SAGEVIEW ADVISORY GROUP, LLC

This Brochure describes the retirement plan consulting, retirement plan asset management, investment management, financial planning and related advisory and supporting services offered by SageView Advisory Group, LLC (“SageView,” the “Firm,” “we” or “us”). SageView is a California limited liability company with a headquarters in Newport Beach, California. SageView’s principal owner is AQ Sage Parent, G.P. (“Sage Parent”), a privately held holding company under the control of Aquiline Capital Partners (“Aquiline”).

SageView is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”), SEC File No. 801-64265, and provides investment advisory services designed to help clients with their financial goals. The Firm conducts business throughout the United States through investment adviser representatives (hereinafter “Institutional Retirement Advisors” or “Wealth Advisors”, which shall be generally referred to herein as “Advisory Representatives”). Each of our Advisory Representatives is permitted to offer all or any combination of the advisory services and programs described below to our clients.

We provide discretionary and non-discretionary investment management services to ERISA Plans, such as tax-qualified retirement plans, pension plans, employee stock ownership plans and other employee pension benefit plans subject to Title 1 of the Employment Retirement Income Security Act of 1974 (“ERISA”) as well as to non-qualified deferred compensation plans, retirements plans offered by a government entity, church, or other entity that is not covered by ERISA (“Non-ERISA Plans,” and together with ERISA Plans, “Plans”). We also provide investment management, financial planning and related financial services to individual clients. 

As of December 31, 2025, the Firm had $37,502,470,791 in assets under management, of which $37,502,470,791 was managed on a discretionary basis and $0 was managed on a non-discretionary basis.

Institutional Retirement Services

1. 1) Retirement Plan Consulting. 
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We provide retirement plan consulting services to tax-qualified retirement plans, pension plans, and other ERISA Plans as well as to non-qualified deferred compensation plans, retirements plans offered by a government entity, church, or other Non-ERISA Plans and their fiduciaries. These services are delivered through one or more retirement plan consulting advisors (“Institutional Retirement Advisors”) and are designed to assist the sponsor of the retirement plan (the “Plan Sponsor”) in meeting the goals of the Plan, and in the case of an ERISA Plan, to assist the Plan Sponsor with its management and fiduciary obligations as set forth in Title 1 of ERISA. When we are hired to provide non-discretionary advice, the Plan retains ultimate responsibility for making investment decisions and is not obligated to act upon any of our recommendations (“Retirement Plan Consulting”). Retirement Plan Consulting is provided pursuant to a retirement plan consulting services agreement, and consists of general and/or specific advice delivered by an Institutional Retirement Advisor, which may include some or all of the following services:

-Plan Setup: Assistance with the Plan construction and initial set up on a recordkeeping platform selected by the Plan.

-Plan Conversion: Assistance with converting a Plan from an existing recordkeeping platform to a new recordkeeping platform. 

-Recommendations and monitoring of investment options: Assistance with reviewing (at least annually) the investment options of the Plan’s investment menu and, when warranted, recommending changes in the Plan’s investment option(s). 

-Plan Performance Review: Assistance with a periodic review (at least annually) of the performance of the Plan’s investments to determine whether the terms of the Plan, Plan design and investment 5 options are meeting the needs of the Plan’s participants in accordance with the Plan’s investment policy statement (IPS). 

-Benchmarking of the platform, fees and services: Review of and benchmarking of the Plan’s recordkeeping fees, services and investments. 

-Plan Operations Review: Periodic review of specific Plan objectives as determined by the Plan and analysis on whether the Plan is operating in accordance with Plan’s investment objectives, IPS and applicable provisions of ERISA as it relates to the specific items.

2) Retirement Plan Asset Management. 

When SageView is appointed as the investment manager to the Plan on a discretionary basis, we provide ongoing investment management services to the Plan, including selecting, monitoring, removing, and/or replacing the available investment options within the Plan, consistent with the objectives, written guidelines and/or investment objectives set forth in the IPS accepted and adopted by the Plan, without obtaining the Plan’s prior consent to make such decisions (“Retirement Plan Asset Management” and together with Retirement Plan Consulting, “Retirement Plan Investment Advice”).

In providing Retirement Plan Investment Advice, we will not advise on any investments not selected, recommended or reported as monitored by SageView, including, but not limited to Plan Sponsor securities, whether or not in the Plan’s investment menu, real estate (other than real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets (other than Collective Investment Funds or non-publicly traded securities or assets recommended by SageView), other illiquid investments, self-directed brokerage accounts (e.g., through a plan brokerage window), and any advisor managed accounts (unless otherwise agreed to in writing), any other investment product that SageView designates as an excluded asset by providing notice to the Plan (collectively, “Excluded Assets”). If a Plan elects to make any Excluded Asset available for the Plan, it must do so within its sole discretion and must acknowledge that it has done so without reliance upon any information provided by SageView that served as a primary basis for such decision. In addition to Retirement Plan Investment Advice, we also offer Investment Policy Statement services in which we gather information regarding a Plan’s investment policies and objectives and assist with the creation of a new IPS or review a Plan’s pre-existing IPS to evaluate the Plan’s adherence to it.

Where we provide Retirement Plan Investment Advice to Plans, we are acting as a fiduciary of the Plan as defined in Section 3(21)(A)(ii) of ERISA. SageView is also acting as a registered investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”). However, unless otherwise agreed to, SageView generally (i) does not act as a fiduciary within the meaning of Section 3(21) of ERISA nor as an “investment manager” as defined in Section 3(38) of ERISA, in attending meetings, providing reporting, or participant education (if applicable); (ii) will not review every investment option available in the industry or every investment option that can be made available on the Plan recordkeeper’s platform; (iii) may select investment products, share classes, or investment products with specially negotiated fee arrangements that may not otherwise be available to a Plan and that may no longer be available if the advisory services agreement with SageView is terminated; (iv) will not provide advice on whether the Plan Sponsor should offer or continue to offer securities issued by the Plan Sponsor or its affiliates as an investment option under the Plan; and (v) is not responsible for selecting brokers, dealers, recordkeepers or other persons through which the investment product transactions are to be effected, handled or processed for the Plan.

The Plan, and not SageView, is responsible for selecting third party service providers, such as a recordkeeper, custodian or plan administrator. At no time will SageView act as custodian of the Plan or have direct access to the Plan’s funds and/or securities. The Plan’s custodian (as selected by the Plan Sponsor) maintains custody of all Plan assets.

3) Integrity Pooled Solutions (PEP)

SageView offers Retirement Plan Asset Management services to certain Adopting Employers (as defined herein) who sponsor defined contribution plans and elect to participate in Integrity Pooled Solutions, a Pooled Employer Plan (“PEP”) offered through Administrative Group, LLC dba Tag Resources (“TAG”) and Transamerica Retirement Solutions, LLC (“TRS,” and together with TAG, “Transamerica”). Integrity Pooled Solutions offers administrative, fiduciary and recordkeeping services to multiple participating employers (each, an “Adopting Employer”). Adopting 6 Employers enter into a written advisory services agreement with SageView, in which SageView is appointed as the discretionary 3(38) investment manager over only the portion of assets in the PEP that are attributable to the Adopting Employer’s employees (or the beneficiaries of such employees). In providing these Retirement Plan Asset Management Services, SageView has full power and authority to select, monitor, remove and replace the investment options to be offered by the Adopting Employer to the participants in the Plan in accordance with the objectives, written guidelines and/or investment objectives set forth in the IPS accepted and adopted by Adopting Employer. The IPS will provide for a single investment lineup for all Adopting Employers for direction by their participants that is intended to reflect the needs and circumstances of the covered workforce as a whole. In performing these services, SageView has discretion to change the investment options within the platform selected by the Adopting Employer and the IPS adopted by the Adopting Employer. SageView will generally select a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. In providing the Retirement Plan Asset Management services described above, we do not place trades or enter orders for securities transactions with respect to the Adopting Employer’s Plan assets or for the execution of any such trade orders. The placing and execution of trades in Plan assets is the sole responsibility of the Plan recordkeeper and/or custodian. SageView may direct the custodian or recordkeeper, as the case may be, to replace an investment option offered under the Plan.

Plan Participant Retirement Services

• 1) Advisor Managed Accounts (“AMA”) - SageView Personalized Portfolios
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• SageView Personalized Portfolios is a service offered to retirement Plans that we service as Plan level investment advisers or managers, which allows plan participants individualized investment advice regarding their Plan investment options. Personalized Portfolios is only made available to Plans that utilize the services of a recordkeeper with whom we work. If the fiduciary of a Plan elects this service, plan participants receive an individualized investment portfolio as a managed account based on the available investment options within the Plan, based upon a number of factors, including the particular participant’s age, retirement timeframe, investment objectives, potential significant life events, risk tolerance and overall financial situation, including assets held outside the Plan. SageView Personalized Portfolios does not provide any investment advisory services for any assets or investments held by the participant outside the Plan. SageView Personalized Portfolios will not include investment advisory services for individual stocks, self-directed brokerage accounts, guaranteed certificate funds, employer-directed monies, or in-plan annuities. 
• Any participants who enroll into SageView Personalized Portfolios must allocate their entire account balance to SageView Personalized Portfolios. Participants are under no obligation to use these services and may cancel their participation in SageView Personalized Portfolios at any time after enrolling.
• SageView’s roles and responsibilities vary depending on which recordkeeper the Plan uses for SageView Personalized Portfolios. The description of the program by recordkeeper is as follows:
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• - Empower Recordkeeping. For Plan Sponsors that have selected Empower as the recordkeeper, SageView creates various model portfolios (hereinafter referred to as the “AMA Model Portfolios”) for a Plan based on the Plan’s investment menu options. These model portfolios include various accumulation and decumulation portfolios and are not created for any particular participant. SageView has appointed Empower Advisory Group (EAG), a registered investment adviser this is not affiliated with SageView, as a sub-adviser to SageView. EAG is responsible for portfolio assignment, rebalancing and overseeing Morningstar Investment Management, LLC (“Morningstar”), the third-party investment adviser providing these services. Morningstar’s proprietary software and technology, “Morningstar Retirement Manager,” functions as an independent financial expert (“IFE”), and processes demographic and financial information about plan participants to identify model portfolios comprised of various asset classes in weights that correspond to various risk profiles selected by the participants. Morningstar will also reallocate participant accounts based on changes in the participant’s data. Participants that utilize Morningstar Retirement Manager may either enroll in the “Managed Account Service,” in which discretionary investment advice is provided, or the “Online Advice” service, in which the participant receives a non-discretionary investment recommendation and ultimately decides whether to adopt the recommended portfolio and to make investment changes.
• When SageView performs the foregoing services, for participants who adopt Managed Account Services, SageView acts as a fiduciary under Section 3(38) of ERISA with respect to the portfolio creation and maintenance of the portfolios it creates. For participants who receive Online Advice, SageView acts as a fiduciary under Section 3(21) of ERISA with respect to the point in time advice given and participants are under no obligation to use the Managed Account Services. Account statements are provided quarterly by Empower to enrolled participants.
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• - Transamerica Recordkeeping. For Plan Sponsors that have selected Transamerica as recordkeeper, SageView acts as a 3(38) co-fiduciary with Transamerica in providing Personalized Portfolios. SageView acts as a 3(38) fiduciary for purposes of construction, development, monitoring and any redesign of the AMA Model Portfolios and Transamerica acts as a 3(38) fiduciary for assigning portfolios to individual participants. Transamerica uses the investment methodology of Morningstar, which functions as the IFE. If the Plan Sponsor enrolls in the “Today’s Advice” service, the participant has the option to receive non-discretionary investment advice, in which SageView acts as a fiduciary under Section 3(21) of ERISA with respect to the point in time advice given. Transamerica has discretionary authority over allocating the participant’s account, without prior participant approval of each transaction. Enrolled assets in the program will be monitored, rebalanced, and reallocated periodically by Transamerica. 
• Participants enrolling into the managed account program and/or interacting with SageView Personalized Portfolios online do so on the Transamerica recordkeeping platform participant website. Enrolled participants receive quarterly recordkeeping statements with account balances, transactions, estimated income in retirement versus goal, and other related information. In addition, participants receive a custom managed accounts report on an annual basis. All documents are distributed by Transamerica.
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• - Other Recordkeepers. For Plan Sponsors that have selected ADP, Charles Schwab, Corebridge, John Hancock, Lincoln, Financial Group, Milliman, Nationwide, OneAmerica, Principal, T. Rowe Price, or Voya as the Plan’s recordkeeper, SageView acts as a 3(38) co-fiduciary with Morningstar. SageView acts as a 3(38) fiduciary for portfolio creation and Morningstar acts as a 3(38) fiduciary for portfolio assignment. Participants enrolling into the managed account program and/or interacting with SageView Personalized Portfolios online do so on the Morningstar participant website. Morningstar has discretionary authority over allocating the participant’s account, without prior participant approval of each transaction. Enrolled assets in the program will be monitored, rebalanced, and reallocated periodically by Morningstar. Enrolled participants receive quarterly progress reports from Morningstar with details on their account from their applicable recordkeeper.
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• 2) PersonalSAGE (Strategic Advice Guidance and Empowerment)
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• PersonalSAGE is a service offered to plan participants in respect of general investment education (as the term “investment education” is defined by the Department of Labor (“DOL”) and applicable regulations and/or guidance, including DOL Interpretive Bulletin 1996-1 (hereafter, “Investment Education”). PersonalSAGE services generally include: (i) transition solutions in which we help plan participants understand the options they have with their retirement Plan assets when they are entering or leaving employment with a Plan Sponsor; (ii) financial coaching; (iii) financial wellness workshops; (iv) group-based education sessions; and (v) access to a website with educational resources and the ability to schedule one-one-one meetings with financial coaches. Specifically, PersonalSAGE coaches meet with participants to collect information necessary to identify the participant’s investment objectives, risk tolerance, time horizon, and retirement-related goals to provide a point-in-time recommendation to assist the participant in creating a portfolio using the Plan’s designated investment alternatives or, as applicable, model portfolios, or managed accounts. SageView does not provide legal or tax advice as part of PersonalSAGE and participants are encouraged to seek the advice of its legal counsel as to matters that might arise relating to the operations and administration of the Plan.
• A limited suite of PersonalSAGE services is also available to Adopting Employers participating in the Integrity Pooled Solutions PEP, which includes participant transition services, financial wellness workshops, a participant website, access to financial coaches and a financial snapshot.
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• 3) Integrity IRA®
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• SageView offers Integrity IRA®, an IRA rollover solution that Plan Sponsors may elect to use, which provides plan participants with an automatic default, lower-risk investment in situations where the Plan has terminated, or the employee has terminated from the Plan and has a plan balance of $7,000 or less (a de minimis “automatic rollover”). In providing this solution, SageView selects the default investment vehicle for the automatic rollover IRA in accordance with applicable safe harbor rules. Eligible plan participants whose accounts are transferred into Integrity IRA® by Plan Sponsors receive information regarding the account from IRA Logix, a third-party administrator, and Matrix Trust Company, an unaffiliated custodian and recordkeeper with which the automatic rollover assets are custodied. Integrity IRA® accountholders may elect to keep their assets in the initial default investment, transfer to another IRA provider, request a distribution, reallocate their assets into other additional fund options selected by SageView, or utilize the services of Morningstar Investment Management to manage the investment allocation. Integrity IRA® is made available only to Plans and not to individual plan participants.
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• Non-Fiduciary Plan Services 
• SageView offers certain non-fiduciary services to Plans on a one-time and ongoing basis (collectively, “NonFiduciary Services”) including the following: (i) strategic planning in which we assist Plan Sponsors in the review of the Plan’s performance and Plan structure by creating periodic reporting; (ii) benchmarking services in which we conduct a periodic review of the Plan’s fees and costs paid to its service providers in order to identify whether such fees and costs are reasonable in light of services received; and (iii) conducting request for proposals (RFPs) to assist the Plan Sponsor in selecting service providers and assisting with the conversion of Plan assets to a new service provider (e.g., recordkeeper). In providing these Non-Fiduciary Services, we do not provide individualized investment advice to the Plan or Plan Sponsor and it is the Plan and Plan Sponsor’s ultimate decision as to whether to make any changes to the Plan structure, documents or service providers.
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• Wealth Management Services 
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• 1) Investment Management 
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• We provide investment management services (“Investment Management”) to individual clients through our wealth management advisors (hereinafter, “Wealth Advisors”), who create individualized investment strategies to meet a client’s specific goals and objectives, subject to a written investment advisory agreement between the client and SageView. We provide these services through our Wealth Advisors. Depending on the terms of the client’s advisory agreement (the “Investment Management Agreement”), a Wealth Advisor will manage the client’s account on either a discretionary or non-discretionary basis. In addition, SageView or its Wealth Advisor will select, appoint and remove any third-party manager and/or allocate and reallocate assets to individual securities or managed strategies in a client’s account without the client’s prior approval or consent. The scope of our discretionary authority does not extend to the withdrawal or transfer of client funds. If a client hires SageView for non-discretionary Investment Management, SageView and the client’s Wealth Advisor do not have the ability to perform the aforementioned without the client’s consent.
• Where the client authorizes SageView to provide discretionary Investment Management services, our Wealth Advisors work with clients to understand each client’s risk tolerance, investment objectives, investment experience and other relevant factors to determine an appropriate asset allocation and portfolio construction to meet that client’s needs. We have the option to allocate a client’s portfolio amongst a mix of mutual funds, stocks, bonds, options, exchange traded funds (“ETFs”), variable annuity (“VA”) sub-accounts, alternative investments and other types of securities, which are based on the client’s investment goals, objectives, and risk tolerance. We can also allocate the account to separately managed accounts (“Separately Managed Accounts”), third-party money managers (“TPMMs”) and/or to SageView’s investment model portfolios constructed by our Portfolio Construction team (“SageView Model Portfolios” or “SageView Models”). SageView Models are centrally managed and may be strategic or dynamic. The strategic SageView Model Portfolios are generally created using 10-year capital market assumptions and maintain a longerterm outlook. These strategies are designed to be more tax-efficient, as they are not adjusted based on short-term market indicators and conditions and typically involve less frequent trading. They are rebalanced and reallocated as needed, but no less than twice a year. Dynamic SageView Models Portfolios are built with the same underlying asset allocation but may be periodically adjusted based on shorter-term (6–12 month) market assumptions to capitalize on opportunities or to mitigate risk.
• SageView Model Portfolios generally consist of individual stocks or bonds, exchange traded funds (“ETFs”), mutual funds, and other public and private securities or investments. Some clients are invested in a custom portfolio, which 9 is an investment account that a Wealth Advisor works with the Investment Management team to manage on behalf of a client, according to that client’s investment objectives and risk tolerance. These portfolios may include investments that are individually selected by the Wealth Advisor and/or include a SageView Model Portfolio. Clients may place reasonable restrictions on the types of investments to be held in their account, provided they are accepted in writing by SageView. The performance of an advisory account with a restriction may be higher or lower than the performance of advisory accounts without restrictions. SageView does not assume responsibility for investment restrictions that are communicated by the client, or a third party (such as the client’s employer), if such restrictions are not accepted by us in writing.
• The amount of compensation we receive from assets invested in SageView Model Portfolios could be higher or lower than the compensation received if we utilize the services of a TPMM. This is because compensation structures vary by product type as well as by TPMM program. This results in a conflict of interest in situations where our Asset-Based Fee (as defined in Item 5) decreases when we use a TPMM, because we have a financial incentive to recommend SageView’s Model Portfolios over another in order to receive greater compensation. There can be other suitable TPMM programs that are more or less costly.
• Pontera Accounts 
• Certain of our clients that do not utilize the services of one of the primary custodians with which we work hire us to provide discretionary management of their employer-sponsored plans, such as 401(k), 403(b) and 457(b) accounts (“Held Away Accounts”). Through a written investment advisory agreement with SageView, Clients grant us access to their Held Away Accounts through Pontera Solutions Inc. (formerly FeeX, Inc.), a non-affiliated order management system (“Pontera”). Clients grant us the authorization with their recordkeeper to purchase, sell, exchange, convert, trade, allocate, reallocate, invest or reinvest assets held in the Held Away Accounts and otherwise make investment decisions for such accounts. These investments are limited by the plan’s menu of investment options and generally include mutual funds, stocks, and exchange traded funds (ETFs), but may also include money market accounts, structured notes, investments with third party managers or private placement funds, if made available by the Client’s retirement plan sponsor. While we can manage and rebalance accounts through Pontera, we cannot initiate a disbursement, change a beneficiary, gain access to any client login credentials, that would trigger custody under Rule 206(4)-2 of the Advisers Act. We are not affiliated with Pontera in any way and receive no compensation from Pontera for use of this platform. Clients on the Pontera platform connect their account(s) electronically directly with Pontera. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the securities made available through their retirement plan. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced.
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• 2) Financial Planning 
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• SageView offers Financial Planning to individuals, families and other clients tailored to the specific client’s needs as an independent service or as part of another service offering based on their relationship with their Wealth Advisor. The scope of the services provided by Wealth Advisors varies and is determined during discussions between the client and the Wealth Advisor. SageView typically makes Financial Planning services available together with Investment Management, but clients may also decide to only engage us for either Financial Planning or Investment Management services. In the case where a client engages us for Financial Planning only, a separate Financial Planning agreement will be executed outlining the included services. Not all clients receive Financial Planning.
• When we provide Financial Planning, we generally focus on the development of a client’s financial plan. Depending on a client’s particular situation, Financial Planning may include some or all of the following: 
• • Assessment and review of goals, financial needs, capacity for risk, retirement timeline, cash flow and/or cash management • Review of the client’s personal and financial circumstances 
• • Analysis of the client's present life activities and anticipated life events to determine impact on the client's financial goals and objectives 
• • Making recommendations to help achieve retirement plan goals and objectives 
• • Designing an investment portfolio to help meet the goals and objectives of the client 
• • Discussing the benefits of estate planning and tax planning 10 
• • Assessing risk and reviewing basic health, life and disability insurance needs; and/or 
• • Reviewing goals and objectives and measuring progress toward these goals
• We will also discuss other aspects as applicable to a client’s specific needs and as agreed to between the Wealth Advisor and the client. As an example, we may recommend that clients begin or revise investment programs, create or revise wills, trusts, and other estate planning documents, obtain or revise insurance coverage, commence or alter retirement savings, establish education or charitable giving programs, and/or begin a college savings plan or financial budget. The client remains solely responsible for determining whether or not to implement the recommendations provided by the Wealth Advisor. In addition to ongoing Financial Planning, we also offer one-time wealth planning services, in which clients receive one-time financial advice regarding one or more selected issues, including but not limited to: 
• • Risk Management/Insurance Planning 
• • Education or other Goal Planning 
• • Charitable Planning 
• • Balance Sheet/Debt Management Planning 
• • Retirement Planning 
• • Estate Modeling 
• • Investment Planning
• Clients who engage us for these services will work with their Advisor to review all relevant objectives, information and agreed upon assumptions, that the Advisor will work from to prepare an analysis related to the scope of work selected by the client. Wealth planning engagements are generally completed within six (6) months of the execution of the written agreement between the client and SageView.
• If our advisory clients receive Financial Planning services, and, pursuant to a plan or consultation, our advisory clients purchase securities or insurance products offered by Cetera, our advisory clients’ Wealth Advisor typically receives commissions as a Registered Representative of Cetera Advisor Networks, LLC (CAN) or Cetera Advisors (CA), or insurance agent of Cetera in connection with such transactions. Thus, in these circumstances the Wealth Advisor will have a conflict of interest when providing these services because the Advisor will likely receive commissions in respect of such purchase. If our advisory clients receive Financial Planning services pursuant to a plan or consultation, and engage in our investment advisory products services, SageView will have a conflict of interest as we will additionally be the ultimate beneficiary of payments from CAN and CA if our advisory clients choose to implement recommendations by retaining a Wealth Advisor to provide other investment products or services. These payments will be used to pay for the commissions of the Wealth Advisors related to their work as Registered Representatives of CAN and CA, certain of SageView’s expenses related to costs affiliated with the work of the Registered Representatives, and a fee for the administration of the relationship.
• Financial Planning clients are not required to implement any recommendations made, implement any financial plan prepared by their Advisor, nor are they required to use the Investment Management or any related services we offer. Clients remains solely responsible for determining whether or not to implement the recommendations provided by the Wealth Advisor. SageView also does not provide any tax preparation, tax advice, legal or accounting services. As such: (i) a client’s personal attorney will be solely responsible for providing legal advice, legal opinions, legal determinations and legal documents and (ii) a client’s personal tax adviser or accountant will be solely responsible for any tax or accounting services provided. Upon request, we may provide clients with names of third-party specialists, with which we have no affiliation.
• We also offer employer sponsored Financial Planning and consultation services. As part of this arrangement, employers pay for all or part of the fees for financial planning services we offer to their eligible employees (such eligibility as determined by the employer). These services are customized by the employer and may include, but are not limited to financial planning meetings, financial plans, and/or annual engagement. Some of our Wealth Advisors have historically provided Financial Planning services to clients through our affiliate, SageView Private Client Group, LLC (PCG), according to the terms and conditions set forth in the written agreement between the client and PCG. However, as of December 2020, all Financial Planning services offered are through the Firm in accordance with the terms and conditions of the Financial Planning Agreement with SageView.
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• Acknowledgement of Fiduciary Duty and Conflict Disclosure for Rollover Recommendations 
• SageView provides discretionary and non-discretionary investment advisory services to individual retirement accounts (“IRAs”) under IRC Section 408 or 408A, tax-qualified retirement plans under IRC Section 401(a), defined contribution retirement plans (such as 401(k) plans), defined benefit retirement plans (such as pension plans) and other employee pension benefit plans subject to ERISA (collectively, “Retirement Accounts”). Where we provide Retirement Plan Investment Advice or Investment Management services as described above to Retirement Accounts, we act as a fiduciary pursuant to Title 1 of ERISA and/or the IRC. The way SageView is compensated for services to Retirement Accounts creates a conflict of interest. In order to mitigate this conflict, we put our client’s interest ahead of our own, and do the following: 
• • Meet a professional standard of care when making investment recommendations that rise to a duty of prudence 
• • Put the client’s interest ahead of our own financial interests when making recommendations that rise to a duty of loyalty 
• • Provide accurate information and avoid misleading statements about conflicts of interest, fees, and investments 
• • Adopt policies and procedures designed to ensure that our Advisors provide advice that is in the best interest of the client 
• • Charge a reasonable fee for the services provided 
• • Provide information about our conflicts of interest and how we address them
• A conflict of interest arises when we make recommendations about retirement plan distributions and rollovers to IRAs, IRA to IRA transfers, IRA to plan rollovers, plan to plan rollovers and change of account types for a retirement plan or IRA (each, a “Rollover Recommendation”) that would result in SageView receiving additional compensation if the recommendation was taken. For example, we receive additional compensation if an accountholder takes our recommendation to move a Retirement Account to SageView for Investment Management services, for which we earn an advisory fee. We manage this conflict through a process designed to develop an informed recommendation in the best interest of the client. In addition to being a conflict of interest, it is also a prohibited transaction under ERISA and/or the Code when we receive compensation as a result of the Rollover Recommendation that we would not have received absent the recommendation. In that circumstance, we will comply with the conditions of exceptions to the prohibited transaction rules (e.g., an applicable prohibited transaction exemption such as PTE 2020-02 or non-enforcement policy). No client is under any obligation to rollover Retirement Accounts to an account advised or managed by us.
• Our material conflicts of interest are described in this Brochure. Retirement Plan Investment Advice, Investment Management, Financial Planning, and other services offered to Plans as described above have in the past, and are expected to in the future, to pose a conflict between the interests of the Firm and the interests of our clients. For example, a recommendation to engage SageView for investment advisory services or to increase the level of investment assets with the Firm, including through rollovers or other transfers of retirement plan accounts or IRAs, would pose a conflict, as it would increase the advisory fees paid to us. 
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• Participation in Wrap Fee Programs 
• We do not offer a wrap fee program.