Human Interest Advisors

It is both. The parent company, Human Interest Inc., builds and operates the retirement plan administration platform. Its wholly owned subsidiary, Human Interest Advisors LLC, is an SEC-registered investment advisor that provides fiduciary advice and discretionary portfolio management to plan sponsors and their employees. This dual structure allows the firm to serve as a 3(38) investment manager on the plans it administers, assuming full fiduciary responsibility for investment selection and monitoring.

Under ERISA Section 3(38), an investment manager assumes full discretionary authority and fiduciary responsibility for selecting, monitoring, and replacing plan investments. When Human Interest acts as a 3(38) on a client's 401(k) plan, the employer sponsor transfers that specific fiduciary liability to Human Interest. This is a more comprehensive standard than the 3(21) advisor role, which only makes recommendations that the plan sponsor must still approve. For small-business owners without in-house retirement expertise, the 3(38) designation makes Human Interest effectively the outsourced investment committee.

Customer acquisition is predominantly through embedded payroll integrations and digital partnerships rather than traditional benefits brokers. The firm's 2023 integration with Gusto exemplifies this model: when a small business sets up payroll on Gusto, 401(k) enrollment is offered natively within the same onboarding flow. Human Interest also maintains direct-sales and channel partnership teams targeting businesses with 5 to 100 employees, a segment that legacy providers typically route to third-party administrators or decline outright due to low asset minimums.

A pooled employer plan (PEP) is a 401(k) structure authorized under the SECURE Act of 2019 that allows multiple unrelated employers to participate in a single retirement plan. Human Interest launched its PEP in 2022, serving as the named fiduciary and plan administrator. The key advantage for participating small businesses is that they share administrative costs, reduce their individual fiduciary liability, and delegate nearly all compliance responsibilities to Human Interest — features that make offering a 401(k) viable for companies with only a handful of employees.

Human Interest constructs its model portfolios from low-cost exchange-traded funds and mutual funds, typically indexed, across a standard glidepath of risk profiles. Participants complete a digital risk assessment during enrollment and are mapped to a corresponding portfolio. For plan sponsors that engage the firm as a 3(38) investment manager, Human Interest has full discretion to select and replace the underlying funds without requiring sponsor approval, which allows the firm to adjust fund lineups in response to fee changes or fund closures.

The direct competitive set includes other digital-first 401(k) providers targeting the micro-business segment: Guideline, Betterment for Business, and Vestwell. Payroll incumbents like ADP and Paychex also offer retirement plans to their small-business payroll clients, though they typically require higher asset minimums and route service through broker-dealer networks. Human Interest's distinction is its combination of a proprietary technology stack, an in-house SEC-registered RIA, and the pooled employer plan structure, which collectively lower the asset threshold at which the firm can profitably serve a new plan.

Under ERISA, a 3(38) investment manager's fiduciary duty runs to the plan and its participants and beneficiaries, not to the employer sponsor. When Human Interest acts in that capacity, its investment decisions must serve the exclusive purpose of providing benefits to participants and defraying reasonable plan expenses. The firm's Form ADV discloses this fiduciary status and the associated conflicts, including its use of proprietary model portfolios and revenue received from the plan recordkeeping relationship.