Financial Engines Advisors L.L.C. ("FEA" or “Edelman Financial Engines” or the “Firm”) is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). FEA provides comprehensive financial advisory services to clients to help them meet their financial and retirement goals. We offer a suite of services that provide different levels of interaction with FEA based upon the unique needs of each client. We are a fiduciary for our advisory services, and none of our planners receive commissions or fees tied to the sale of certain types of products (see Item 10 for more information on commissions and fees). FEA was established in 1997; Edelman Financial Services was founded in 1986. On November 1, 2018, Financial Engines Advisors L.L.C. (sometimes referred to as “legacy FE” or “legacy Financial Engines”) and Edelman Financial Services, LLC (sometimes referred to as “legacy EFS” or “legacy Edelman Financial”) came together under the FEA ADV to offer investment advisory services to clients. The name of the registered investment advisor remains Financial Engines Advisors L.L.C.; our overall business primarily operates using the name "Edelman Financial Engines". In all circumstances, advisory services are provided by Financial Engines Advisors L.L.C., the investment advisory firm registered with the SEC. The principal owner of FEA is Edelman Financial Engines, LLC. The ultimate parent company of Edelman Financial Engines, LLC, and in turn FEA, is Edelman Financial Engines, L.P.1 I. Overview of Advisory Services Edelman Financial Engines provides technology-enabled investment advisory services, including financial planning, investment management and retirement income solutions, for a variety of account types including employer-sponsored defined contribution accounts (401(k), 457, and 403(b) plans), individual retirement accounts (“IRAs”), and taxable accounts. We help individuals, either online, through one of our tools or with an advisor representative, develop a strategy to help them reach their investment and retirement goals. We do this by offering a comprehensive set of services, including holistic, personalized plans for saving and investing, assessments of potential retirement income levels in a variety of scenarios, and the option to speak on the phone or meet face-to-face with an investment advisor representative. As further explained below, our services generally can be accessed either through the workplace, online or through one of our investment professionals. Advisory services are tailored to the individual needs of clients, and clients can impose reasonable restrictions on relevant accounts in consultation with us. Clients participate in a wrap fee program offered by the Firm, for which we receive a portion of the wrap fee for our services. Edelman Financial Engines works to ensure that clients are engaged with services and tools that will help them achieve their long-term goals in a manner that is appropriate for their needs. Edelman Financial Engines maintains practices to reasonably ensure that clients are directed towards services which will help them work towards those goals in a method that is in their best interest. Edelman Financial Engines has acquired or may acquire certain advisory clients through acquisitions or otherwise. Those clients will generally transition to Edelman Financial Engines models, practices, and methodologies over time in a reasonable manner. For an interim period, they may remain invested, and have their accounts managed and administered, in the manner they were at their legacy firms; including in connection with individual equities, alternative assets, and other holdings established prior to acquisition by EFE. 1 Ric Edelman was a co-founder and employee of Edelman Financial Engines. He ceased being an employee and supervised person of the Firm in December 2021. When we provide investment advice or recommendations to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated creates some conflicts with our clients’ interests, so we at times operate under a special rule of the US Department of Labor (“DOL”), Prohibited Transaction Exemption (“PTE”) 2020-02, which requires us to act in their best interest and not put our interests ahead of theirs. Under the PTE’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of our clients’ when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the client’s best interest;
• Charge no more than is reasonable for our services; and
• Give clients basic information about conflicts of interest. II. Discretionary Advisory Services Offered through the Workplace Through a variety of service offerings, Edelman Financial Engines works with participants who have invested in their employer’s retirement plans to manage their workplace retirement accounts and help them reach their retirement goals. The Firm offers the following services for employees’ workplace retirement and other accounts through an agreement between the Firm and the plan and/or the sponsoring employer (“plan sponsor”). Professional Management Edelman Financial Engines helps plan participants by providing discretionary investment management for their retirement plan accounts through the Firm’s Professional Management service. That service includes the following features:
• a Retirement Plan or similar document outlining how the Firm will manage and allocate the account. This can include, for example, the account’s portfolio allocation target, suggestions regarding the client’s savings and a forecast regarding their likelihood of achieving their self-articulated retirement goals;
• periodic portfolio monitoring: o updates on current retirement account balances and estimated contributions, and a retirement income forecast; o the Firm provides suggestions for ways to modify the income forecast, set appropriate risk levels, and get a more holistic picture of likely retirement finances; and o Quarterly Retirement Updates outlining, among other things, how the account is performing against goals;
• phone access to investment advisor representatives as well as online account access; Professional Management is generally made available to plan participants in a defined contribution plan through an agreement between the Firm and the plan sponsor. That agreement will specify the methods of enrollment into Professional Management for eligible plan participants, which may include:
• an “opt-in” method of enrollment where a retirement plan participant actively elects to enroll in the program;
• an “opt-out” method of enrollment where eligible plan participants are automatically enrolled in Professional Management in accordance with plan or plan sponsor specifications, with the ability to withdraw at any time without penalty. With this type of enrollment, Professional Management may be designated as a qualified default investment alternative (“QDIA”), as permitted under ERISA; or
• some combination of both methods, as determined by the plan or plan sponsor and as agreed to by the Firm. Plan participants who enroll in Professional Management grant the Firm discretionary authority to determine an allocation target for the plan account based upon a variety of inputs provided to the Firm and then to direct the plan provider to execute transactions in a manner designed to achieve that target. This discretionary authority allows the Firm to allocate the client’s plan account among the menu of investment alternatives that have been selected by the plan or plan sponsor, excluding any brokerage window option (if applicable) or other plan restricted investments. To allow the Firm to provide Professional Management, the plan provider supplies information about each plan participant and the plan account to the Firm. Professional Management clients may provide additional information to the Firm concerning a variety of inputs, including desired retention of company stock, risk preference, asset class exposure limitations, assets held outside the plan, investment objective, and desired retirement age. The Firm determines an investment strategy and an allocation target based on a reasonable understanding of what is in the best interest of the client, including by considering the client’s current age, an assumption about the retirement age, the available investments for the account, any pension plan information provided, an assumption about risk tolerance that is based on the client’s current age and assumed retirement age, the client’s current portfolio allocation, and any additional information provided by the client. Additional information provided by the client may modify these parameters. During the period following enrollment, the Firm determines how to transition the account toward the allocation target, directs the plan provider regarding allocation of the account (which may include transfer or exchange directions) and provides directions regarding new contributions to the account. The Firm does not give account directions relating to plan restricted investments. Certain plan sponsor “insiders,” as defined under applicable regulations, and non-U.S. participants in plans, may not be eligible for the Professional Management program. Income Beyond Retirement Professional Management clients may also, if their plan provider has elected to offer this service and if available under the plan sponsor’s agreement with the Firm, access the Firm’s “Income Beyond Retirement” feature. This service provides portfolio management and income payout options to retirees and near retirees from their 401(k) or similar plan account. For those who elect this feature, the Firm manages the client’s portfolio to balance between safety and growth, seeking to protect the ability of the account to generate future income. Income Beyond Retirement also allows additional flexibility for a client to select what portion of their managed account is managed on our standard “growth” objective, and what portion is managed on an “income” objective. Income Beyond Retirement seeks to manage investments and to create payouts that can generally last clients into their early 90s. Upon request, in addition to managing the investment allocations in such accounts, the Firm will work with the plan provider to calculate and facilitate withdrawals from the client’s plan account post-retirement. The Firm does not receive any additional compensation for providing the Income Beyond Retirement service. Professional Management clients at certain plan sponsors may have access to the Income+ feature of Professional Management, a predecessor feature to Income Beyond Retirement. Income+ offers many of the same features as Income Beyond Retirement but does not permit Professional Management members to select what portion of their account is managed on a “growth” or “income” objective; instead, the member’s account will be managed on an “income” objective only. Clients pay no additional fees for the Income Beyond Retirement or Income+ features, and they can transition to an Income Beyond Retirement/Income+ portfolio either automatically upon eligibility or at their request (as defined, in part, by the agreement between the Firm and the relevant sponsor). An account balance is maintained for an optional out-of-plan annuity purchase. An in-plan annuity need not be included in a plan’s investment lineup for a plan sponsor to offer Income Beyond Retirement or Income+ to its participants. While the Firm may provide general educational information regarding an out-of-plan annuity, it does not sell or distribute annuities and does not receive any compensation related to out-of-plan annuity purchases made in relation to the Income Beyond Retirement or Income+ features. Income Beyond Retirement and Income+ availability is subject to establishment of certain data connectivity arrangements between the Firm and the applicable plan provider and is subject to applicable retirement plan provisions related to plan withdrawals. Workplace IRA Where previously available, plan participants who already have a managed workplace account may have had access to the Firm’s “Workplace IRA” offering, a fee-based individual retirement account (“IRA”) management service offered through the workplace. In some limited circumstances, IRA management services may also have been available to spouses as well as to the plan participants. Personal Advisor If available under the plan sponsor’s agreement with the Firm, plan participants can access our Personal Advisor service. Personal Advisor is a holistic investment advisory service which provides access to a planner and investment management on the participant’s workplace account (as described in the Professional Management section above) and can also provide discretionary investment management on non-workplace assets. The non- workplace assets are invested in either a customized portfolio generated from the Firm’s advice platform or in a model portfolio. Plan participants who select the Personal Advisor service pay an additional fee, as described in Item 5. Personal Advisor requires use of one of the custodians utilized in the Firm’s Wrap Fee Program for the participant’s non-workplace assets, as described in Item 12. For plan participants who do not have access to the Personal Advisor service, comparable investment management of their non-workplace accounts may be available directly through a planner, as described in Section IV below. III. Sub-Advisory Services In addition to providing investment advisory and related services directly to clients under arrangements with employer-sponsored plans and plan sponsors, the Firm also has arrangements with certain third parties to provide similar services on a sub-advisory basis. The Firm may license certain technology and software and provide other services to financial services firms to enable those firms to provide investment advisory and related services. For example, the Firm may develop and host customized or private-labeled websites to enable a financial institution to make investment advisory and related services available to that institution’s clients. Depending on the arrangement with the financial institution, the Firm may act as sub-advisor to the financial institution, or the Firm may act as a technology vendor and the financial institution will be responsible for making investment recommendations to its clients. Additionally, at the direction of the third party the firm may conduct phone-based engagements with plan participants in its capacity as sub-advisor and designated investment expert under applicable DOL rule. IV. Discretionary Advisory Services through Planners Edelman Financial Engines offers investment advisory services for qualified and taxable accounts through planners working in one of our offices nationwide. These services include making and implementing investment decisions for clients based on their needs and providing ongoing advice. In consultation with a client and after consideration of their goals, risk tolerance, investment horizon, and needs, planners will typically prepare a financial plan which takes these factors into consideration and most typically recommend a Firm created model offered through the Firm’s Wrap Fee Program. At times we may also recommend a more customized set of investments for a client whose needs are better served outside of one of the standard models offered by the Firm, including where the Firm has acquired assets and clients through acquisition. For more information on the Firm’s Wrap Fee Program, please see our Wrap Fee Brochure. Generally, clients who have investable assets below a certain threshold and/or who have less complex financial needs and therefore may not need the same services offered by planners working in an office (including the ability to meet in person) will usually work with a centralized, team-based group of professionals who can help provide services which are more appropriate to such clients’ needs. The fee for working with dedicated planners in an office is the same as that for working with professionals in a team-based approach and is outlined in Item 5. Model portfolios and custom models available through the Wrap Fee Program feature allocation appropriate for each client and their needs. The investments in these accounts include, but are not limited to, equities, cash or cash equivalents, CDs, bonds, and funds registered under the Investment Company Act of 1940, for example, closed-end funds, mutual funds, and exchange traded funds (“ETFs”) (collectively referred to as “securities”). Cash equivalent products may include mutual funds and/or ETFs, as well as Federal Deposit Insurance Corporation (“FDIC”) insured bank certificates of deposit, or other types of holdings as appropriate. Investments may range across various asset classes. The securities, asset categories and portfolio weightings vary for each model. In order to determine the model most suited to a client's needs and circumstances, planners speak with clients to discuss their specific situation and review various information provided. Investment objectives and risk tolerance are key factors that help planners recommend an appropriate model. Planners also consider other inputs which can include, but are not limited to, the client’s age, health, family circumstances, income, expenses, assets, debts, liquidity needs, goals, personal objectives, and time horizon. Tools are available to help planners and clients choose a model. If a client’s investment objectives, risk tolerance or financial situation changes, they are instructed to contact their planner so that appropriate changes, if any, can be discussed and implemented. Edelman Financial Engines generally manages client accounts and the assets within them on a discretionary basis, in accordance with the client’s objectives and goals. There are also situations where certain assets may be, for some period of time, held in a client’s account without being managed by the Firm. Unless a different arrangement is agreed to with a particular client, we will not assess an advisory fee for such assets held within an account for longer than what might be considered reasonable under specific circumstances. Clients may request reasonable restrictions on the types of investments that will be made on their behalf or on the management of their account. A client will ultimately be placed in a model or allocation that the Firm believes is in their best interest and meets their needs, and which allows for such reasonable restrictions as appropriate. A client cannot usually request that we buy specific holdings or types of holdings, although exceptions may be granted. We reserve the right, at our sole discretion, to close an account (or decline to open one) if overly constraining restrictions are requested or the restrictions requested are incompatible with the client’s objectives and/or the portfolio recommended. The Firm offers clients the ability to aggregate and share with Edelman Financial Engines

information concerning other investment and financial accounts established through or held with third parties. While aggregating and sharing such information does not mean that Edelman Financial Engines will manage or advise on those outside accounts, it does help our planners offer more holistic and personalized investment advice to our clients. It is up to each client to decide whether to share such information. Planners generally prepare and/or discuss a financial plan for prospective clients prior to the commencement of advisory services. As discussed above, this financial plan is based on a variety of factors provided by the client and is designed to assist them in achieving their stated goals and objectives. The financial plan will evolve as we learn more about the client and as their circumstances change. Whether to implement the financial plan with Edelman Financial Engines or elsewhere is entirely at the client’s discretion. Clients who choose to implement the financial plan elsewhere will not receive ongoing investment advice from the Firm. The Firm may also offer a retirement review to prospective clients in certain marketing campaigns. The Firm may, at its sole discretion, decline to assist a client with the implementation of investment strategies or choices that have not been recommended or that we deem not to be in the client’s best interest. Our objective is to provide services which are in the best interest of our clients. A conflict of interest exists for our planners as they have an economic incentive to offer certain advisory services, including recommending rollovers to clients from defined contribution, defined benefit, and other plans. This applies to those services for which the advisory fee that Edelman Financial Engines charges, and the compensation that the planner receives, is a function of the assets under management. With respect to rollovers from qualified plans, clients are under no obligation to roll them over to Edelman Financial Engines and should carefully consider all relevant factors before doing so. While Planners may discuss tax topics, generally, in the context of providing holistic financial planning for certain clients, Planners do not provide legal or actionable tax advice. Clients are advised to work with an attorney or accountant on matters requiring legal or tax counsel. Planners may also at times refer clients to certain other third-party service providers, who could potentially assist them with their needs. In such situations, the Firm introduces the client to the service provider, who then works directly with the client to assist them with those services. The Firm is not compensated for such introductions to these third-parties. Additionally, Edelman Financial Engines, through an affiliate, may assist certain clients with individual tax related items pursuant to the terms in their agreements. Services Available to Address Specific Client Needs Retirement Paycheck® Service The Retirement Paycheck service is designed to help clients generate a consistent income stream in retirement while remaining invested in the financial markets as a long-term investor. Retirement Paycheck accounts have two components. The income generation component generally places three years’ worth of monthly income into lower risk investments, such as U.S. government bonds, FDIC-insured bank CDs, money market funds, or highly rated short-term corporate bonds. After determining how much should be allocated to the income generation component of this service, remaining funds are invested in a highly diversified portfolio to help guard against inflation and increases in the cost of living. The period for which an income stream can be generated depends on the amount of the income to be generated, additional unanticipated withdrawals taken from the account, and market conditions. Clients do not pay any commissions, upfront fees or surrender penalties for this service, and can cancel at any time. Clients do pay a fee in addition to the wrap fee, for fixed income trades which are utilized in the Retirement Paycheck service. Clients placed in the Retirement Paycheck service authorize the Firm to provide portfolio management services and to direct the investment and reinvestment of the client’s assets. Customized Portfolios Certain Edelman Financial Engines clients can invest in customized portfolios. While the investment management philosophy is the same as for model portfolios, customized portfolios determine appropriate allocations at the household level for individual clients. Accounts enrolled in this feature are regularly monitored and consider factors such as individual tax circumstances, unmanaged assets, concentrated positions, objectives, risk tolerance, and other relevant factors. Management of Held Away Assets The Firm offers discretionary management services for assets in certain defined contribution plan participant accounts, such as 401(K)s, through a third-party platform. These assets are held away from our primary qualified custodians and are held in the custody of the plan custodian(s). Through this platform, the Firm does not maintain custody of Client assets, as it does not have direct access to Client login credentials required to execute trades. The Firm is not affiliated with the platform in any way and receives no compensation for using their services. A link will be provided to Clients enabling them to connect their account(s) to the platform. Once Client’s account(s) is connected, the Firm will review the current asset allocations. In consultation with the Client, and considering their goals, risk tolerance, needs, and investment horizon, the Firm will reallocate the assets in the account. This may include some or all the securities made available through the platform. Once the appropriate allocation is determined, it is continuously and regularly monitored, and rebalanced if necessary. Turnkey Asset Management Program (“TAMP”) The Firm’s Turnkey Asset Management Program (“TAMP”) program makes Wrap Fee Program models available to clients of select unaffiliated investment advisers (“TAMP Advisors”). The wrap fee is shared between Edelman Financial Engines and the TAMP Advisors on a negotiated basis. V. Non-Discretionary Online Advice Online Advice is a dynamic online service that allows individuals to input and/or access information in an online portal in order to obtain advice and information on the holdings within their accounts. This service is non- discretionary in nature and no holdings are bought or sold for clients using Online Advice unless they themselves initiate trading activity. Online Advice is primarily available to participants in employer-sponsored defined contribution plans through an agreement between the Firm and the plan and/or the sponsoring employer. This service is not available to new subscribers or for existing subscriber renewals. Once certain information is provided by the client into the Online Advice service, or upon that information being provided automatically where available, the Firm’s Online Advice service will generate:
• a forecast of the client’s potential future account value or the potential annual retirement income based upon the information provided;
• a forecast of the likelihood that a client will achieve their self-reported retirement income or account value goals, taking into consideration the total household investment portfolio as known by the service;
• phone access to investment advisor representatives via a toll-free number;
• guidance on savings rates and retirement age; and
• as outlined below, investment recommendations. Investment recommendations Online Advice clients can receive specific non-discretionary buy and sell recommendations for tax-deferred and/or taxable accounts, and – where applicable – on investments held within a company’s qualified retirement plan. To obtain such recommendations, clients specify the universe of available investment alternatives they wish Online Advice to consider. For those accessing these services through their employer, Online Advice clients will receive specific recommendations on how to allocate their funds among the universe of investment alternatives (generally mutual funds and, in some cases, one or more equity securities issued by the plan sponsor) that have been selected by their plan sponsor or other plan fiduciary for the applicable defined contribution plan (or by another financial institution or the adopter in the case of other accounts outside the plan account). Online Advice can provide recommendations with respect to mutual funds, commingled funds, separate accounts, and exchange-listed equity securities (sell only). When generating investment recommendations, the Firm may take into consideration closed-end funds and exchange traded funds as well as other holdings, as appropriate and where it has access to such information. The Firm also offers educational content to clients who use Online Advice. The educational content may include an analysis of the risk, expenses, style, turnover and historical performance of a particular mutual fund compared to its peers and may describe how the fund might perform in the future relative to its peers. The educational content may also present a graphical representation of historical performance of an illustrative investment in the fund. Advice implementation The Online Advice client is responsible for determining whether and when to implement the recommendations they receive from Online Advice. The Firm has established electronic communications links with certain defined contribution plan providers (“plan providers”) and other financial institutions. With Online Advice, the Firm does not have discretion over client accounts and does not initiate trade instructions on behalf of clients. Account monitoring through Online Advice Clients may use Online Advice as frequently as they choose to monitor progress toward their retirement goals, receive forecasts and investment recommendations, and access educational content. Online Advice updates the values of most mutual funds and stocks in plan accounts daily. A client is responsible for periodically revisiting Online Advice to ensure that account information, holdings and personal information is accurate and up to date. The failure of an Online Advice client to review and periodically update their personal and financial information can materially affect the value of this service. For certain participants, some account information may be updated automatically when the client revisits Online Advice if the Firm has established an electronic communications link with the participant’s plan sponsor and/or plan provider or other financial institution. For manually added and linked accounts, we rely on the client to provide ongoing and updated data either by logging in to refresh a linked account or by manually updating the manually added accounts. The Firm may periodically provide e-mail notifications to clients concerning changes in the value of the client’s investments or the chances of reaching the client’s goal. VI. Other Services Offered by the Firm Retirement Plans Division (RPD) The Retirement Plans Division – Small Business (“RPD”) is available to plan sponsors of 401(k), profit-sharing, non-qualified deferred compensation and retirement plans (“Plans”), as a separate service offering from our traditional workplace offering. These Plans can include both participant-directed and trustee-directed Plans. Through RPD, Edelman Financial Engines creates and maintains model asset allocation portfolios for Plans. It is intended for small and mid-sized companies, organizations, endowments, and associations, who may benefit from value-add services such as participant education, professionally managed model portfolios and a single point of contact for the sponsor of the plan and its employees. Edelman Financial Engines offers plan sponsors the option of delegating discretionary authority to Edelman Financial Engines with respect to the selection of models on behalf of the Plans in RPD. In such cases, Edelman Financial Engines will select the underlying asset classes for the models and the underlying investment securities for each underlying asset class. Usually, the investment securities consist of funds including, but not limited to, mutual funds and ETFs. The plan sponsor (or other plan fiduciary or agent) approves models to be used for the Plan’s assets, and then Edelman Financial Engines invests pursuant to those models on behalf of the Plan. Generally, in the case of a participant-directed Plan, after the plan sponsor (or other Plan fiduciary or agent) reviews and approves certain recommended models, the models are offered to Plan participants as investment options. Participants select an investment option for their Plan accounts. We do not have discretion to choose a particular option for participants as these plans are employee-directed. Therefore, we are not responsible for reviewing or changing any participant’s decision to invest in a particular investment option. RPD may also offer, as negotiated, assistance with Investment Policy Statements, Designated Investment Alternatives, Qualified Default Investment Alternatives or Retirement Plan Consulting Services. Edelman Financial Engines is not responsible for the administration of the Plan. The responsibility is designated to a third-party administrator. Plan sponsors (or other Plan fiduciaries or agents) are permitted to impose reasonable restrictions on the underlying assets used in the investment options recommended to the Plan. For example, a plan sponsor (or other Plan fiduciary or agent) may request that securities or types of securities not be purchased, or that such securities be sold. Edelman Financial Engines reserves the right, at our sole discretion, to reject any Plan account where unreasonable or overly restrictive conditions are requested. Plan sponsors (and other Plan fiduciaries or agents) may be introduced to RPD through other unaffiliated registered investment advisers. The unaffiliated registered investment adviser initiates and maintains the relationship with the plan sponsor. The unaffiliated adviser may charge a separate fee for its services and does not share in the advisory fee generated from any Plan assets that are invested in RPD. Edelman Financial Engines receives no compensation or economic benefit from products or services offered by the unaffiliated adviser to Plans, other than from the services which RPD provides under a separate Investment Management Agreement, nor does the Firm compensate any such unaffiliated parties for such introductions. Separate from, but related to the RPD business, Edelman Financial Engines planners provide certain investment advisory services on certain non-ERISA (e.g., a simple IRA or a SEP IRA) and certain ERISA covered plans. The latter could be solo Defined Benefit plans or individuals within a defined benefit or defined contribution plan where the employees are able to hire an investment advisor to manage their investments within the plan. In addition, Edelman Financial Engines planners may establish a client relationship with one or more plan participants or beneficiaries in various ways, including but not limited to:
• A plan participant or beneficiary seeking advice on assets they hold outside their plan (such as a non- qualified investment account);
• As part of an individual or household financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relate to assets held outside of the plan; and/or through a rollover of an Individual Retirement Account ("IRA Rollover"). If we are providing the stated retirement plan services to a plan, our planners may, upon the request of a plan participant or beneficiary, arrange to provide investment advisory services on assets they hold outside their plan directly to that participant or beneficiary through a separate investment management agreement. See Section IV. Discretionary Advisory Services through Planners above for details. Ready Cash™ Individuals, including clients and may include prospective clients, who are seeking a place to maintain their cash reserves are offered to open an account at UMB Bank, N.A. (UMB), Member FDIC (“Ready Cash™”) through the Firm’s online portal (“Customers”). The account is at UMB Bank, N.A. and is not an investment advisory account managed by Edelman Financial Engines. The cash balance participating Customers placed through Ready Cash™ is in turn placed by UMB at participating program banks, where it earns a variable rate of interest and is eligible for FDIC deposit insurance. Customer funds are FDIC insured up to applicable limits while in transit through UMB. Edelman Financial Engines receives a platform fee from UMB in exchange for providing the Ready Cash service to its Customers. Receipt of the platform fee presents a potential conflict of interest as the Firm receives an economic benefit related to Customers who choose to participate in the Ready Cash™ program, as opposed to other alternatives in the market. In addition, planners may receive more compensation related to the provision of advisory services than with Ready Cash™, creating a potential conflict as well. The Firm does not believe that either conflict is material. Ready Cash™ availability may be limited based on operational capacity. Educational Products and Guidance The Firm, or an affiliate, in a non-fiduciary capacity, may offer retirement plan and related guidance and education, including as a workplace benefit, separate from the discretionary and non-discretionary services described above. Such services may include wellness education through phone-based counselors with digital tools and guidance. Generally, availability of such services is subject to the agreement between an employer and the Firm and/or its affiliates. The Firm, subject to plan sponsor authorization, may provide plan participants with a Retirement Evaluation. The Retirement Evaluation is made available in printed or electronic format to specified plan participants, and is designed to communicate some (or all) of the following information:
• a summary of the current value of the participant’s plan account;
• a forecast of how much the plan account investments, and other investments that participants submit for analysis, might be worth at retirement;
• whether a change is suggested to the participant’s contribution rate, their portfolio’s risk and diversification, unrestricted company stock holdings, if applicable, target date usage, if applicable, and/or investment style and allocation;
• investment proposals; and
• a projection of how much annual income the participant may anticipate at retirement, based on how much the plan account plus Social Security and certain other benefit accounts could provide. Recordkeeping Through an arrangement with a third party, the Firm provides recordkeeping services to a limited number of retirement plans. These services are separate from the Firm’s Online Advice, Professional Management, and Personal Advisor services described in Item 4. VII. Amount of Discretionary and Non-Discretionary Client Assets that FEA Manages As of December 31, 2023, FEA managed approximately $270,770,414,650 in assets on a discretionary basis. FEA did not manage any assets on a non-discretionary basis as of December 31, 2023.