehicles based on the Adviser’s investment policy statement and Advisers’ own due diligence on each Investment Vehicle. Plans that select the Adviser’s 3(38) fiduciary services cannot impose investment restrictions. Plans that would like to impose restrictions (e.g., remove an Investment Vehicle) can do so by selecting the Adviser’s 3(21) fiduciary service.
Participants As described above, Participants that use the platform receive a Model Portfolio recommendation that is based on information that the Adviser has received, e.g., current age, and assumptions that Adviser makes regarding a Participant’s financial circumstances and preferred risk level, and the Participant can make adjustments to such information to receive an updated Model Portfolio recommendation. However, Participants do not have to accept these recommendations. Instead, a Participant could choose any Model Portfolio by indicating their risk tolerance or, if a Participant prefers to select their own Investment Vehicle allocations, choose a Participant Selected Portfolio.
Participants that do not use the platform will receive a Model Portfolio based on their current age, also referred to as a Default Allocation, as described above.
In providing these recommendations and Default Allocations, the Adviser does not consider other assets held by the Participants or diversification of Participants’ entire portfolio of investments.
Assets Under Management As of December 31, 2023, Adviser had $3,448,251,436 in assets under management managed on a discretionary basis. While both Participants and Plans are clients, we count the assets under management attributable to Participants in a Plan once.
Separately, Adviser’s non-discretionary assets are assets under advisement on behalf of Participant Selected Portfolios and are not reflected above. The amount of non-discretionary assets under advisement on behalf of Participant Selected Portfolios as of December 31, 2023 was $697,212,005.