DESCRIPTION OF THE COMPANY
This Disclosure Brochure describes the advisory services offered
by AssetMark, Inc. (“AssetMark”) through its Retirement Services
division to defined contribution retirement plans qualified under
Internal Revenue Code (“IRC”) Section 401(k) and to IRC Section
403(b) Client Plans (“Client” or “Client Plans”).
AssetMark is an investment adviser registered with the U.S.
Securities and Exchange Commission providing various investment
advisory services pursuant to Investment Management Services
Agreements (“IMSAs”) or Client Services Agreements (“CSAs”)
(“Client Agreements”) since 1999.
AssetMark is a wholly-owned subsidiary of AssetMark Financial
Holdings, Inc. AssetMark Financial Holdings, Inc. is an indirect
subsidiary of Huatai Securities, Co., Ltd. (“HTSC”). HTSC is a financial
services and securities brokerage firm, incorporated in China and
listed on the Shanghai and Hong Kong stock exchanges with global
depository receipts (“GDRs”) listed on the London stock exchanges.
Entities incorporated in China may be subject to China’s laws and
regulations that differ from those in the United States. AssetMark
Financial Holdings, Inc., is publicly listed on the New York Stock
Exchange (ticker: AMK).
AssetMark is the sponsor of the AssetMark Platform (the “Platform”)
through which it offers its advisory services to its clients. AssetMark
Wealth Solutions includes AssetMark Asset Management (AAM),
Due Diligence, Investment Consulting and other portfolio, wealth,
and practice solutions. AAM manages AssetMark’s proprietary
investment strategies. AAM replaces AssetMark Portfolio Solutions
(APS) (formerly referred to as AssetMark Investment Management).
AssetMark also serves as the investment adviser for the following
registered investment companies (“Proprietary Funds”):
1) GuideMark Funds (no-load sub-advised mutual funds)
2) GuidePath Funds (no-load funds of funds and a sub-advised managed
futures mutual fund)
AssetMark is responsible for the selection and management of
subadvisors for each of the GuideMark Funds. AssetMark is not
registered with the Commodity Futures Trading Commission (“CFTC”)
as a commodity trading advisor, based on its determination that it
may rely on certain exemptions from registration provided by the
Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC
has not passed upon the availability of these exemptions to AssetMark.
AssetMark currently acts as a registered “commodity pool operator”
(“CPO”) with respect to the GuidePath Managed Futures Strategy
Fund and its wholly owned controlled foreign corporation, the
GuidePath Managed Futures Strategy Cayman Fund. AssetMark is
registered as a CPO under the CEA and the rules of the CFTC.
DESCRIPTION OF THE RETIREMENT ADVISORY SERVICES
I. IRC 401(k) and IRS 413(e) Retirement Advisory Services
Through its Retirement Services division and pursuant to Client
Agreements with Client, AssetMark provides advisory services to
defined contribution retirement plans intended to be qualified under
Internal Revenue Code of 1986 (“IRC”) Section 401(a) that maintain
individual accounts (“Accounts”) for their Participants (generally
IRC 401(k) plans). AssetMark also provides advisory services to
Clients that are employers that have been admitted to a pooled
employer plan (the “PEP”) that has been established under IRC
Section 413(e)and Section 3(43) of Employee Retirement Income
Security Act of 1974, as amended, (“ERISA”) and is administered
by a registered pooled plan provider (the “Pooled Plan Provider”)
within the meaning of Section 3(44) of ERISA and Section 413(e)
(3) of the IRC. The Pooled Plan Provider is independent of and not
affiliated with AssetMark.
Pursuant to the Client Agreements, AssetMark acknowledges
that it is providing investment advice to the Client Plan and is a
“fiduciary” (within the meaning of section 3(21) of the Employee
Retirement Income Security Act of 1974), and accepts appointment
as an “investment manager” (within the meaning of Section 3(38)
of ERISA) with discretion, in all instances, to the extent that a
Client Plan is subject to ERISA and to the extent it provides:
i. investment advisory services to Client Plan assets pursuant to
the Client Agreements, and
ii. in the case of Clients admitted to the PEP, to the extent it provides
investment advisory services to the Client with respect to the
assets in the PEP, that are attributable to employees of the Client.
AssetMark develops and maintains Investment Alternatives for
use by the Client Plans’ Participants and beneficiaries. These
Investment Alternatives include individual mutual funds and/or
exchange traded funds (“ETFs”) (collectively, “Individual Funds”)
and Managed Accounts Solutions (as described below). AssetMark
provides the investment advisory services in accordance with any
reasonable investment restrictions specified by the Client Plan and
accepted by AssetMark.
AssetMark provides the Managed Accounts Solutions through
the maintenance of “Asset Allocation Models,” which specify the
percentage of specific securities to be held by each Account.
AssetMark has contracted with investment management firms
(“Portfolio Strategists”) to provide Asset Allocation Models
comprised of recommended portfolio allocations. Portfolio
Strategists do not provide discretionary investment management
services to Accounts. A Client may specify the initial Investment
Alternatives to be provided by the Plan to Plan Participants.
AssetMark has the authority to replace Investment Alternatives at
its discretion. AssetMark has the authority to select, remove and
replace securities, including mutual fund and ETF shares, and other
investments, as Investment Alternatives, in Client Plan Accounts,
and with regard to the Managed Accounts, to determine the portion
of assets in the Managed Account that shall be allocated to each
fund share, security, investment or asset class and to change such
allocations. AssetMark has the authority to remove an Individual
Fund or Managed Account Solution as an Investment Alternative,
including but not limited to a Qualified Default Investment
Alternative (“QDIA”) and, at its discretion, direct, or not, that
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Client Plan assets invested in the removed Investment Alternative
be moved to another (existing or new) replacement Investment
Alternative. AssetMark can also act as a Portfolio Strategist for
AssetMark‘s proprietary Investment Alternatives offered to the
Client Plans. Information about specific Investment Alternatives
offered to the Client Plans is included in the AssetMark Retirement
Services Quarterly Performance Review that can be obtained from
the client’s financial advisor.
AssetMark does not provide Plan Participants and beneficiaries
individualized investment advice. AssetMark does not know
the individual investment objectives of Plan Participants and
beneficiaries and AssetMark has no responsibility for determining
whether any Investment Alternative is suitable for any particular
Plan Participant or Client Plan. AssetMark is responsible for
determining whether the Investment Alternatives are generally
suitable to be investments for Client Plans.
II. IRC 403(b) Advisory Services
Pursuant to Client Agreements, AssetMark provides advisory
services to plans intended to be qualified under IRC Section 403(b)
that maintain individual accounts (“Accounts”) for their Participants.
Pursuant to the Client Agreements, AssetMark acknowledges that
it is providing investment advice to the Client Account and is a
“fiduciary” (within the meaning of section 3(21) of ERISA) and
accepts appointment as an “investment manager” (within the
meaning of Section 3(38) of ERISA) with discretion for ERISA,
in all instances, to the extent a Plan is subject to ERISA and to
the extent it provides investment advisory services to Client Plan
assets pursuant to the Client Agreements.
Fidelity 403(b) Portfolios
AssetMark provides asset allocation services to participants
of 403(b) plans where Fidelity Institutional Wealth Services
(“Fidelity”) is an authorized provider under the Participant’s plan.
AssetMark provides asset allocation services to participants
based upon investment choices made available through the
Participants’ plans or through Brokerage Link, if available. Mutual
fund options for the Fidelity 403(b) portfolios generally do not
include all mutual funds offered by Fidelity, and in most cases, are
limited to only certain Fidelity family mutual funds. As a result,
risk characteristics and returns of Fidelity 403(b) portfolios could
vary significantly from non-Fidelity 403(b) portfolios. AssetMark
provides investment advisory services in accordance with any
reasonable investment restrictions specified by the Clients’ Plans
and accepted by AssetMark. Minimum account size is $50,000
and is subject to negotiation.
TIAA CREF – 403(b) Portfolios (closed to new accounts)
AssetMark provides asset allocation services to participants of
403(b) plans where TIAA CREF is an authorized provider under the
participant’s plan. AssetMark provides asset allocation services to
participants based upon investment choices made available through
the Client Plan. Mutual fund options for the TIAA CREF portfolios
typically include all (or almost all) mutual funds offered by TIAA CREF.
Minimum account size is $50,000 and subject to negotiation.
Screened Portfolios (Values Based Portfolios)
AssetMark offers portfolios screened for various values-based
considerations (“Screened Portfolios”) Screened Portfolio
allocations are typically constructed from mutual funds, but
also include Managed Accounts Solutions, individual securities,
closed-end funds and exchange traded funds. Mutual funds
utilized in Screened Portfolios are selected from a more limited
menu of mutual funds than non-screened allocations offered
by AssetMark. As a result, risk characteristics and returns of
Screened Portfolios could vary significantly from non-screened
portfolios. Minimum account sizes for applicable services apply
and are subject to negotiation.
AssetMark’s Retirement Services division does not participate in a
Wrap Fee program.
SERVICES NO LONGER OFFERED
AssetMark continues to provide other advisory services which are no
longer offered to new Clients. Clients with these services may contact
AssetMark for more information.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, AssetMark had $1.4 billion in assets under
management under the Retirement Services division programs.