Firm Description and Principal Ownership
RPA is an SEC registered investment adviser providing pension consulting and investment
management services to defined benefit and defined contribution plans. RPA works closely
with the plan sponsors and other plan fiduciaries, regarding plan design, investment options,
selection of the plan administrator and record keeper, enrollment and educational services
for plan participants, and other services based upon our analysis of the particular needs of
the plan. Thereafter, RPA shall periodically conduct a review of the plan, the investment
options offered by the plan to its participants, the model portfolios constructed for the plan,
and any other items the plan sponsors have agreed to in the RPA services agreement. RPA is
an SEC-registered investment advisor wholly owned by Cerity Partners LLC (“Cerity
Partners”). Cerity Partners is owned by Cerity Partners Equity Holding LLC. Cerity Partners
Equity Holding LLC is owned by Cerity Partners EOE LLC which is owned by certain
employees of Cerity Partners, funds affiliated with Genstar Capital Partners LLC (“Genstar”)
and Lightyear Capital LLC (“Lightyear”). Genstar, Lightyear and their affiliates do not have
any role in the Firm’s investment process related to the management of client assets.
Standard Services
RPA offers the following services:
Employee Retirement Securities Act of 1974 (“ERISA”) Non-Fiduciary Services:
Plan Design Consulting: RPA will perform a review of the Plan’s existing arrangements and
will provide recommendations that are designed to assist in identifying any limitations of
existing and/or proposed Plan arrangements as well as recommendations to assist the client
in its decision to make additional services available through the Plan.
Investment Policy Statement: RPA will assist the client in developing a formal, written
Investment Policy Statement (“IPS”) or it may review and recommend amendments to the
client relating to the existing IPS. The IPS may contain the standards and processes for
selecting and monitoring Plan investments and will set forth the number of general
investment options and asset class categories to be offered to Plan participants with a goal of
providing a menu of investments that will allow for the creation of well-diversified portfolios
through a mix of asset class exposures. The IPS is subject to the final approval of client, and
RPA does not guarantee that the client will achieve the investment objectives in the IPS. In
providing IPS services, RPA will not render any investment advice and will not be acting as an
ERISA fiduciary.
Financial Wellness Coaching: RPA will conduct periodic group enrollment and education
meetings with Plan participants through its team of salaried (non-commission) retirement
consultants. The purpose of the meetings is to increase retirement plan participation among
employees and to assist Plan participants in making informed decisions about contribution
amounts, investment allocations and distributions. Only standardized investment education
materials, which are consistent with “investment education” as that term is defined in
Department of Labor Interpretative Bulletin 96-1, will be used in connection with providing
Financial Wellness Coaching. Such information may include information about the benefits
of Plan participation, investment objectives of Plan investment options, general financial and
investment information, asset allocation portfolios of hypothetical individuals with different
time horizons and risk profiles and interactive investment materials such as questionnaires
to assess the impact of different allocations on retirement income. RPA may also provide
interactive investment materials to assist participants in assessing their future retirement
income needs. In providing Financial Wellness Coaching services, RPA will not provide advice
concerning the appropriateness of any individual investment option for a particular
participant or beneficiary under the plan and will not be acting as an ERISA fiduciary in
rendering, unless the client elects “Participant Advice” Services as described below.
Administrative Support: RPA will make its representatives available to the Client to
educate the Client and its employees about the Plan’s features, including any web-based
support offered by RPA or other service providers.
ERISA Fiduciary Services:
In addition to the fiduciary standard that applies to RPA services and those of its affiliates as
investment advisers, there are circumstances under which RPA is subject to a fiduciary duty
under the Internal Revenue Code (“IRC”), the ERISA.
Investment Recommendations & Performance Monitoring: Unless the client elects RPA’s
Fiduciary Protection Program as described below, RPA will perform the following
nondiscretionary service as an ERISA fiduciary, as defined in Section 3(21) of ERISA. RPA will
review the investment
options available through the Plan and will provide recommendations
to the client to assist in selecting the “core” investments to be offered to Plan participants,
including the Plan’s QDIAs, if applicable, that meet the criteria set forth in the Plan’s IPS. RPA
will provide reports on a regular basis that are designed to assist the client in monitoring the
core investment options and may provide recommendations to assist the client in removing
and replacing investments that no longer meet the IPS criteria.
Participant Advice: RPA will meet with Plan participants that seek to engage RPA for
Participant Advice services to gather information concerning their retirement investments,
time horizon, risk tolerance and investment goals. RPA will review the information and
provide individualized investment advice that may include a recommendation to invest in a
particular model portfolio or percentages to be allocated among a number of the Plan’s core
investment options. RPA will not provide recommendations on investments held outside of
the plan, and the Plan participant retains the sole responsibility to implement the
recommendations. RPA does not guarantee that it will achieve the Plan participants’
investment objectives.
Additional Services - Fiduciary Services
ERISA Fiduciary Services:
Investment Management Services: RPA shall have discretionary investment authority to
direct the core investments offered to Plan participants in a manner that is consistent with
the criteria set forth in the Plan’s IPS. Such authority will include that necessary to select,
monitor, remove, and replace all investment alternatives that constitute the core investment
menu. In the event that RPA provides instructions directly to the plan’s record keeper or
third-party administrator with regard to the removal, or replacement of investments. In
rendering Investment Management Services, RPA will act as an ERISA fiduciary and will
serve as an investment manager as defined in Section 3(38) of ERISA. RPA shall retain final
decision-making authority with regard to all discretionary fiduciary services, and the Plan
fiduciaries remain responsible for demonstrating that RPA was prudently selected and
monitored.
ERISA Non-Fiduciary Services:
Review of Fiduciary Liability Insurance Coverage: RPA will work with qualified insurance
professionals to review client’s fiduciary liability coverage. RPA may assist the Client in
obtaining additional or replacement insurance if necessary.
Formal Plan Committee and Charter: RPA will assist in establishing a formal Retirement
Plan Committee, if one does not already exist and, draft a Committee Charter which will serve
as a guide to the committee regarding fiduciary decisions related to the management and
administration of the retirement plan. RPA will schedule, draft agendas, and manage the
Committee meetings.
Fiduciary File Maintenance: RPA will create a Fiduciary File containing plan documents,
committee meeting materials, compliance filings, etc., and provide a paper trail of the
committee decision-making process. We will work closely with your service providers to
request and upload pertinent documents & disclosures as they become available. In addition,
we will provide an annual fiduciary assessment report for the Committees review.
Fiduciary Training: RPA provides both onsite and online fiduciary training for your
committee. RPA provides education pertaining to topics such as: fiduciary responsibility,
prohibited transactions, selecting and monitoring service providers and overall plan
governance.
Strategic Planning: RPA will work with Committee to establish an 18-month strategic
planning calendar to ensure all aspects of your retirement plan are addressed. We manage
these workflows through a custom client management system designed for institutional
clients.
Monitoring of Qualified Fiduciary: The Client is responsible as a Plan fiduciary for selection
of RPA as a Plan fiduciary, and for monitoring the performance of RPA. To facilitate this
responsibility, RPA will provide Client with a structure for the annual review and monitoring
of the RPA as a Plan fiduciary. RPA provides the Client with its proprietary diagnostic and
benchmarking tool designed to measure the dimensions of a successful plan from both a plan
participant and plan sponsor perspective.
Customization
RPA tailors all services to the individual parameters and restrictions of each Retirement Plan,
the plan documents, and the instructions of the plan sponsors.
Assets Under Management
As of December 31, 2022, RPA has assets under management totaling $16,218,185,103. Of
that total, $2,768,068,873 is managed on a discretionary basis and $13,450,116,230 is
managed on a non-discretionary basis.
The parent company of RPA, Cerity Partners and its subsidiaries have aggregate assets under
advisement of $84,224,999,541 as of December 31, 2023.