Firm Description
All Star Financial Inc. (“ASF”) was approved as an investment advisor in 1992, in 2022 All
Star Financial changed ownership from a Corporation to a LLC. Now known as All Star
Financial LLC dba All Star Financial. Robert J. Klefsaas is majority owner and Matthew A.
Berhow and Eric Gardner are additional owners.
ASF is associated with The Hays Group, an Employee Benefit Consulting firm
headquartered in Minneapolis, MN. The Hays Group, along with ASF, does an extensive
independent analysis of many Pension-Profit Sharing/401(k) money managers and
carriers. ASF and The Hays Group are not affiliated. The analysis consists of measuring
volatility, performance, manager longevity, etc. After the analysis, ASF will consult with the
client and present three to five options for the corporate employee to choose from in
selecting how they want their plan allocated.
Types of Advisory Services
ASF provides service to qualified and non-qualified retirement plans including 401(k)
plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred
compensation plans. As an Accredited Investment Fiduciary, ASF makes sure companies
are using the right process to meet their fiduciary responsibility set by ERISA Section
404(c). Using Fi360’s defined 22 step fiduciary process, ASF helps the ERISA Section 3(16)
plan administrator establish an Investment Committee and develop an Investment Policy
that sets the path to follow and what specific parameters that need to be used to select,
monitor and replace investment options. ASF also educates employees on why they need to
use their plan and how to allocate their assets to best meet their specific goals and
objectives.
ERISA PLAN SERVICES
ASF provides service to qualified and non-qualified retirement plans including 401(k)
plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred
compensation plans. ASF may acts as either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. ASF typically acts as a limited scope ERISA 3(21) fiduciary
that can advise, help and assist plan sponsors with their investment decisions on a non-
discretionary basis. As an investment advisor ASF has a fiduciary duty to act in the best interest of
the client. The plan sponsor is still ultimately responsible for the decisions made in their plan,
though using ASF can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding the
initial selection, retention, removal and addition of investment options.
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Client shall have
the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
2. Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands the Advisor’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such, the
Advisor is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the
Plan participants. Advisor will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a
particular participant or beneficiary under the Plan.
Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Advisor
may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Client.
3. The Advisor has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Advisor under this
Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. ASF can also act as an ERISA 3(38) Investment Manager in which it
has discretionary management and control of a given retirement plan’s assets. ASF would then
become solely responsible and liable for the selection, monitoring and replacement of the plan’s
investment options.
1. Fiduciary Services are:
Adviser has discretionary authority and will make the final decision regarding the
initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
Provide discretionary investment advice to the Client with respect to the selection
of a qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The
Client retains the sole responsibility to provide all notices to the Plan participants
required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands the Adviser’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such, the
Adviser is not providing fiduciary advice as defined by ERISA to the Plan
participants. Adviser will not provide investment advice concerning the prudence of
any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Adviser may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Adviser and Client.
3. The Adviser has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser under this
Agreement.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written client consent.
Wrap Fee Programs
ASF does not sponsor any wrap fee programs.
Client Assets under Management
ASF has the following ERISA assets under management:
3(21) plan Amounts: 3(38) plan Amounts: Date Calculated:
$373,771,792 $118,561,549 12/31/2023