We provide investment management for retirement plans sponsored by California businesses, such as 401(k) plans. Under a written agreement, we can serve as a 3(21) investment adviser, recommending the plan's investment menu while you make the final decisions, or as a 3(38) investment manager, selecting and monitoring the menu ourselves. Recordkeeping, administration and payroll stay with the providers you hire for them.
Who this is for
California employers that sponsor a 401(k) or similar plan, or are choosing between CalSavers and their own plan, and want an independent adviser for the plan's investments. Owners with a solo 401(k), SEP IRA or SIMPLE IRA too.
How it works
- Review. We look at your current plan or your options, including CalSavers, the state program for employers that do not sponsor a plan. If CalSavers suits your business better, we tell you.
- Choose the role. You decide whether we act as a 3(21) adviser or a 3(38) investment manager, set out in a written agreement.
- The investment menu. We build or review the plan's investment lineup, looking at costs, diversification and how the options fit your employees.
- Monitoring. We monitor the menu at least quarterly, replace or recommend replacing funds when warranted, and meet with you at least annually.
- Employees. We can explain the options to employees in English or Spanish (education, not individualized advice).
3(21) or 3(38)
| 3(21) — co-fiduciary | 3(38) — discretionary | |
|---|---|---|
| Who selects the investments | We recommend, you decide | We decide and monitor |
| Your responsibility | You keep responsibility for the investment decisions you make | You remain responsible for prudently choosing and monitoring us |
| Employer time | More | Less |
| Suits | Owners who want the final say | Owners who want the investment work handled |
Either way you remain the plan sponsor; neither role removes all of an employer's fiduciary responsibility.
2026 limits (educational)
| Plan | Employee contribution | Notes |
|---|---|---|
| 401(k) | $24,500; +$8,000 catch-up at 50+; $11,250 catch-up at 60 to 63 instead | Employer contributions also allowed; total annual additions capped at $72,000 |
| SIMPLE IRA | $17,000 ($18,100 for certain plans); +$4,000 catch-up at 50+ ($5,250 at 60 to 63) | Employer match or nonelective contribution required |
| SEP IRA | Employer contributions only | Up to 25% of compensation or $72,000, whichever is less |
| CalSavers | IRA contribution limit ($7,500 in 2026) | State program; employer does not choose investments |
Sources: IRS Notice 2025-67 (IR-2025-111); IRS SEP contribution limits page. Plan terms may set lower limits.
Tax credits
The IRS startup-costs credit can cover up to $5,000 a year for three years of eligible costs of starting a SEP, SIMPLE IRA or 401(k) for employers with up to 100 employees (100% of eligible costs for 50 or fewer employees; 50% for 51 to 100). Adding automatic enrollment can add $500 a year for three years. Confirm eligibility with your CPA. IRS: startup costs tax credit
What it costs
Our investment-management fee is up to 2.00% of the assets we manage per year, subject to negotiation, generally billed quarterly in arrears and disclosed in writing before we begin. The firm may waive all or part of its fee. Brokerage, transaction, fund and ETF expenses may apply separately. The complete published schedule → For a retirement plan, the fee is based on plan assets under our management. We receive no brokerage commissions and nothing from any recordkeeper, fund company or insurer. Recordkeeper, administrator and fund costs are charged separately by those providers.
What this does not include
- Recordkeeping, administration and Form 5500 filing (the recordkeeper's and administrator's jobs).
- Payroll processing.
- Legal plan documents (an ERISA attorney or the plan provider).
- Guarantees: investing involves risk, including possible loss of principal.
Common questions
Do I have to offer a retirement plan?
In California, employers with one or more employees must either register with CalSavers or offer a qualified plan of their own. What every employer must do →
What is the difference between a 3(21) and a 3(38)?
A 3(21) adviser recommends the investment menu and you make the final decision. A 3(38) investment manager selects and monitors the menu. Either way you remain responsible for choosing and monitoring the adviser.
How are you paid?
Up to 2.00% a year of the plan assets we manage, subject to negotiation, billed quarterly in arrears. There is no separate per-plan or flat fee, and we receive nothing from plan providers.
Who does the recordkeeping and the Form 5500?
The recordkeeper and the third-party administrator. We work alongside them.
Talk about your company's plan.
The first conversation is thirty minutes, in English or Spanish.