Financial Engines Advisors L.L.C. ("FEA" or “Edelman Financial Engines” or the “Firm”) is an investment advisory
firm registered with the United States Securities and Exchange Commission (“SEC”). FEA provides
comprehensive financial advisory services to clients to help them meet their financial and retirement goals. We
offer a suite of services that provide different levels of interaction with FEA based upon the unique needs of
each client. We are a fiduciary for our advisory services, and none of our planners receive commissions or fees
tied to the sale of certain types of products (see Item 10 for more information on commissions and fees).
FEA was established in 1997; Edelman Financial Services was founded in 1986. On November 1, 2018,
Financial Engines Advisors L.L.C. (sometimes referred to as “legacy FE” or “legacy Financial Engines”) and
Edelman Financial Services, LLC (sometimes referred to as “legacy EFS” or “legacy Edelman Financial”) came
together under the FEA ADV to offer investment advisory services to clients. The name of the registered
investment advisor remains Financial Engines Advisors L.L.C.; our overall business primarily operates using the
name "Edelman Financial Engines". In all circumstances, advisory services are provided by Financial Engines
Advisors L.L.C., the investment advisory firm registered with the SEC.
The principal owner of FEA is Edelman Financial Engines, LLC. The ultimate parent company of Edelman
Financial Engines, LLC, and in turn FEA, is Edelman Financial Engines, L.P.1
I. Overview of Advisory Services
Edelman Financial Engines provides technology-enabled investment advisory services, including financial
planning, investment management and retirement income solutions, for a variety of account types including
employer-sponsored defined contribution accounts (401(k), 457, and 403(b) plans), individual retirement
accounts (“IRAs”), and taxable accounts. We help individuals, either online, through one of our tools or with an
advisor representative, develop a strategy to help them reach their investment and retirement goals. We do this
by offering a comprehensive set of services, including holistic, personalized plans for saving and investing,
assessments of potential retirement income levels in a variety of scenarios, and the option to speak on the
phone or meet face-to-face with an investment advisor representative. As further explained below, our services
generally can be accessed either through the workplace, online or through one of our investment professionals.
Advisory services are tailored to the individual needs of clients, and clients can impose reasonable restrictions
on relevant accounts in consultation with us. Clients participate in a wrap fee program offered by the Firm, for
which we receive a portion of the wrap fee for our services.
Edelman Financial Engines works to ensure that clients are engaged with services and tools that will help them
achieve their long-term goals in a manner that is appropriate for their needs. Edelman Financial Engines
maintains practices to reasonably ensure that clients are directed towards services which will help them work
towards those goals in a method that is in their best interest. Edelman Financial Engines has acquired or may
acquire certain advisory clients through acquisitions or otherwise. Those clients will generally transition to
Edelman Financial Engines models, practices, and methodologies over time in a reasonable manner. For an
interim period, they may remain invested, and have their accounts managed and administered, in the manner
they were at their legacy firms; including in connection with individual equities, alternative assets, and other
holdings established prior to acquisition by EFE.
1 Ric Edelman was a co-founder and employee of Edelman Financial Engines. He ceased being an employee and
supervised person of the Firm in December 2021.
When we provide investment advice or recommendations to clients regarding their retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we are compensated creates some conflicts with our clients’ interests, so we at
times operate under a special rule of the US Department of Labor (“DOL”), Prohibited Transaction Exemption
(“PTE”) 2020-02, which requires us to act in their best interest and not put our interests ahead of theirs.
Under the PTE’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of our clients’ when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the client’s best interest;
• Charge no more than is reasonable for our services; and
• Give clients basic information about conflicts of interest.
II. Discretionary Advisory Services Offered through the Workplace
Through a variety of service offerings, Edelman Financial Engines works with participants who have invested in
their employer’s retirement plans to manage their workplace retirement accounts and help them reach their
retirement goals. The Firm offers the following services for employees’ workplace retirement and other
accounts through an agreement between the Firm and the plan and/or the sponsoring employer (“plan
sponsor”).
Professional Management
Edelman Financial Engines helps plan participants by providing discretionary investment management for their
retirement plan accounts through the Firm’s Professional Management service. That service includes the
following features:
• a Retirement Plan or similar document outlining how the Firm will manage and allocate the account. This
can include, for example, the account’s portfolio allocation target, suggestions regarding the client’s savings
and a forecast regarding their likelihood of achieving their self-articulated retirement goals;
• periodic portfolio monitoring:
o updates on current retirement account balances and estimated contributions, and a retirement
income forecast;
o the Firm provides suggestions for ways to modify the income forecast, set appropriate risk
levels, and get a more holistic picture of likely retirement finances; and
o Quarterly Retirement Updates outlining, among other things, how the account is performing against
goals;
• phone access to investment advisor representatives as well as online account access;
Professional Management is generally made available to plan participants in a defined contribution plan through
an agreement between the Firm and the plan sponsor. That agreement will specify the methods of enrollment
into Professional Management for eligible plan participants, which may include:
• an “opt-in” method of enrollment where a retirement plan participant actively elects to enroll in the
program;
• an “opt-out” method of enrollment where eligible plan participants are automatically enrolled in
Professional Management in accordance with plan or plan sponsor specifications, with the ability to
withdraw at any time without penalty. With this type of enrollment, Professional Management may be
designated as a qualified default investment alternative (“QDIA”), as permitted under ERISA; or
• some combination of both methods, as determined by the plan or plan sponsor and as agreed to by the
Firm.
Plan participants who enroll in Professional Management grant the Firm discretionary authority to determine an
allocation target for the plan account based upon a variety of inputs provided to the Firm and then to direct the
plan provider to execute transactions in a manner designed to achieve that target. This discretionary authority
allows the Firm to allocate the client’s plan account among the menu of investment alternatives that have been
selected by the plan or plan sponsor, excluding any brokerage window option (if applicable) or other plan
restricted investments.
To allow the Firm to provide Professional Management, the plan provider supplies information about each plan
participant and the plan account to the Firm. Professional Management clients may provide additional
information to the Firm concerning a variety of inputs, including desired retention of company stock, risk
preference, asset class exposure limitations, assets held outside the plan, investment objective, and desired
retirement age.
The Firm determines an investment strategy and an allocation target based on a reasonable understanding of
what is in the best interest of the client, including by considering the client’s current age, an assumption about
the retirement age, the available investments for the account, any pension plan information provided, an
assumption about risk tolerance that is based on the client’s current age and assumed retirement age, the
client’s current portfolio allocation, and any additional information provided by the client. Additional
information provided by the client may modify these parameters.
During the period following enrollment, the Firm determines how to transition the account toward the
allocation target, directs the plan provider regarding allocation of the account (which may include transfer or
exchange directions) and provides directions regarding new contributions to the account. The Firm does not give
account directions relating to plan restricted investments. Certain plan sponsor “insiders,” as defined under
applicable regulations, and non-U.S. participants in plans, may not be eligible for the Professional Management
program.
Income Beyond Retirement
Professional Management clients may also, if their plan provider has elected to offer this service and if available
under the plan sponsor’s agreement with the Firm, access the Firm’s “Income Beyond Retirement” feature. This
service provides portfolio management and income payout options to retirees and near retirees from their
401(k) or similar plan account. For those who elect this feature, the Firm manages the
client’s portfolio to balance between safety and growth, seeking to protect the ability of the account to
generate future income. Income Beyond Retirement also allows additional flexibility for a client to select what
portion of their managed account is managed on our standard “growth” objective, and what portion is managed
on an “income” objective. Income Beyond Retirement seeks to manage investments and to create payouts that
can generally last clients into their early 90s. Upon request, in addition to managing the investment allocations
in such accounts, the Firm will work with the plan provider to calculate and facilitate withdrawals from the
client’s plan account post-retirement. The Firm does not receive any additional compensation for providing the
Income Beyond Retirement service.
Professional Management clients at certain plan sponsors may have access to the Income+ feature of
Professional Management, a predecessor feature to Income Beyond Retirement. Income+ offers many of the
same features as Income Beyond Retirement but does not permit Professional Management members to select
what portion of their account is managed on a “growth” or “income” objective; instead, the member’s account
will be managed on an “income” objective only.
Clients pay no additional fees for the Income Beyond Retirement or Income+ features, and they can transition to
an Income Beyond Retirement/Income+ portfolio either automatically upon eligibility or at their request (as
defined, in part, by the agreement between the Firm and the relevant sponsor). An account balance is maintained
for an optional out-of-plan annuity purchase. An in-plan annuity need not be included in a plan’s investment
lineup for a plan sponsor to offer Income Beyond Retirement or Income+ to its participants. While the Firm may
provide general educational information regarding an out-of-plan annuity, it does not sell or distribute annuities
and does not receive any compensation related to out-of-plan annuity purchases made in relation to the Income
Beyond Retirement or Income+ features.
Income Beyond Retirement and Income+ availability is subject to establishment of certain data connectivity
arrangements between the Firm and the applicable plan provider and is subject to applicable retirement plan
provisions related to plan withdrawals.
Workplace IRA
Where previously available, plan participants who already have a managed workplace account may have had
access to the Firm’s “Workplace IRA” offering, a fee-based individual retirement account (“IRA”)
management service offered through the workplace. In some limited circumstances, IRA management
services may also have been available to spouses as well as to the plan participants.
Personal Advisor
If available under the plan sponsor’s agreement with the Firm, plan participants can access our Personal Advisor
service. Personal Advisor is a holistic investment advisory service which provides access to a planner and
investment management on the participant’s workplace account (as described in the Professional Management
section above) and can also provide discretionary investment management on non-workplace assets. The non-
workplace assets are invested in either a customized portfolio generated from the Firm’s advice platform or in a
model portfolio. Plan participants who select the Personal Advisor service pay an additional fee, as described in
Item 5. Personal Advisor requires use of one of the custodians utilized in the Firm’s Wrap Fee Program for the
participant’s non-workplace assets, as described in Item 12. For plan participants who do not have access to the
Personal Advisor service, comparable investment management of their non-workplace accounts may be
available directly through a planner, as described in Section IV below.
III. Sub-Advisory Services
In addition to providing investment advisory and related services directly to clients under arrangements with
employer-sponsored plans and plan sponsors, the Firm also has arrangements with certain third parties to
provide similar services on a sub-advisory basis. The Firm may license certain technology and software and
provide other services to financial services firms to enable those firms to provide investment advisory and
related services. For example, the Firm may develop and host customized or private-labeled websites to enable
a financial institution to make investment advisory and related services available to that institution’s clients.
Depending on the arrangement with the financial institution, the Firm may act as sub-advisor to the financial
institution, or the Firm may act as a technology vendor and the financial institution will be responsible for
making investment recommendations to its clients. Additionally, at the direction of the third party the firm
may conduct phone-based engagements with plan participants in its capacity as sub-advisor and designated
investment expert under applicable DOL rule.
IV. Discretionary Advisory Services through Planners
Edelman Financial Engines offers investment advisory services for qualified and taxable accounts through
planners working in one of our offices nationwide. These services include making and implementing investment
decisions for clients based on their needs and providing ongoing advice. In consultation with a client and after
consideration of their goals, risk tolerance, investment horizon, and needs, planners will typically prepare a
financial plan which takes these factors into consideration and most typically recommend a Firm created model
offered through the Firm’s Wrap Fee Program. At times we may also recommend a more customized set of
investments for a client whose needs are better served outside of one of the standard models offered by the
Firm, including where the Firm has acquired assets and clients through acquisition. For more information on
the Firm’s Wrap Fee Program, please see our Wrap Fee Brochure. Generally, clients who have investable assets
below a certain threshold and/or who have less complex financial needs and
therefore may not need the same services offered by planners working in an office (including the ability to meet
in person) will usually work with a centralized, team-based group of professionals who can help provide services
which are more appropriate to such clients’ needs. The fee for working with dedicated planners in an office is
the same as that for working with professionals in a team-based approach and is outlined in Item 5.
Model portfolios and custom models available through the Wrap Fee Program feature allocation appropriate
for each client and their needs. The investments in these accounts include, but are not limited to, equities,
cash or cash equivalents, CDs, bonds, and funds registered under the Investment Company Act of 1940, for
example, closed-end funds, mutual funds, and exchange traded funds (“ETFs”)
(collectively referred to as “securities”). Cash equivalent products may include mutual funds and/or ETFs, as well
as Federal Deposit Insurance Corporation (“FDIC”) insured bank certificates of deposit, or other types of holdings
as appropriate. Investments may range across various asset classes.
The securities, asset categories and portfolio weightings vary for each model. In order to determine the model
most suited to a client's needs and circumstances, planners speak with clients to discuss their specific situation
and review various information provided. Investment objectives and risk tolerance are key factors that help
planners recommend an appropriate model. Planners also consider other inputs which can include, but are not
limited to, the client’s age, health, family circumstances, income, expenses, assets, debts, liquidity needs, goals,
personal objectives, and time horizon. Tools are available to help planners and clients choose a model. If a
client’s investment objectives, risk tolerance or financial situation changes, they are instructed to contact their
planner so that appropriate changes, if any, can be discussed and implemented.
Edelman Financial Engines generally manages client accounts and the assets within them on a discretionary
basis, in accordance with the client’s objectives and goals. There are also situations where certain assets may be,
for some period of time, held in a client’s account without being managed by the Firm. Unless a different
arrangement is agreed to with a particular client, we will not assess an advisory fee for such assets held within
an account for longer than what might be considered reasonable under specific circumstances.
Clients may request reasonable restrictions on the types of investments that will be made on their behalf or on
the management of their account. A client will ultimately be placed in a model or allocation that the Firm
believes is in their best interest and meets their needs, and which allows for such reasonable restrictions as
appropriate. A client cannot usually request that we buy specific holdings or types of holdings, although
exceptions may be granted. We reserve the right, at our sole discretion, to close an account (or decline to open
one) if overly constraining restrictions are requested or the restrictions requested are incompatible with the
client’s objectives and/or the portfolio recommended.
The Firm offers clients the ability to aggregate and share with Edelman Financial Engines
information concerning
other investment and financial accounts established through or held with third parties. While aggregating and
sharing such information does not mean that Edelman Financial Engines will manage or advise on those outside
accounts, it does help our planners offer more holistic and personalized investment advice to our clients. It is up
to each client to decide whether to share such information.
Planners generally prepare and/or discuss a financial plan for prospective clients prior to the commencement
of advisory services. As discussed above, this financial plan is based on a variety of factors provided by the
client and is designed to assist them in achieving their stated goals and objectives. The financial plan will
evolve as we learn more about the client and as their circumstances change. Whether to implement the
financial plan with Edelman Financial Engines or elsewhere is entirely at the client’s discretion. Clients who
choose to implement the financial plan elsewhere will not receive ongoing investment advice from the Firm.
The Firm may also offer a retirement review to prospective clients in certain marketing campaigns. The Firm
may, at its sole discretion, decline to assist a client with the implementation of investment strategies or
choices that have not been recommended or that we deem not to be in the client’s best interest.
Our objective is to provide services which are in the best interest of our clients. A conflict of interest exists for
our planners as they have an economic incentive to offer certain advisory services, including recommending
rollovers to clients from defined contribution, defined benefit, and other plans. This applies to those services
for which the advisory fee that Edelman Financial Engines charges, and the compensation that the planner
receives, is a function of the assets under management. With respect to rollovers from qualified plans, clients
are under no obligation to roll them over to Edelman Financial Engines and should carefully consider all
relevant factors before doing so.
While Planners may discuss tax topics, generally, in the context of providing holistic financial planning for
certain clients, Planners do not provide legal or actionable tax advice. Clients are advised to work with an
attorney or accountant on matters requiring legal or tax counsel. Planners may also at times refer clients to
certain other third-party service providers, who could potentially assist them with their needs. In such
situations, the Firm introduces the client to the service provider, who then works directly with the client to
assist them with those services. The Firm is not compensated for such introductions to these third-parties.
Additionally, Edelman Financial Engines, through an affiliate, may assist certain clients with individual tax
related items pursuant to the terms in their agreements.
Services Available to Address Specific Client Needs
Retirement Paycheck® Service
The Retirement Paycheck service is designed to help clients generate a consistent income stream in retirement
while remaining invested in the financial markets as a long-term investor. Retirement Paycheck accounts have
two components. The income generation component generally places three years’ worth of monthly income
into lower risk investments, such as U.S. government bonds, FDIC-insured bank CDs, money market funds, or
highly rated short-term corporate bonds. After determining how much should be allocated to the income
generation component of this service, remaining funds are invested in a highly diversified portfolio to help guard
against inflation and increases in the cost of living. The period for which an income stream can be generated
depends on the amount of the income to be generated, additional unanticipated withdrawals taken from the
account, and market conditions. Clients do not pay any commissions, upfront fees or surrender penalties for
this service, and can cancel at any time. Clients do pay a fee in addition to the wrap fee, for fixed income trades
which are utilized in the Retirement Paycheck service.
Clients placed in the Retirement Paycheck service authorize the Firm to provide portfolio management services
and to direct the investment and reinvestment of the client’s assets.
Customized Portfolios
Certain Edelman Financial Engines clients can invest in customized portfolios. While the investment
management philosophy is the same as for model portfolios, customized portfolios determine appropriate
allocations at the household level for individual clients. Accounts enrolled in this feature are regularly
monitored and consider factors such as individual tax circumstances, unmanaged assets, concentrated
positions, objectives, risk tolerance, and other relevant factors.
Management of Held Away Assets
The Firm offers discretionary management services for assets in certain defined contribution plan participant
accounts, such as 401(K)s, through a third-party platform. These assets are held away from our primary qualified
custodians and are held in the custody of the plan custodian(s). Through this platform, the Firm does not
maintain custody of Client assets, as it does not have direct access to Client login credentials required to execute
trades. The Firm is not affiliated with the platform in any way and receives no compensation for using their
services. A link will be provided to Clients enabling them to connect their account(s) to the platform. Once
Client’s account(s) is connected, the Firm will review the current asset allocations. In consultation with the
Client, and considering their goals, risk tolerance, needs, and investment horizon, the Firm will reallocate the
assets in the account. This may include some or all the securities made available through the platform. Once the
appropriate allocation is determined, it is continuously and regularly monitored, and rebalanced if necessary.
Turnkey Asset Management Program (“TAMP”)
The Firm’s Turnkey Asset Management Program (“TAMP”) program makes Wrap Fee Program models available
to clients of select unaffiliated investment advisers (“TAMP Advisors”). The wrap fee is shared between
Edelman Financial Engines and the TAMP Advisors on a negotiated basis.
V. Non-Discretionary Online Advice
Online Advice is a dynamic online service that allows individuals to input and/or access information in an online
portal in order to obtain advice and information on the holdings within their accounts. This service is non-
discretionary in nature and no holdings are bought or sold for clients using Online Advice unless they themselves
initiate trading activity. Online Advice is primarily available to participants in employer-sponsored defined
contribution plans through an agreement between the Firm and the plan and/or the sponsoring employer. This
service is not available to new subscribers or for existing subscriber renewals.
Once certain information is provided by the client into the Online Advice service, or upon that information
being provided automatically where available, the Firm’s Online Advice service will generate:
• a forecast of the client’s potential future account value or the potential annual retirement income based
upon the information provided;
• a forecast of the likelihood that a client will achieve their self-reported retirement income or account value
goals, taking into consideration the total household investment portfolio as known by the service;
• phone access to investment advisor representatives via a toll-free number;
• guidance on savings rates and retirement age; and
• as outlined below, investment recommendations.
Investment recommendations
Online Advice clients can receive specific non-discretionary buy and sell recommendations for tax-deferred
and/or taxable accounts, and – where applicable – on investments held within a company’s qualified retirement
plan. To obtain such recommendations, clients specify the universe of available investment alternatives they
wish Online Advice to consider. For those accessing these services through their employer, Online Advice clients
will receive specific recommendations on how to allocate their funds among the universe of investment
alternatives (generally mutual funds and, in some cases, one or more equity securities issued by the plan
sponsor) that have been selected by their plan sponsor or other plan fiduciary for the applicable defined
contribution plan (or by another financial institution or the adopter in the case of other accounts outside the
plan account).
Online Advice can provide recommendations with respect to mutual funds, commingled funds, separate
accounts, and exchange-listed equity securities (sell only). When generating investment recommendations, the
Firm may take into consideration closed-end funds and exchange traded funds as well as other holdings, as
appropriate and where it has access to such information.
The Firm also offers educational content to clients who use Online Advice. The educational content may
include an analysis of the risk, expenses, style, turnover and historical performance of a particular mutual fund
compared to its peers and may describe how the fund might perform in the future relative to its peers. The
educational content may also present a graphical representation of historical performance of an illustrative
investment in the fund.
Advice implementation
The Online Advice client is responsible for determining whether and when to implement the recommendations
they receive from Online Advice. The Firm has established electronic communications links with certain defined
contribution plan providers (“plan providers”) and other financial institutions. With Online Advice, the Firm does
not have discretion over client accounts and does not initiate trade instructions on behalf of clients.
Account monitoring through Online Advice
Clients may use Online Advice as frequently as they choose to monitor progress toward their retirement goals,
receive forecasts and investment recommendations, and access educational content. Online Advice updates the
values of most mutual funds and stocks in plan accounts daily. A client is responsible for periodically revisiting
Online Advice to ensure that account information, holdings and personal information is accurate and up to date.
The failure of an Online Advice client to review and periodically update their personal and financial information
can materially affect the value of this service. For certain participants, some account information may be
updated automatically when the client revisits Online Advice if the Firm has established an electronic
communications link with the participant’s plan sponsor and/or plan provider or other financial institution. For
manually added and linked accounts, we rely on the client to provide ongoing and updated data either by
logging in to refresh a linked account or by manually updating the manually added accounts. The Firm may
periodically provide e-mail notifications to clients concerning changes in the value of the client’s investments or
the chances of reaching the client’s goal.
VI. Other Services Offered by the Firm
Retirement Plans Division (RPD)
The Retirement Plans Division – Small Business (“RPD”) is available to plan sponsors of 401(k), profit-sharing,
non-qualified deferred compensation and retirement plans (“Plans”), as a separate service offering from our
traditional workplace offering. These Plans can include both participant-directed and trustee-directed Plans.
Through RPD, Edelman Financial Engines creates and maintains model asset allocation portfolios for Plans. It is
intended for small and mid-sized companies, organizations, endowments, and associations, who may benefit
from value-add services such as participant education, professionally managed model portfolios and a single
point of contact for the sponsor of the plan and its employees.
Edelman Financial Engines offers plan sponsors the option of delegating discretionary authority to Edelman
Financial Engines with respect to the selection of models on behalf of the Plans in RPD. In such cases, Edelman
Financial Engines will select the underlying asset classes for the models and the underlying investment securities
for each underlying asset class. Usually, the investment securities consist of funds including, but not limited to,
mutual funds and ETFs. The plan sponsor (or other plan fiduciary or agent) approves models to be used for the
Plan’s assets, and then Edelman Financial Engines invests pursuant to those models on behalf of the Plan.
Generally, in the case of a participant-directed Plan, after the plan sponsor (or other Plan fiduciary or agent)
reviews and approves certain recommended models, the models are offered to Plan participants as investment
options. Participants select an investment option for their Plan accounts. We do not have discretion to choose
a particular option for participants as these plans are employee-directed. Therefore, we are not responsible for
reviewing or changing any participant’s decision to invest in a particular investment option. RPD may also offer,
as negotiated, assistance with Investment Policy Statements, Designated Investment Alternatives, Qualified
Default Investment Alternatives or Retirement Plan Consulting Services. Edelman Financial Engines is not
responsible for the administration of the Plan. The responsibility is designated to a third-party administrator.
Plan sponsors (or other Plan fiduciaries or agents) are permitted to impose reasonable restrictions on the
underlying assets used in the investment options recommended to the Plan. For example, a plan sponsor (or
other Plan fiduciary or agent) may request that securities or types of securities not be purchased, or that such
securities be sold. Edelman Financial Engines reserves the right, at our sole discretion, to reject any Plan account
where unreasonable or overly restrictive conditions are requested.
Plan sponsors (and other Plan fiduciaries or agents) may be introduced to RPD through other unaffiliated
registered investment advisers. The unaffiliated registered investment adviser initiates and maintains the
relationship with the plan sponsor. The unaffiliated adviser may charge a separate fee for its services and does
not share in the advisory fee generated from any Plan assets that are invested in RPD. Edelman Financial Engines
receives no compensation or economic benefit from products or services offered by the unaffiliated adviser to
Plans, other than from the services which RPD provides under a separate Investment Management Agreement,
nor does the Firm compensate any such unaffiliated parties for such introductions.
Separate from, but related to the RPD business, Edelman Financial Engines planners provide certain investment
advisory services on certain non-ERISA (e.g., a simple IRA or a SEP IRA) and certain ERISA covered plans. The
latter could be solo Defined Benefit plans or individuals within a defined benefit or defined contribution plan
where the employees are able to hire an investment advisor to manage their investments within the plan. In
addition, Edelman Financial Engines planners may establish a client relationship with one or more plan
participants or beneficiaries in various ways, including but not limited to:
• A plan participant or beneficiary seeking advice on assets they hold outside their plan (such as a non-
qualified investment account);
• As part of an individual or household financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relate to assets held outside of the plan; and/or
through a rollover of an Individual Retirement Account ("IRA Rollover").
If we are providing the stated retirement plan services to a plan, our planners may, upon the request of a plan
participant or beneficiary, arrange to provide investment advisory services on assets they hold outside their plan
directly to that participant or beneficiary through a separate investment management agreement. See Section
IV. Discretionary Advisory Services through Planners above for details.
Ready Cash™
Individuals, including clients and may include prospective clients, who are seeking a place to maintain their
cash reserves are offered to open an account at UMB Bank, N.A. (UMB), Member FDIC (“Ready Cash™”)
through the Firm’s online portal (“Customers”). The account is at UMB Bank, N.A. and is not an investment
advisory account managed by Edelman Financial Engines. The cash balance participating Customers placed
through Ready Cash™ is in turn placed by UMB at participating program banks, where it earns a variable rate
of interest and is eligible for FDIC deposit insurance. Customer funds are FDIC insured up to applicable limits
while in transit through UMB. Edelman Financial Engines receives a platform fee from UMB in exchange for
providing the Ready Cash service to its Customers. Receipt of the platform fee presents a potential conflict of
interest as the Firm receives an economic benefit related to Customers who choose to participate in the Ready
Cash™ program, as opposed to other alternatives in the market. In addition, planners may receive more
compensation related to the provision of advisory services than with Ready Cash™, creating a potential conflict
as well. The Firm does not believe that either conflict is material. Ready Cash™ availability may be limited
based on operational capacity.
Educational Products and Guidance
The Firm, or an affiliate, in a non-fiduciary capacity, may offer retirement plan and related guidance and
education, including as a workplace benefit, separate from the discretionary and non-discretionary services
described above. Such services may include wellness education through phone-based counselors with digital
tools and guidance. Generally, availability of such services is subject to the agreement between an employer
and the Firm and/or its affiliates.
The Firm, subject to plan sponsor authorization, may provide plan participants with a Retirement Evaluation.
The Retirement Evaluation is made available in printed or electronic format to specified plan participants, and is
designed to communicate some (or all) of the following information:
• a summary of the current value of the participant’s plan account;
• a forecast of how much the plan account investments, and other investments that participants submit for
analysis, might be worth at retirement;
• whether a change is suggested to the participant’s contribution rate, their portfolio’s risk and diversification,
unrestricted company stock holdings, if applicable, target date usage, if applicable, and/or investment style
and allocation;
• investment proposals; and
• a projection of how much annual income the participant may anticipate at retirement, based on how much
the plan account plus Social Security and certain other benefit accounts could provide.
Recordkeeping
Through an arrangement with a third party, the Firm provides recordkeeping services to a limited number of
retirement plans. These services are separate from the Firm’s Online Advice, Professional Management, and
Personal Advisor services described in Item 4.
VII. Amount of Discretionary and Non-Discretionary Client Assets that FEA Manages
As of December 31, 2023, FEA managed approximately $270,770,414,650 in assets on a discretionary basis. FEA
did not manage any assets on a non-discretionary basis as of December 31, 2023.