Overview
Stone Hill Fiduciary Management, LLC ("Stone Hill") is a New York-based investment
advisor and independent ERISA fiduciary, established July 1, 2012. Stone Hill is owned
by Sheldon Martin Geller, the President and Managing Member.
The sole business of Stone Hill is providing investment advisory services and fiduciary
services under the Employee Retirement Income Security Act of 1974, as amended
("ERISA") to retirement plan sponsors ("Plan Sponsors") relating to the retirement plans
of the Plan Sponsors (each, a "Plan").
Client Plan Sponsors can place limitations on discretionary authority and require approval
prior to the exercise of same with respect to one or more types of Plan transactions as
mutually agreed upon and as set forth in the agreement entered into by and between Stone
Hill and the Plan Sponsor for investment advisory and ERISA fiduciary services.
Stone Hill acts as an ERISA Section 402(a) Named Fiduciary for Plan investments, an
ERISA Section 402(a) Named Fiduciary for Plan administration, an ERISA Section 3(16)
Managing Fiduciary Plan Administrator, an ERISA Section 3(21) investment advisor and
an ERISA Section 3(38) investment manager on behalf of the Plan Sponsor. In the
alternative, Stone Hill acts only as an ERISA Section 3(21) investment advisor. In rare
cases, Stone Hill can act solely as either a 3(38) investment manager while not serving as
a 3(16) Managing Fiduciary Plan Administrator, or act as a 3(21) investment adviser and
a 3(16) Managing Fiduciary Plan Administrator.
Pursuant to a Managed Account Sub-Advisory Agreement, Stone Hill serves as a Sub-
Adviser to an SEC-registered Investment Adviser, acting as an ERISA Section 3(21)
investment advisor on behalf of the underlying Plan Sponsor.
Stone Hill assists the Plan Sponsor of a participant-directed plan in determining an
appropriate investment, custodial and recordkeeping platform for the Plan, the selection
of offerings in the investment menu for plan participants on the platform of the underlying
Plan, and reviews and evaluates the diversification of the funds offered to Participants at a
Plan-level (not a Participant-level).
Stone Hill assists the Plan Sponsor of a trustee-directed plan or an employer-directed plan
as to the broad asset allocation approach, including allocation performance analysis and
investment advice regarding plan assets of pension, profit sharing and retirement plan
accounts subject to ERISA.
Stone Hill also provides ongoing services to Plan Sponsors, including: (i) monitoring the
Plan's investment lineup pursuant to the Plan's investment policy statement, including
recommendations to add or delete funds offered by the Plan to participants; (ii) providing
a periodic fiduciary review, performance summary and managing fiduciary's report for the
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Plan; (iii) providing an annual assessment of employer practices, operational compliance,
service provider quality, fees and expenses for the Plan; and (iv) as requested, conducting
requests for proposals and requests for information and performing searches and
comparisons of appropriate platforms and service providers, all pursuant to a documented
process based on the needs of the Plan.
Stone Hill provides appropriate guidance to Participants pursuant to the safe harbor
provisions under ERISA.
As a registered investment advisor, Stone Hill is a fiduciary to its advisory clients. As a
Managing Fiduciary and a Named Fiduciary, Stone Hill exercises discretionary authority
and control respecting the management of the Plan and the management of its assets and
has discretionary authority and discretionary responsibility in the administration of the
Plan. Therefore, Stone Hill is a "fiduciary" under ERISA with respect to Plan
administration and with respect to Plan investments, including to the extent it renders
"investment advice" to the Plan within the meaning of Section 3(21)(a)(ii) of ERISA and
the Department of Labor regulations promulgated thereunder.
Neither Stone Hill nor the Plan Sponsor provides the Participants with any investment
advice. The Participants are responsible for any individual investment selections made
under the participant-directed Plan.
Stone Hill renders investment advice and fiduciary guidance to the Plan Sponsor, the
board of directors of the Plan Sponsor, the trustees of the trust established as a part of the
Plan and the retirement plan committee appointed by the board of directors of the Plan
Sponsor as to plan assets of pension, profit sharing and retirement plan accounts subject to
ERISA.
Stone Hill is not a participant in any wrap fee programs.
Stone Hill has $2,160.5 million in plan assets under management as of February 29, 2024,
as follows:
Discretionary plan assets - $ 1,489.1 million
Non-discretionary plan assets - $ 671.4 million