Human Interest Advisors Disclosures

General Disclosure

Last updated October 17, 2023

Human Interest is an affordable, full-service 401(k) and 403(b) provider that seeks to make it easy for small and medium-sized businesses to assist their employees with investing for retirement. Investment Advisory services provided through Human Interest Advisors, a Registered Investment Adviser. For more information, please visit humaninterest.com.

This content has been prepared for informational purposes only, and should not be construed as tax, legal, or individualized investment advice. Consult an appropriate professional regarding your situation. Human Interest does not provide tax or legal advice. Investing involves risk, including risk of loss. Past performance does not guarantee future results.

Advisory Services Disclosure

Investment Advisory services are provided to plan sponsor and plan participant clients who have signed an agreement with Human Interest Advisors LLC, a subsidiary of Human Interest Inc. (together, “Human Interest”). Human Interest Advisors is a registered investment adviser with the Securities and Exchange Commission ("SEC"). SEC registration does not imply a certain level of skill or training, nor an endorsement by the SEC. Investing involves risk and may result in loss. Past performance is no guarantee of future results.

Human Interest Advisors’ ("HIA") advisory services are bundled with Human Interest Inc.’s (“HII”) plan administration and recordkeeping services. HIA is a subsidiary of HII that shares common control and operational resources with HII, which means there is a lack of fully independent oversight. In addition, this creates a financial incentive for the Adviser and Human Interest Inc. to serve as the providers to advisory clients. Lower fees and higher quality services might be available from third-party providers, bundled or unbundled. Please carefully read Human Interest Inc.’s Terms of Service and Human Interest Advisors’ Terms of Service for a full description of HII and HIA's services.

Additional Information can be found in the company’s Form ADV available at https://humaninterest.com/hia/regulatory-filings/

Fee Disclosures

For information about Human Interest’s pricing, please refer to our Pricing Page, which describes the fees charged for administrative and advisory services (advisory services meaning 3(21) fiduciary investment advisor services and/or 3(38) fiduciary investment manager services as further described in the Terms of Service). Fees for investment advisory services are billed according to the Terms of Service to plans and recorded at the participant account level based upon a percentage of total assets under management. Maximum annual advisory fees are 0.12% of plan assets and do not include a separate annual fee of 0.60% of plan assets paid to HII for recordkeeping and custody-related services. Both of these fees are deducted from employee accounts on a monthly basis.

In addition to the maximum annual advisory fee, additional fee or cost scenarios could occur, and include the following:

1. Mutual fund annual operating expenses are established by each individual mutual fund and disclosed in the relevant prospectus, as well as through fee disclosures provided to Participants. Mutual fund fees are embedded in each mutual fund’s net asset value and are borne equally by each fund shareholder, including those plan participants who elect to purchase shares.

2. Plan Sponsors who elect 3(21) services and select their own mutual funds for their Plan may find that those funds they select carry additional types of fees or expenses.

3. In some instances, Plan Sponsors or Participants may elect services from financial advisors or other professionals, which causes additional fees.

4. Certain mutual funds in our 3(38) lineup charge additional fees*:

Vanguard Long-Term Bond Index Admiral - 0.50% purchase fee (currently paid by Human Interest)
TIAA-CREF Social Choice Bond Premier - 0.15% 12b-1 fee (currently reimbursed by Human Interest to the plan)

*One mutual fund that was previously in HIA’s 3(38) lineup charges an additional fee: TIAA-CREF Social Choice Eq Premier - 0.15% 12b-1 fee (currently reimbursed by Human Interest to the plan). Please note that while the fund was removed from the 3(38) lineup, some plans utilizing 3(38) or 3(21) advisory services may still hold the fund until it has been swapped out by HIA. For 3(21) plans, the plan must opt-in to having the fund swapped out by HIA.

5. Additional fees may be charged to a particular participant by a mutual fund with respect to short-term trading or redemptions that exceed the fund’s established guidelines.

Important information on the fees and expenses, objectives, and risks of any mutual fund can be found in its prospectus. Plan Participants may request a prospectus from Human Interest or navigate to each fund's website to download.

Disclosures about relationships, endorsements, and testimonials

Human Interest maintains relationships with plan sponsors, participants, and other third parties who have an economic relationship with Human Interest. From time to time, they may make statements or provide information about Human Interest, and may have received non-cash compensation or gift cards from Human Interest in exchange for providing the statements or information. From time to time, Human Interest may also provide information about its services and products which is created or supplemented, in whole or in part, using the statements or information that has been provided by one or more current clients or other third parties and which is used to solicit or refer potential clients to HII, or otherwise indicates approval, endorsement, or recommendation of, or describes the experience with, Human Interest. Non-cash compensation may be provided by Human Interest to the party providing the statements or information. When considering this information and when evaluating Human Interest’s advertising, products, and services, you should be aware that the relationship creates a conflict of interest which creates an incentive for the statements or information to be presented in a fashion that is favorable to Human Interest.

Non-cash compensation arrangements will be of a de minimis nature in the form of small gifts, tchotchkes, or other tokens of appreciation. Gift cards were nominal in value. The cost of these incentives will be paid directly by Human Interest and will not be charged to any of Human Interest’s clients. Human Interest expects the good faith value of these items to remain below $250 on a rolling 12-month basis per person. Human Interest may also request and receive approval from certain clients for use of the client’s logo and/or other intellectual property, hyperlinks, or other shared content. As a result, this creates a conflict of interest because the client will seek to portray Human Interest in a favorable light in order to receive or enhance beneficial treatment in the relationship.

Human Interest asks clients to place reviews, positive or negative, on certain third-party websites. While comments are not approved by Human Interest and are subject to the terms of those sites, an actively solicited testimonial creates a conflict of interest as it can encourage a client to provide a review that speaks favorably for or recommend a product or service of Human Interest. Human Interest may, on certain review platforms, offer non-cash compensation of a de minimis nature, in exchange for a written review. Additionally, Human Interest previously offered, on certain review platforms, a small gift card of a de minimis nature, in exchange for a written review. This creates a conflict of interest because the client is financially incentivized to leave a positive review of Human Interest’s products and services. Below is a list of the review platforms on which Human Interest maintains a presence where reviews are actively solicited, non-cash compensation is offered, or both:

G2: From 5/25/22 - 12/31/22, Human Interest offered gift cards as an incentive for clients to complete G2 reviews. Please visit this page to view our most recent overall rating and reviews.

TrustRadius: From 8/23/22-12/31/22, Human Interest offered gift cards as an incentive for clients to complete reviews. Please visit this page to view our most recent overall rating and reviews.

Better Business Bureau® (“BBB”): Human Interest solicits current clients to provide reviews on BBB. Non-cash compensation is provided in exchange for the reviews. Direct solicitation of clients for reviews creates a conflict of interest because the client may be more likely to present information in a fashion that is favorable to Human Interest. Please visit this page to view our most recent overall client reviews score and our BBB rating and accreditation. Please note that client reviews are not factored into the BBB rating. For information on how the BBB rating is calculated, please visit this page.

Google: Human Interest solicited clients for Google reviews in exchange for nominal non-cash compensation from 10/3/23-10/16/23. Active solicitation and non-cash compensation will make a customer more likely to portray Human Interest favorably. Click here for most recent rating.

Referral arrangements

HII utilizes the services of unaffiliated firms (“Referring Partners”) who participate in an agreement with HII to assist with finding new recordkeeping clients. In consideration for such services, HII compensates the Referring Partner with a negotiable dollar amount at the time of the referral, or a percentage of HII’s administrative services fees. Compensation to Referring Partners will be paid directly by HII and will not be charged to any of Human Interest’s clients.

The Referring Partner, in introducing and/or recommending HII’s recordkeeping services, has a conflict of interest with regard to both its relationship with HII and with regard to the compensation that the Referring Partner and/or its representatives receive in connection with making introductions and/or recommendations.

In addition, there are situations where a third party adviser that provides investment advisory services independent of and/or in addition to HIA’s services can refer clients to HII and HII will pay and/or facilitate the payment to the third-party advisor. Such third-party advisor fees are separately negotiated between the third party advisor and the plan.

While the above mentioned referrals are to HII, HIA is an affiliate and can benefit from a successful referral to the extent that it raises assets for the Adviser and related asset-based fees.