Alera Retirement Advisors has been in business since January 18, 2011. The Alera Group is the principal
owner of Alera Retirement Advisors.
Alera Retirement Advisors’ investment advisory services are currently limited to the discretionary
management of investment portfolios in accordance with the investment objective(s) of the client. Alera
Retirement Advisors generally does not provide financial planning or other consulting services. To the
extent specifically requested by a client, Alera Retirement Advisors may provide limited consultation
services to its investment management clients on investment and non-investment related matters. Any such
consultation services, to the extent rendered, shall be rendered exclusively on an unsolicited basis.
Investment Management Services
Alera Retirement Advisors can be engaged to manage all or a portion of a client’s assets. Alera Retirement
Advisors intends to primarily allocate its client’s investment management assets, on a discretionary basis
among Independent Managers (as defined below), mutual funds, and exchange traded funds. Alera
Retirement Advisors may also provide advice about any type of investment held in a client’s portfolio.
Alera Retirement Advisors also may render non-discretionary investment management services to clients
relative to: variable life/annuity products that they may own, their individual employer-sponsored retirement
plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing,
Alera Retirement Advisors either directs or recommends the allocation of client assets among the various
investment options that are available with the product. The client assets shall be maintained at the specific
insurance company or custodian designated by the product.
It is Alera Retirement Advisors’ practice to tailor its advisory services to the individual needs of clients. Alera
Retirement Advisors will ensure that each client’s investments are suitable for that client and consistent
with their investment needs, goals, objectives and risk tolerance as well as any restrictions requested by
the client.
Clients shall have the ability to impose reasonable restrictions on the management of their account,
including the ability to instruct Alera Retirement Advisors not to purchase certain securities or types of
securities.
Alera Retirement Advisors’ clients are advised to promptly notify Alera Retirement Advisors if there are ever
any changes in their financial situation or investment objectives or if they wish to impose any reasonable
restrictions upon Alera Retirement Advisors’ management services.
Use of Independent Managers
As mentioned above, Alera Retirement Advisors recommends that certain clients authorize the active
discretionary management of a portion of their assets by and/or among certain independent investment
manager(s) (“Independent Manager(s)”), based upon the stated investment objectives of the client. The
terms and conditions under which the client shall engage the Independent Manager(s) shall be set forth in
separate written agreements between (1) the client and Alera Retirement Advisors and (2) Alera Retirement
Advisors or client and the designated Independent Manager(s). Alera Retirement Advisors shall continue
to render services to the client relative to the discretionary selection of Independent Manager(s) as well as
the monitoring and review of account performance and client investment objectives, for which Alera
Retirement Advisors shall receive an annual advisory fee which is based upon a percentage of the market
value of the assets being managed by the designated Independent Manager(s).
When selecting an Independent Manager for a client, Alera Retirement Advisors shall review information
about the Independent Manager(s) such as its disclosure statement and/or material supplied by the
Independent Manager(s) or independent third parties for a description of the Independent Manager’s
investment strategies, past performance and risk results to the extent available. Factors that Alera
Retirement Advisors shall consider in recommending Independent Manager(s) include the client’s stated
investment objective(s), management style, performance, reputation, financial strength, reporting, pricing,
and research. The investment management fees charged by the designated Independent Manager(s),
together with the fees charged by the wrap fee program sponsor and corresponding designated broker-
dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Alera Retirement Advisors’
investment advisory fee set forth above. As discussed above, the client may incur additional fees than those
charged by Alera Retirement Advisors, the designated Independent Manager(s), wrap fee program sponsor
(if applicable), and corresponding broker-dealer and custodian.
In addition to Alera Retirement Advisors’ written disclosure statement, the client shall also receive the
written disclosure statement of the designated Independent Manager(s) and wrap fee program sponsor (if
applicable). Certain Independent Manager(s) may impose more restrictive account requirements and
varying billing practices than Alera Retirement Advisors. In such instances, Alera Retirement Advisors may
alter its corresponding account requirements and/or billing practices to accommodate those of the
Independent Manager(s) or wrap fee program sponsor.
If Alera Retirement Advisors refers a client to certain Independent Manager(s) where Alera Retirement
Advisors’ compensation is included in the advisory fee charged by such Independent Manager(s) and the
client engages those Independent Manager(s), Alera Retirement Advisors shall be compensated for its
services by receipt of a fee to be paid directly by the Independent Manager(s) to Alera Retirement Advisors
in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended,
and any corresponding state securities laws, rules, regulations, or requirements. Any such fee shall be paid
solely from the Independent Manager(s) investment management fee or the program fee of the wrap fee
program (as appropriate), and shall not result in any additional charge to the client.
Management Through Similarly Managed Accounts
For certain clients, Alera Retirement Advisors may manage client portfolios by allocating portfolio
assets among various securities on a discretionary basis using one or more of its proprietary
investment strategies (collectively referred to as “investment strategy”). In so doing, Alera Retirement
Advisors shall buy, sell, exchange and/or transfer securities based upon the investment strategy.
Alera Retirement Advisors’ management using the investment strategy has been designed to comply with
the requirements of Rule 3a-4 of the Investment Company Act of 1940, as amended. Rule 3a-4 provides
similarly managed accounts, such as the investment strategy, with a safe harbor from the definition of an
investment company. In accordance with Rule 3a-4, the following features have been specifically included
in Alera Retirement Advisors’ management using the investment strategy:
1. Initial Interview – an initial interview is conducted with each client to determine the client’s financial
circumstances, goals, acceptable levels of risk, any reasonable restrictions on the management of
their account, and other relevant circumstances;
2. Individual Treatment – the client’s account is managed on the basis of the client’s financial
circumstances and investment objectives;
3. Consultation – an Advisory Affiliate of Alera Retirement Advisors knowledgeable about the client’s
account shall be reasonably available to consult with the client relative to the status and
management of their account;
4. Notice of Transactions – the client shall receive notice of all transactions in their account as if they
had maintained a similar account outside of the investment strategy;
5. Quarterly Statement – the client shall be provided with a quarterly statement containing a
description of all activity in the their account;
6. Ability to Impose Restrictions – the client shall have the ability to impose reasonable restrictions
on the management of their account, including the ability to instruct Alera Retirement Advisors not
to purchase certain securities or types of securities;
7. No Pooling – the client’s beneficial interest in a security does not represent an undivided interest in
all the securities held by the custodian, but rather represents a direct and beneficial interest in the
securities which comprise the client’s account;
8. Separate Account – a separate account is maintained for the client with the custodian; and
9. Ownership - each client retains indicia of ownership of the account (e.g. right to withdraw securities
or cash, exercise or delegate proxy voting, and receive transaction confirmations).
In addition to the foregoing, clients may, in writing, place reasonable limitations upon Alera Retirement
Advisors’ discretionary authority. The investment strategy may involve an above-average portfolio turnover
that could negatively impact upon the net after-tax gain experienced by an individual client. Securities in
the investment strategy are usually exchanged and/or transferred without regard to a client’s individual tax
ramifications. Certain investment opportunities that become available to Alera Retirement Advisors’ clients
may be limited. For example, various mutual funds may limit the ability of Alera Retirement Advisors to buy,
sell, exchange or transfer securities consistent with its investment strategy. As further discussed in response
to Item 12B (below), in order to meet its fiduciary duties to all of its clients, Alera Retirement Advisors will
endeavor to allocate investment opportunities among its clients on a fair and equitable basis. Participation
in Alera Retirement Advisors’ investment strategy carries additional risk to clients in that a mutual fund or
insurance company may unilaterally restrict and/or prohibit Alera Retirement Advisors’ trading activities thus
prohibiting it from managing the assets consistent with the investment strategy.
Additions and Withdrawals to Accounts
Clients may make additions to and withdrawals from their account at any time, subject to Alera Retirement
Advisors’ right to terminate an account. Clients may withdraw account assets on notice to Alera Retirement
Advisors, subject to the usual and customary securities settlement procedures. However, Alera Retirement
Advisors designs its portfolios as long-term investments and the withdrawal of assets may impair the
achievement of a client’s investment objectives.
Alera Retirement Advisors has $38,959,318 under discretionary asset under management and
$0 under non-discretionary asset under management as of December 2022.
Retirement Plan Advisory Services
ARA provides advisory services to retirement plans (each a “Plan”) pursuant to The Employee Retirement
Income Security Act of 1974 (“ERISA”). Services include both fiduciary and non-fiduciary services to the
sponsor of the Plan (the “Plan Sponsor”) and the participants of the Plan (the “Plan Participants”). Services
will be provided on either a non-discretionary basis (ERISA 3(21) Fiduciary Services) or on a discretionary
basis (ERISA 3(38) Services).
Advisory services are negotiated based on the needs of the Plan and the direction and engagement by the
Plan Sponsor and are included in the terms of a retirement plan advisory agreement.
ARA typically provides the following Plan Fiduciary Services pursuant to the scope and terms of ARA’s
agreement with each Plan Sponsor:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Searches
• Investment Review, Analysis, and Monitoring
• Performance Reporting
• ERISA 404(c) Assistance
• Qualified Default Investment Alternative Designation
• Non-Discretionary Advisory Services (ERISA 3(21) Fiduciary Services)
• Discretionary Advisory Services (ERISA 3(38) Fiduciary Services)
ARA may also provide communication and education services to the Plan and the Plan Participants,
pursuant to the terms of the retirement plan advisory agreement. Services may include:
• Assist with Plan Participant enrollment
• Plan Participant Investment Education
• Periodic on-site visits with Plan Sponsor for account updates and reviews
• Periodic Plan Participant Education Advice (may require separate engagement by the Plan Participant)