Guided Choice Asset Management, Inc. (“GCAM”), in business since 1999, is a wholly
owned subsidiary of GuidedChoice.com, Inc., collectively known as “GuidedChoice.”
GuidedChoice operates under two brand names, GuidedChoice and 3Nickels. GCAM
developed the engine that powers the services offered by these brands.
The GuidedChoice brand is focused on retirement wellness, engaged in the business
of designing and developing retirement plan advice and management software and
retirement income planning software, and marketing the related products and
services. GuidedChoice provides services via a web-based digital interface primarily
to defined contribution plans and directly to participants in defined contribution
plans (such as a 401(k) plan) and other types of employee benefit plans, and to
customers of financial services companies, as well as retail investors. Similar
services are also provided to financial institutions as a sub-advisor.
The 3Nickels brand is focused on financial wellness, providing a suite of digital tools
designed to help individuals strategically plan and invest to achieve multiple
financial goals, as well as get answers to questions about their money in the areas
of: investments, goals, college, budgeting, loans, credit cards, medical, house, gifts,
cars, debt, and retirement. 3Nickels provides services via mobile app primarily to
retail customers, participants in employee benefit plans, and customers of financial
services companies.
Under the GuidedChoice Brand
Provider Level Investment Selection Services
Given a universe of investments by an institutional provider of plan services, we will
select a subset of investments that meet defined criteria, which may include
requirements established by the plan provider. The objective is to obtain a list of
screened investments that meet the requirements of the plan sponsor for asset class
diversification, performance, expenses, risk, and portfolio construction. The
investments are monitored quarterly to ensure they continue to meet the criteria
and changes are made within any recordkeeping system constraints.
Plan Level Services
Investment Policy Statement
We provide plan sponsors an investment policy that outlines the process used for
selecting investments to be used within a qualified plan. The statement includes, but
is not limited to, the method used to determine and attain diversification amongst
the investments and the selection and ongoing monitoring processes for
investments.
Investment Selection
Based on the plan sponsor’s objectives as stated in the Investment Policy Statement,
we will select a line-up of investment options for the plan that will include a broad
range of asset classes. In addition, the plan sponsor may elect to choose additional
investments, such as company stock or a self-directed brokerage option. The
objective is to provide enough diversification to enable the plan’s participants to
invest efficiently.
Investment Monitoring
If outlined in the Investment Policy Statement or Participant Agreement, we will
monitor the investment line-up on a periodic basis to ensure that the investments
are continuing to match the stated objectives. A report will be provided to the plan
sponsor outlining the metrics of the investments, including but not limited to,
performance, risk measurements, expenses, and style analysis. The report may also
include an analysis of the investment options.
Retirement Readiness Analysis
Based upon the retirement benefits provided by the employer, including Social
Security, we can provide a projection of the plan’s participants’ retirement
readiness. We will project a range of income at retirement for each employee based
upon the assets currently in the employer’s retirement benefit plans, expected
future contributions and earnings, and Social Security. A Retirement Readiness
Report, as described below, can be provided to each employee.
Individual Level Services
Guidance & Advice
Individuals may use our advice and management service for accumulation and/or
our retirement income planning service for distribution, our digital tools, a call
center, or a paper-based solution to access personalized guidance. Individuals who
have received and accepted a disclosure agreement may obtain advice through our
digital tools, call center, or a paper-based solution. This service includes a projection
of a potential range of income at retirement based upon the current value of any
retirement assets included, expected future contributions and earnings, and Social
Security. Based upon the retirement goal established, we may recommend changes
to the savings rate, investment allocation, risk level, and retirement age. Then we
will provide a projected range of income at retirement based upon the new
parameters.
Investment Constraints. Certain specific investments may be excluded from
our recommendations either by the individual, or in certain cases, by the plan
or plan provider. We will take the excluded investments into account when
calculating projections, as well as when making an investment allocation
recommendation.
Company Stock. A plan sponsor may include company stock as an
investment option in a defined contribution plan. If a participant owns
company stock in the account, the participant, or in certain cases the plan or
plan provider, may elect to exclude it from the asset allocation; although, we
will take into account the company stock when making an allocation
recommendation. If it is not excluded, we will include it in the asset
allocation recommendation, which may result in the inclusion or exclusion of
company stock in the allocation. The recommendation will comply with any
plan restrictions on selling company stock.
Brokerage Account. A plan sponsor may include a brokerage account as an
option in the plan. GCAM has established electronic communication links
with certain financial institutions to enable data exchange with regard to the
underlying investments held in the brokerage account. In addition, the
participant can enter those investments into our software. We will take the
investments into consideration when making the investment allocation
recommendation.
Investment Recommendations. We provide advice on the specific
investment options available to an individual. Within a qualified plan, those
investments generally include open-ended mutual funds, money market
funds, stable value funds, exchange listed securities, separate and
commingled trusts, real estate investment trusts, guaranteed investment
contracts, and variable and fixed annuities. In addition, we may take into
account additional investments held outside a qualified plan for purposes of
projections and possibly buy/sell recommendations. These include, but are
not limited to, passbook savings accounts, certificates of deposit, closed-end
mutual funds, privately held securities, corporate, government, and
municipal bonds, real estate, and commodities.
Implementing Advice. The individual using our advice services elects
whether or not to implement the advice. GCAM has established electronic
communication links with certain plan providers and financial institutions to
facilitate data exchange and transactions. An individual may be able to
implement and transmit the investment directions and savings rate changes
to those institutions.
Ongoing Analysis. Where GCAM has established electronic communication
links with plan providers and financial institutions, when the individual
revisits our digital services, some account and investment data may be
updated automatically. The individual should review and ensure that all data
is updated. Failure to do so may materially affect the relevance of the advice
provided.
Personalized Spending Report. For those individuals using the retirement
income planning service (usually at or in retirement), a personalized report
is generated that indicates from which accounts to liquidate to provide for
the required retirement income need. The recommendation takes into
account tax efficiencies when determining from which accounts to liquidate.
Managed Account
In a managed account, GCAM is responsible for managing an individual’s
investments within the account. The investments used by GCAM in the managed
account are those that are made available to the individual, typically through a
retirement plan. An individual can elect to discontinue participating in a managed
account at any time.
Investment Constraints. Certain specific investments may be excluded from
our recommendations either by the individual or in certain cases, by the plan
or plan provider. We will take the excluded investments into account when
calculating projections, as well as when making an investment allocation
recommendation.
Company Stock. A plan sponsor may include company stock as an
investment option in a defined contribution plan. If a participant owns
company stock in the account, the
participant may elect to exclude it from the
asset allocation, although we will take into account the company stock when
making an allocation recommendation. If the participant does not exclude it,
we will include it in the asset allocation recommendation, which may result
in the inclusion or exclusion of company stock in the allocation. The
recommendation will comply with any plan restrictions on selling company
stock.
Brokerage Account. A plan sponsor may include a brokerage account as an
option in the plan. GCAM has established electronic communication links
with certain financial institutions to enable data exchange with regard to the
underlying investments held in the brokerage account. In addition, the
participant can enter those investments into our software. We will take the
investments into account when making the investment allocation
recommendation.
Investment Recommendations. We provide advice on the specific
investment options available to an individual. Within a qualified plan, those
investments generally include open-ended mutual funds, exchange traded
funds, money market funds, money market deposit accounts, stable value
funds, exchange listed securities, separate and commingled trusts, real estate
investment trusts, guaranteed investment contracts, and variable and fixed
annuities. In addition, we may take into account additional investments held
outside a qualified plan for purposes of projections and possibly buy/sell
recommendations. These include, but are not limited to, passbook savings
accounts, certificates of deposit, closed-end mutual funds, privately held
securities, corporate, government and municipal bonds, real estate, and
commodities.
Ongoing Analysis. Where GCAM has established electronic communication
links with plan providers and financial institutions, when the individual
revisits our digital services, some account and investment data may be
updated automatically. The individual should review and ensure that all
data is updated. Failure to do so may materially affect the relevance of
the advice provided and may adversely impact the managed account.
Personalized Spending Report. For those individuals using the retirement
income planning service (usually at or in retirement), a personalized report
is generated that indicates from which accounts to liquidate to provide for
the required retirement income need. The recommendation takes into
account tax efficiencies when determining from which accounts to liquidate.
Periodic Account Review. Ongoing, GCAM will review the individual’s
account and make investment allocation changes automatically to ensure the
appropriate risk level based upon the individual’s investment objectives.
Usually, rebalancing takes place quarterly but no less often than annually.
The individual agrees and authorizes GCAM to execute transactions without
prior approval to meet the selected objectives.
Annual Report. Each individual in a managed account receives an annual
projection of their potential range of income at retirement, based upon the
current value of any retirement assets included in the digital interface,
expected future contributions and earnings, as well as Social Security.
Opt-In. Individuals enroll in a managed account by actively selecting to
participate. This may be through the advice and management or retirement
income planning services, our digital services, a call center, or a paper-based
solution.
Opt-Out. Eligible participants are enrolled in a managed account in
accordance with rules established by the plan or plan sponsor. Individuals
enrolled can elect to discontinue the managed account at any time.
The individual gives GCAM discretionary authority to determine an investment
allocation for the individual and manage the allocation until the individual elects to
discontinue the managed account. Individuals, who have received and accepted a
disclosure agreement, may use the advice and management and/or retirement
income planning services, our digital services, a call center, or a paper-based
solution to access the personalized advisory and managed account services.
This service includes a projection of a potential range of income at retirement based
upon the current value of any retirement assets included, expected future
contributions and earnings, and Social Security. Based upon the retirement goal
established, we may recommend changes to the savings rate, investment allocation,
risk level, and retirement age. Then we will provide a projected range of income at
retirement based upon the new parameters. The individual may modify any of the
recommendation to meet personal preferences. We will then provide a projected
range of income at retirement based upon the modified parameters. GCAM will then
manage the account based upon the selected risk level target.
Retirement Readiness Report
Based upon the retirement benefits provided by the employer, including Social
Security, we can provide a projection of the plan’s participants’ retirement
readiness. We will project a range of income at retirement for each employee based
upon the assets currently in the employer’s retirement benefit plans, expected
future contributions and earnings, and Social Security, as well as other known assets
in certain circumstances.
Sub-advisory Services
GCAM has arrangements with financial institutions to provide services as a sub-
advisor. GuidedChoice.com, Inc. or GCAM may license technology and provide other
services to financial institutions to enable them to provide their own advisory and
managed account services. In addition, GCAM may provide the investment allocation
to be used for individuals’ managed accounts within another advisory platform.
Client Assets Managed
As of December 31, 2023, for individuals in retirement plans, GCAM directly
managed $6,645,705,545 in discretionary assets.
Under the 3Nickels Brand
Subscription-based Advice Version
Individuals who download our mobile app or use the web interface and agree that
they have received and accept a disclosure agreement get access to personalized
guidance and advice. 3Nickels includes the establishment of three standard financial
goals: retirement income, debt pay-off, and emergency fund. Individuals can include
additional financial goals, determine the priority of all goals, and receive advice on
how they may achieve them. Advice includes a projection of a potential range of
income at retirement based upon the current value of any retirement assets
included, expected future contributions and earnings, and Social Security. Based
upon the goals entered, we may recommend changes to the retirement plan savings
rate, investment allocation, risk level, and retirement age, as well as adjustments to
budgetary spending. A projected range of income at retirement based upon the new
parameters will also be provided and all goals will include an indication of whether
or not the individual is on-track to meet them.
Investment Constraints. Certain specific investments may be excluded from
our recommendations by the individual. We will take the excluded
investments into account when calculating projections, as well as when
making an investment allocation recommendation.
Company Stock. If a participant owns company stock in a defined
contribution plan account, the participant may elect to exclude it from the
asset allocation; although, we will take into account the company stock when
making an allocation recommendation. If it is not excluded, we will include it
in the asset allocation recommendation, which may result in the inclusion or
exclusion of company stock in the allocation.
Investment Recommendations. We provide advice on the specific
investment options available to an individual, provided the user enters them
into the interface. Within qualified plans, those investments generally include
open-ended mutual funds, money market funds, stable value funds, exchange
listed securities, separate and commingled trusts, real estate investment
trusts, guaranteed investment contracts, and variable and fixed annuities. In
addition, we may take into account additional investments held outside a
qualified plan for purposes of projections and possibly buy/sell
recommendations. These include, but are not limited to, passbook savings
accounts, certificates of deposit, closed-end mutual funds, privately held
securities, corporate, government and municipal bonds, real estate, and
commodities.
Implementing Advice. The individual using advice services elects whether
or not to self-implement the advice.
Ongoing Analysis. When the individual revisits our digital services, some
account and investment data may be updated automatically through the use
of account aggregation services. The individual should review and ensure
that all data is updated. Failure to do so may materially affect the
relevance of the advice provided.