Vestwell Client Investments Policies

Thank you for choosing to partner with Vestwell to support your business. We look forward to working with you. Properly operating a workplace retirement plan requires careful coordination with various service providers and other third parties. This policy document explains how Vestwell supports your role as the investment manager or investment advisor to the plan. You will also find information on how to send your investment selections to Vestwell, along with how to make any changes if needed. This document is meant to be read together with the Division of Responsibilities. 

  1. Investment Programs - Vestwell’s platform architecture allows your firm to have easy and seamless control of the investment options that are made available to the Plan. A Plan’s Investment Program is the full menu of available investment options: Fund Lineup, Risk and Goal Models, and Target Date Series.

    • Any Investment Program that you create (and any future adjustments you make to that Program) will be applied to all Plans that you have selected to use that Investment Program.

    • If you wish to create unique Investment Programs for individual Plans to allow flexibility, please let our Investments Team know so they can work with you to create these Programs.

      • Please note that advisors must finalize their investment lineups at the beginning of the onboarding process. Your firm will receive confirmation of your Investment Program selection. It is your responsibility to inform us when or if any changes to the investment options are necessary or appropriate. As mentioned in our Division of Responsibilities, when your firm acts as an investment fiduciary, Vestwell does not perform or undertake any fiduciary responsibilities with respect to the selection of the Plan’s investments and we do not perform any monitoring, benchmarking, or other similar activities.
  2. Revenue Sharing - Vestwell does not allow CUSIPS with 12b-1 fees. If a fund has a “clean” share class (i.e., a share class that does not have any indirect compensation, 12b-1 fees, sub-TA fees, commissions, “soft dollar” fees, or any other form of revenue sharing), that class must be used. If you are requesting an exception to that rule, we must complete an internal review and approval process. That will potentially require additional time needed to onboard the Plan and we may not be able to meet the Plan Sponsor’s desired onboarding date.  
  3. Fact Sheets/ Fund Prospectus - Plan participants can access fund fact sheets and prospectuses on their Vestwell portal on the Investments Holdings and Investment Comparison pages. For Plans where Vestwell Advisors is not serving as the investment manager, your firm is responsible for providing fact sheets for custom risk models. Those fact sheets must be delivered to and we will upload them to participants’ portals.
  4. Form ADV - Where Vestwell Advisors is not serving as the investment manager, you must provide us with your firm’s Form ADV. The Vestwell team will upload these documents to the Plan participants’ portals.
  5. CITs/ Stable Value Funds - The Vestwell platform can support a variety of CITs and stable value funds, including: 
    • Reliance Metlife Stable Value Fund 25053
    • John Hancock Stable Value Fund (for Hancock advisors only) 
    • The Standard Stable Asset Fund
    • Morley Stable Value Fund
    • Putnam Stable Value
    • flexPATH Stable Value* note that this approval process falls under Wilmington CIT approval
      • Please note that these fund providers often require the Plan Sponsor to sign a participation agreement or similar agreement in order to enable our custodian to trade these funds.  That process is controlled completely by the fund provider, and our custodian requires the signed agreement well before the first pay date. The failure by the Plan Sponsor to promptly sign those agreements may result in the fund being removed from the Plan or delays in onboarding.  Please encourage the Plan Sponsor to review and sign all Plan documents and agreements as soon as possible. .  

  6. Lineup Changes - As the investment fiduciary to the Plan, it is your responsibility to make any changes to the investment lineup that you consider appropriate for the Plan. Vestwell does not have and will not perform any role or responsibility in that regard. In order for Vestwell to efficiently review your investment changes, you must provide those changes to us in Good Order, which means: the selections are provided to us in our required format; we confirm that your selected funds are open and available to our custodian for trading on the Vestwell platform and, if any of the new funds require either a waiver, participation agreement, or any other prior approval from the fund provider, those materials must be completed, signed by the Plan Sponsor and provided to Vestwell.  Investment lineup changes require coordination of these activities and, for that reason,  Vestwell supports model allocation updates on a quarterly basis or 60 days after the last reallocation. 
    • If your firm is serving as an ERISA section 3(21) investment advisor, you must receive prior written consent from the Plan Sponsor(s) and provide that approval to Vestwell before any lineup changes can be made. 
    • Fund Additions/Removals take approximately 45-60 business days for these changes, as long as you provide the lineup to us in our required format and we are able to complete all of the coordination activities mentioned above. Material changes to investment selections require providing participants with 30 days advance notice of the change, which is included in that timeline. 
    • Model Allocation Changes take approximately 10 business days, as long as the lineup is provided to us in our required format and all of the other coordination activities mentioned above are completed on time. Additionally, all funds must currently be in the lineup.