We specialize in the following types of services: retirement plan consulting, retirement plan asset management,
asset management, and financial planning/consultations.
We are dedicated to providing individuals and other types of clients with a wide array of investment advisory
services. SageView is a limited liability company formed in the State of California. The firm is registered with the
SEC as a large advisory firm under Rule 203A‐2(b) of the Investment Advisers Act of 1940.
Description of the Types of Advisory Services We Offer
(i) Retirement Plan Consulting
We provide retirement plan consulting services to employer plan sponsors on a one-time or ongoing basis.
Generally, such retirement plan consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan
sponsor dictate, areas of advising could include: investment options, plan structure and participant education.
All retirement plan consulting services shall be in compliance with the applicable state law(s) regulating
retirement plan consulting services. This applies to client accounts that are retirement plans or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to
such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but
only with respect to the provision of services described in section 1 of the Retirement Plan Consulting
Agreement).
In providing these services, SageView generally does not provide any services with respect to the following
types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS),
participant loans, non-publicly traded securities or assets; (other than Collective Investment Funds or non-
publicly traded securities or assets recommend by SageView), or brokerage window programs (collectively,
“Excluded Assets”) Non-Excluded Assets are “Included Assets”.
(ii) Retirement Plan Asset Management
We provide retirement plan asset management services on an ongoing basis. Generally, such asset
management services consist of selecting, monitoring, removing, and/or replacing the investment options
under the Plan, consistent with the objectives, written guidelines and/or investment objectives set forth in
the written investment policy statement (“IPS”) accepted and adopted by the client. As the needs of the plan
sponsor dictate, areas of management could include: plan investment options, asset allocation, plan
structure, and participant education.
We emphasize continuous and regular account supervision. Once the appropriate Plan investments have
been determined, we review the Plan investments at least annually and if necessary, replace investments based
upon the Plan sponsor’s objectives, written guidelines and/or investment objectives.
All retirement plan asset management services are in compliance with applicable state and federal law(s)
and regulation regarding retirement plan consulting services, including but not limited to the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). If we are hired to perform retirement plan
asset management services, we acknowledge that we are a fiduciary within the meaning of section 3(38) of
ERISA (but only with respect to the provision of services described in the applicable retirement plan consulting
agreement between us and the Plan).
(iii) SageView Plan Participant Services
SageView Personalized Portfolios
We offer SageView Personalized Portfolios, a web-based, managed account program that is made available
to certain Plans who wish to offer these services to their participants. This program is not available to all Plans
and depends upon the capabilities of the Plan’s recordkeeper. If a Plan elects this service, participants will work
with an investment manager, who will select their investments from among the Plan’s available investment
options, and thereafter manage the participant’s investment selection.
Participants receive a personalized investment portfolio that reflects the SageView Personalized Portfolios
investment options and the participant’s age, retirement timeframe, investment objectives, potential
significant life events, risk tolerance and overall financial situation, including assets held outside the Plan,
which may be taken into consideration when determining the allocation of assets in the participant’s account.
SageView Personalized Portfolios does not provide advice for, recommend allocations of, or manage any
assets of a participant that are not within the Plan, unless such participant elects to use the wealth
management services of SageView, subject to an asset management agreement between the participant and
SageView. SageView Personalized Portfolios will not include management services for individual stocks, self-
directed brokerage accounts, guaranteed certificate funds, employer-directed monies, or in-plan annuities.
Participants must allocate their entire account balance to SageView Personalized Portfolios assets.
Participants are under no obligation to use these services and may cancel their participation in SageView
Personalized Portfolios at any time.
There are three variations of fiduciary responsibility, technology, and service as it relates to the managed
account program depending on the recordkeeper.
(1) For Plan Sponsors working with Empower, SageView is the 3(38) Fiduciary for portfolio creation and
assignment. Empower Advisory Group acts as a sub-adviser to SageView for portfolio assignment using
the investment methodology of a third-party, “Morningstar Investment Management (“Morningstar”),
which functions as an Independent Financial Expert (“IFE”).
Participants whose Plans are with Empower as recordkeeper will enroll into the managed account program
and interact with SageView Personalized Portfolios through the Empower recordkeeping platform participant
website. Account update statements are provided to enrolled participants by Empower.
SageView has discretionary authority over allocating the participant’s account, without prior participant
approval of each transaction. SageView sub-advises the allocation of the participant’s account to Empower
Advisory Group, LLC. Enrolled assets in the program will be monitored, rebalanced, and reallocated periodically
by SageView via Empower Advisory Group, LLC acting as a sub-adviser to SageView.
(2) For Plan Sponsors working with Transamerica, SageView is a co-fiduciary to the managed account
program with Transamerica. SageView acts as a 3(38) fiduciary for portfolio creation and Transamerica
acts as a 3(38) fiduciary for portfolio assignment. Transamerica uses the investment methodology of a
third-party who functions as an IFE.
Participants enrolling into the managed account program and/or interacting with SageView Personalized
Portfolios online do so on the Transamerica recordkeeping platform participant website. Account update
statements are provided to enrolled participants by Transamerica.
Transamerica has discretionary authority over allocating the participant’s account, without prior participant
approval of each transaction. Enrolled assets in the program will be monitored, rebalanced, and reallocated
periodically by Transamerica.
(3) For Plan Sponsors working with Charles Schwab, Corebridge, John Hancock, Lincoln, Financial
Group, Milliman, OneAmerica, Principal, T. Rowe Price, or Voya, SageView acts as co-fiduciary to the
managed account program with Morningstar. SageView acts as a 3(38) fiduciary for portfolio creation
and Morningstar acts as a 3(38) fiduciary for portfolio assignment.
Participants enrolling into the managed account program and/or interacting with SageView Personalized
Portfolios online do so on the Morningstar participant website. Account update statements are provided to
enrolled participants by Morningstar.
Morningstar has discretionary authority over allocating the participant’s account, without prior participant
approval of each transaction. Enrolled assets in the program will be monitored, rebalanced, and reallocated
periodically by Morningstar.
PersonalSAGE (Strategic Advice Guidance and Empowerment)
SageView also offers PersonalSAGE, a comprehensive financial readiness solution for Plan participants whose
Plan Sponsor has elected this service. PersonalSAGE provides participants with transition solutions (to help
participants understand the options they have with their retirement plan when they are entering or leaving
employment with a Plan Sponsor), financial coaching, financial wellness workshops, group-based education
sessions, a participant website with educational resources and access to speak with financial coaches.
Integrity IRA
SageView offers Integrity IRA, a solution that Plan Sponsors may elect to use for automatic IRA rollovers in
situations where the plan or the employee has terminated, and the employee’s assets are rolled out of the
retirement plan into an IRA. In providing the Integrity IRA solution, SageView works with a third-party
administrator, recordkeeper and custodian. Integrity IRA is designed to comply with applicable safe harbor
rules. SageView selects and monitors default investment options in the automatic IRA rollover, along with
other investment options that the accountholder
may self-direct and receives a fee from the IRA accountholder
for these services. SageView also receives a fee from the default fund that is selected. IRA accountholders
may elect to move their assets out of the default investment option into one or more mutual funds or other
available investments, at any time. Integrity IRA is made available only to Plans and not to individual plan
participants.
(iv) Wealth Management:
We also offer individual wealth management and related services for individuals on a discretionary and on a non-
discretionary basis, subject to an investment advisory agreement between the individual and SageView. In
providing wealth management services, we emphasize continuous and regular account supervision. As part
of our wealth management service, we generally create an investment portfolio consisting of individual
stocks or bonds, exchange traded funds (“ETFs”), mutual funds, and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific financial situation, including
their age, risk tolerance, investment objective, accepted investment guidelines and other such factors that render
the investment portfolio suitable for the investor. Once the appropriate portfolio has been determined, we
monitor and rebalance the portfolio. Each client has the opportunity to place reasonable restrictions on
the types of investments to be held in the portfolio, which must be accepted in writing by SageView.
We utilize the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in the
implementation of an investment portfolio designed by us. Before selecting a third-party advisory firm or
individual, we ensure that the chosen party is properly licensed or registered.
Our firm has entered into a service agreement with Pontera (formerly FeeX Inc.) to provide wealth management
services for accounts held away from one of the primary custodians with which we work. Through this, we are
able to create a portfolio, consisting of the securities/investment opportunities available depending on the
type of held away account being managed by us. The Pontera platform allows us to avoid having custody of
Client assets since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with Pontera in any way and receive no compensation from Pontera for use of this platform. Clients
on the Pontera platform connect their account(s) electronically directly with Pontera. The client’s individual
investment strategy is tailored to their specific needs and may include some or all of the securities made
available. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the
client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and
regularly monitored, and if necessary, rebalanced.
(v) Financial Planning and Consultations:
We provide a variety of financial planning and consultation services to individuals, families, and other clients
regarding the management of their financial resources based upon an analysis of client’s current situation,
goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or
rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning
or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning,
Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost
Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis,
Lines of Credit Evaluation, Business and Personal Financial Planning. In providing financial planning services,
we do not invest the assets of the financial planning client. We also do not provide tax advice, tax preparation,
legal or accounting services.
Our written financial plans and financial consultations include general recommendations for a course of
activity or specific actions to be taken by the clients. For example, we may recommend that clients begin
or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage,
commence or alter retirement savings, establish education or charitable giving programs, begin a college
savings plan, cash flow analysis or financial budget. Upon request, we provide clients with recommendations
to third-party accountants, attorneys, tax preparation providers or other specialists, with which we have no
affiliation and receive no compensation. For written financial planning engagements, we provide our clients
with a written summary of their financial situation, observations, and recommendations. Financial consulting
engagements are delivered orally and do not have a written financial plan associated with the service.
Our firm also offers Employer Sponsored Financial Planning and Consultation services. As part of this
arrangement, Employers provide a list of employees to whom our firm will provide Financial Planning and
Consultations services.
Financial Planning
Financial Planning may include advice that addresses one or more areas of a client's financial situation, such
as estate planning, risk management, budgeting and cash flow controls, retirement planning, education
funding, and investment portfolio design and ongoing management. Depending on a client’s particular
situation, financial planning may include some or all of the following:
Gathering factual information concerning the client's personal and financial situation;
Assisting the client in establishing financial goals and objectives;
Analyzing the client's present situation and anticipated future activities in light of the client's financial
goals and objectives;
Identifying problems foreseen in the accomplishment of these financial goals and objectives and
offering alternative solutions to the problems;
Making recommendations to help achieve retirement plan goals and objectives;
Designing an investment portfolio to help meet the goals and objectives of the client;
Providing estate planning;
Assessing risk and reviewing basic health, life and disability insurance needs; or
Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is provided, the client may choose to direct that the advisor implement the
financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no
obligation to act upon any of the recommendations made by SageView under a financial planning engagement
and/or engage the services of any recommended professional.
General Consulting
In addition to the foregoing services, we may provide general consulting services to clients. These services are
provided on a project basis, and may include, without limitation, minimal cash flow planning for certain events
such as education expenses or retirement, estate planning analysis, income tax planning analysis and review
of a client’s insurance portfolio, as well as other matters specific to the client as and when requested by the
client and agreed to by SageView. Consulting services may also be provided for business clients in a wide
range of areas, including but not limited to, executive compensation consulting, business succession planning
and related financial and business issues. The scope and fees for consulting services will be negotiated with
each client at the time of engagement for the applicable project.
Conflict Disclosure for Rollover Recommendation
A conflict of interest arises when we make recommendations about retirement plan distributions and rollovers
to IRAs, IRA to IRA transfers, IRA to plan rollovers, plan to plan rollovers and change of account types for a
retirement plan or IRA (each, a “rollover recommendation”) if it results in us receiving compensation that we
would not have received absent the recommendation, for example, fees for advising or managing a rollover
IRA. We will manage this conflict through a process designed to develop an informed recommendation in the
best interest of the client. No client is under an obligation to roll over retirement plan or IRA assets to an
account advised or managed by us. When we make a rollover recommendation, it is fiduciary advice under the
Investment Advisers Act of 1940 (the “Advisers Act”). Also, when we provide investment advice to a plan
participant about his/her retirement plan account or to an IRA owner about his/her IRA, including a rollover
recommendation, we are a fiduciary within the meaning of Title I of the Employee Retirement Income Security
Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing
retirement accounts. In addition to being a conflict of interest, it is also a prohibited transaction under ERISA
and/or the Code when we receive compensation as a result of the rollover that we would not have received
absent the recommendation. In that circumstance, we will comply with the conditions of exceptions to the
prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as PTE 2020-02 or
non-enforcement policy).
Participation in Wrap Fee Programs
We do not offer a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, we manage $21,527,102,771 on a discretionary basis and $181,049,388,859 on
a non-discretionary basis, totaling $202,573,491,630 in aggregate Assets Under Management.