401k Generation

The firm acts as an ERISA 3(21) and 3(38) fiduciary depending on the engagement. Under 3(21), it makes investment recommendations to the plan committee, which retains final discretion. Under 3(38), the firm assumes full investment-manager responsibility, selecting and monitoring the fund lineup directly. This co-fiduciary structure shifts liability away from the plan sponsor for investment decisions.

401k Generation operates as a registered investment adviser (RIA) rather than a broker-dealer. This RIA structure places the firm under a fiduciary standard, requiring it to act in the best interest of plan participants. The distinction matters because broker-dealers often operate under a less stringent suitability standard and may accept revenue-sharing payments that an RIA is less likely to accept.

The firm typically charges an asset-based advisory fee or a per-participant fee, directly invoiced to the plan or deducted from participant accounts. It does not rely on commissions or revenue-sharing from fund managers—a compensation model designed to meet the 'level-fee' safe harbor under ERISA's fiduciary rule.

The firm services qualified defined-contribution plans, including 401(k) profit-sharing plans, 403(b) plans for nonprofits, and cash-balance pension plans. Its client base consists mainly of small and mid-sized plan sponsors who require outsourced fiduciary support.

Yes, alongside plan-level fiduciary services, the firm offers participant-level managed accounts that allocate an individual's retirement savings according to age, risk tolerance, and retirement-time-horizon inputs. This dual structure—plan fiduciary plus participant-level management—is common among specialist retirement-plan advisory firms.