Form ADV Part 2A
1645 E 6th Street, Suite 200 Austin, TX 78702 (888) 228-3491 Guideline.com
September 1, 2021
This brochure provides information about the qualifications and business practices of Guideline, Inc. (“Guideline”), an investment adviser registered with the United States Securities and Exchange Commission (the “SEC”), and the successor investment adviser to Guideline Investments, L.L.C. Registration does not imply a certain level of skill or training but only indicates that Guideline has registered our business with the SEC. The information in this brochure has not been approved or verified by the SEC or by any state securities authority.
Additional information about Guideline and our services is available on the SEC’s website at www.adviserinfo.sec.gov and our website at www.guideline.com.
If you have any questions about the contents of this brochure, please contact us at (888) 228-3491 or hello@guideline.com.
This brochure shall serve as an other-than-annual update to our previous brochure dated May 3, 2021. The following is a summary of the material changes made with this brochure update:
- Item 1 has been updated to reflect our current address
- Item 5 has been updated to reflect our current IRA Monthly Base Fee for IRA accounts with more than $10,000 in assets.
401(k), individual retirement account (IRA), and simplified employee pension (SEP) individual retirement account clients are encouraged to review this entire Form ADV Part 2.
Table of Contents
Item 6: Performance-Based Fees
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
A. Broker-Dealer or Broker-Dealer Representative Registration
B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Registration
C. Material Relationships and Possible Conflicts of Interests
D. Material Conflicts of Interest From Other Investment Advisers or Managers
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
C. Investing Personal Money in the Same Securities as Clients
D. Trading Securities at or Around the Same Time as Clients’ Securities
B. Factors That Trigger a Non-Periodic Review of Client Accounts
C. Content and Frequency of Regular Reports Provided to Clients Regarding their Accounts
Item 14: Client Referrals and Other Compensation
B. Compensation to Non-Advisory Personnel for Client Referrals
Item 16: Investment Discretion
Item 17: Voting Client Securities (Proxy Voting)
Item 18: Financial Information
Important Information
Throughout this brochure, Guideline may also be referred to as “our,” “we,” or “us.” Clients or prospective clients may also be referred to as “401(k) plan sponsors” or “401(k) plan participants” or “IRA clients” or “clients.”
This brochure is intended to help you learn more about Guideline’s 401(k), IRA, and SEP IRA services. If you cannot find what you are looking for here, please direct your questions to hello@guideline.com, or visit our website at www.guideline.com.
Guideline is a Delaware corporation formed on June 25, 2015. On February 28, 2019, Guideline became the successor investment adviser to Guideline Investments, L.L.C. when Guideline Investments, L.L.C., a wholly-owned subsidiary of Guideline, was merged with and into Guideline.
401k) Services
Guideline provides plan administration, recordkeeping, and investment management services to employer-sponsored retirement plans. Guideline’s services include selecting, monitoring, and managing our investment menu, qualified default investments, and portfolios for retirement plans.
Guideline also recommends managed portfolios composed of mutual funds to 401(k) plan participants via our proprietary software. Guideline’s economic, investment, and other financial interests are not taken into consideration when making investment decisions.
Guideline also offers a Guideline for Advisors® program and Guideline for Accountants program which allow third-party advisors and accountants to assist with managing the accounts of mutual clients. Guideline does not charge additional fees to, nor does it receive any additional compensation from, third-party advisors, accountants, 401(k) plan sponsors, or 401(k) plan participants for the services provided by Guideline pursuant to the Guideline for Advisors® and Guideline for Accountants programs. The third-party advisor participating in Guideline for Advisors® may charge fees to 401(k) plan sponsors or 401(k) plan participants for their services pursuant to separate agreements between the advisor and the 401(k) plan sponsor.
IRA and SEP IRA Services
Guideline acts as sponsor of IRAs and SEP IRA clients (collectively “IRA”), providing account set-up, limited administration, recordkeeping, and maintenance.
Guideline also provides investment management services to IRAs, including selecting, monitoring, and managing our investment menu and portfolios for the accounts. We also recommend managed portfolios composed of mutual funds to IRA clients via our proprietary software. Guideline’s economic, investment, and other financial interests are not taken into consideration when making investment decisions.
401(k) Plans
Guideline offers three tiers of 401(k) plan services to employers: Core, Flex, and Max. 401(k) plan sponsors may elect to change tiers once during any calendar year.
Also included with our services are automated investment advice to 401(k) plan participants via our proprietary software. Pursuant to section 404(c) of the Employee Retirement Income Security Act of 1974, as amended, Guideline provides a selection of diversified investments representing a range of risk/return characteristics. 401(k) plan participants can choose to invest in one of our managed portfolios - recommended based on the 401(k) plan participant’s reported risk tolerance and estimated time until retirement - or create a custom portfolio from our investment menu. If a 401(k) plan participant does not provide investment instructions, their funds are automatically invested into one of our managed portfolios based on the participant’s age and estimated time until retirement.
Guideline’s account opening process is designed to provide clients an opportunity to select from a variety of investment options, including selecting a model or creating a custom portfolio. In doing this, 401(k) plan participants have flexibility to choose any combination of the index funds offered by Guideline, and they can change their chosen portfolio at any point.
IRA and SEP IRA Plans
Guideline offers three types of IRAs:
- Traditional IRA - an individual retirement account which allows clients to direct pre-tax income towards investments that can grow tax deferred.
- Roth IRA - an individual retirement account that accrues gains tax-exempt using after-tax money to invest.
- SEP IRA an individual retirement account which allows business owners to contribute SEP contributions towards traditional IRAs for their employees or self-employed owners.
IRA clients are able to modify their portfolio, create a custom portfolio, make annual contributions, and distribute funds from their IRA.
Our service also includes automated investment advice to IRA clients via our proprietary software. Guideline provides a selection of diversified investments representing a range of risk/return characteristics. IRA clients can choose to either invest in one of our managed portfolios - recommended by our proprietary system based on the owner’s reported risk tolerance and estimated time until retirement - or they can create a custom portfolio from our investment menu.
Guideline’s account opening process is designed to provide clients an opportunity to select from a variety of investment options, including selecting a model or creating a custom portfolio. In doing this, IRA clients have flexibility to choose any combination of the index funds offered by Guideline, and they can change their chosen portfolio at any point.
In a wrap fee investment program, the investor pays one stated fee to cover management fees, transaction costs, fund expenses, and other administrative fees. Guideline does not participate in any such wrap fee program.
As of December 31, 2020, Guideline managed $2,468,168,065 in assets under management on a discretionary basis, and $977,335,330 in assets under management on a non-discretionary basis.
401(k) Plan Sponsors
Guideline charges plan administration and service fees directly to the 401(k) plan sponsor as set forth below. Guideline can waive any of the below fees and offer discounts at our discretion.
| Type of Service | Fee |
|---|---|
| Monthly Participant Fees | $8 per active employee |
| Monthly Base Fee | $49-$129 |
Extraordinary Services Fee: $300/hour ($300 minimum). Guideline reserves the right to assess a fee for services requested by clients that are beyond the scope of agreed-upon services between Guideline and the client.
Additional information about plan pricing is available at www.guideline.com/pricing.
Guideline furnishes a detailed schedule of fees to 401(k) plan sponsors upon entering into a contract for services. Monthly fees are negotiable for larger employers. Our fees may be modified from time to time with not less than thirty (30) days written notice.
401(k) Plan Participants
Guideline charges 401(k) plan participants as set forth below.
Guideline can waive any of the below fees and offer discounts at our discretion.
| Type of Service | Fee |
|---|---|
| Annual Account Fee* | 0.08% |
| Terminated 401(k) Plan Participant Monthly Base Fee | $4 |
*Calculated and deducted on a monthly basis at 1/12 of the annual stated rate (0.08%) based on the account balance on the last day of each month.
401(k) plan participant fees are non-negotiable. Guideline furnishes a detailed schedule of fees which may be charged to 401(k) plan participants in a fee disclosure statement upon enrollment and on an annual basis. Our fees may be modified from time to time with not less than thirty (30) days written notice.
IRA and SEP IRA Plans
Guideline charges fees directly to the IRA owners as set forth below. Guideline can waive any of the below fees and offer discounts at our discretion.
| Type of Service | Fee |
|---|---|
| IRA Monthly Base Fee (accounts with $10,000 or less in assets* | $2/month |
| IRA Monthly Base Fee (accounts with more than $10,000 in assets)* | $4/month |
| SEP IRA Monthly Base Fee (all accounts) | $8/month |
| Annual Account Fee** | 0.08% |
*For purposes of determining the IRA monthly base fee, account assets are determined based on the average daily balance of the account over the billable month.
**Calculated and deducted on a monthly basis at 1/12 of the annual stated rate (0.08%) based on the account balance on the last day of each month.
Guideline provides a schedule of fees charged to IRA clients upon enrollment for services. Fees are non-negotiable and may be modified during the term of the agreement with thirty (30) days’ advance written notice to the IRA client.
Guideline monthly base fees will be itemized in a monthly invoice and delivered electronically to 401(k) plan sponsors and IRA clients following the end of the month in which services were provided. The total amount of each invoice will be automatically debited from the 401(k) plan sponsor or IRA clients’ Funding Source (as defined in Guideline’s terms of service for each service) approximately five (5) days after the invoice is issued. 401(k) plan participant fees are deducted from the 401(k) plan participant’s account balance. In the event that an error is reported after fees have been debited, resulting in overpayment, Guideline may refund the excess payment in the form of a credit on the following month’s invoice.
Guideline’s annual account fee is deducted from the 401(k) plan participant’s account balance on a monthly basis and from the IRA client’s account balance or via ACH from their designated bank account on a monthly basis. In the event that an error is reported after the annual account fee has been debited, resulting in overpayment, Guideline may credit such overpayment back to the client’s Guideline account balance.
Guideline does not charge our clients third-party fees.
Guideline requires our clients to use Benefit Trust Company as their custodian. Custodian fees are paid by Guideline; clients do not pay custodian fees. However, should Guideline for any reason fail to pay the custodial fees, the 401(k) plan sponsor agrees to pay Benefit Trust Company for services rendered by it based on the fee schedule in the Custodian Agreement. BTC may withdraw such compensation directly from 401(k) plan assets.
BTC will collect 10% of any invoicing, collecting, and reporting on sub-transfer agency, shareholder servicing, and service fees received from mutual fund company transfer agents that Benefit Trust Company has entered into contractual agreement with. These revenue sharing expenses are billed monthly at 1/12th of the annual stated rate based on month-end net assets.
401(k) plan participants and IRA clients are responsible for the payment of third-party mutual fund fees, which are charged directly from 401(k) plan participant and IRA client assets by the mutual funds in which the 401(k) plan participant or IRA client invests.
Under the Guideline for Advisors(R) program, Guideline provides billing services to certain third-party advisors for our 401(k) plans. Guideline does not charge additional fees to, nor does it receive any additional compensation from, third-party advisors, 401(k) plan sponsors, or 401(k) plan participants for these services. The Guideline for Advisors(R) program is not currently available to our IRA clients.
Large 401(k) plans (defined as a plan with 100+ employees) are subject to large plan audits, and 401(k) plan sponsors are responsible for the costs associated with the audit. These costs are not charged by Guideline but rather the independent, third-party auditor the 401(k) plan sponsor chooses to engage with.
Guideline does not accept prepayment of fees.
Neither Guideline nor our firm personnel receive compensation for the sale of securities or other investment products. There is one mutual fund utilized by Guideline in our investment menu that charges 12b-1 fees on investments made, however neither Guideline nor our firm personnel receive these 12b-1 fees. In the limited instances where investments are made into this particular mutual fund, please be advised of the following:
- The practice of recommending mutual fund share classes that charge 12b-1 fees presents a conflict of interest if Guideline or our firm personnel receive such fees as it would give Guideline an incentive to recommend investment products based on the compensation received, rather than on a client’s needs. Guideline generally only offers “no-load” mutual fund share classes when possible, and only utilizes this particular mutual fund that charges a 12b-1 fee as a small portion of its investment menu. This particular mutual fund is available in an institutional share class that does not charge a 12b-1 fee, however the institutional share class requires a minimum investment amount that we do not qualify for.
- Clients have the option to purchase investment products that Guideline recommends through other brokers or agents that are not affiliated with Guideline.
- The investments made into this particular mutual fund are minimal and the 12b-1 fees earned from this particular mutual fund are paid to the fund’s distributor, whether that is a third party or an affiliate of the fund itself.
- These 12b-1 fees are not offset or rebated in any way.
Neither Guideline nor our firm personnel accept performance-based fees on a share of capital gains on, or capital appreciation of, the assets of 401(k) plan participants or IRA clients.
Guideline’s 401(k) clients are employers who offer employer-sponsored retirement plans to their employees.
Guideline’s clients for our IRA services are individuals who participated in an employer-sponsored Guideline 401(k) and who desire to transfer their 401(k) account to invest in Traditional and Roth IRAs through Guideline. Guideline’s clients for our SEP IRA services are business owners who may be self-employed or the employees of small businesses who wish to invest SEP contributions through Guideline.
There are four principles that form the basis of Guideline’s investment philosophy and guide us through our duties and responsibilities as an investment manager:
- Make saving for retirement simple and more accessible
- Minimize investment fees
- Diversify broadly for better risk-adjusted returns
- Create long-term investment strategies for retirement investors
Guideline subscribes to the concept that investors can maximize their expected returns for a given level of risk through a portfolio of diversified assets (or minimize their risk subject to a given level of expected return). Guideline believes participants should have access to a range of low-fee investments with different risk, covariance, and return characteristics, allowing for the construction of diversified portfolios. Guideline believes that minimizing fees, mitigating risk through diversification, and investing for a long-term horizon are the underpinnings to successfully prepare for retirement.
Guideline’s investment strategy assumes that investors are risk averse and will only take on increased risk if compensated with higher expected returns. Investors who want higher returns will need to accept greater risk. Different investors will evaluate the trade-off differently based on their own individual risk profile. When choosing between portfolios, the implication is that rational investors will invest in portfolios with the most favorable risk-to-expected-return profiles and corresponding to their level of comfort with risk.
“Long-term investing” is designed to capture market rates of both return and risk. Investing in the capital markets can expose investors to various types of risk that will typically surface at different intervals. These risks include, but are not limited to, market risk, political and regulatory risk, interest rate risk, credit risk, and inflation (purchasing power) risk.
Investors should be aware that there is a material risk of loss using any investment strategy. Our mutual fund investments are not guaranteed or insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. Investing in mutual funds carries the risk of capital loss. All mutual funds have costs that lower investment returns. Primary asset classes of the funds represented in Guideline portfolios include stocks (“equities”), bonds (“fixed income”), and cash equivalents, which present a lower risk.
Guideline has no criminal or civil actions to report.
Guideline has no administrative proceedings to report.
Guideline has no self-regulatory organization proceedings to report.
Neither Guideline nor our firm personnel are registered as, or have pending applications to register as, a broker-dealer or a representative of a broker-dealer.
Neither Guideline nor our firm personnel are registered as, or have pending applications to register as, either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an associated person of the foregoing entities.
Neither Guideline nor its representatives have any conflicts of interest to disclose.
Guideline does not recommend or select other investment advisers for clients.
Guideline has a written Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers of 1940, as amended (the “Advisers Act”) that covers areas such as insider trading, personal securities transactions, conflicts of interest, gifts and entertainment, service on a board of directors, recordkeeping, and violations reporting.
We periodically review and amend our Code of Ethics so that the policies and procedures remain current, and we require firm personnel to annually attest to their understanding and adherence to the Code of Ethics provisions. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request at no charge.
Guideline does not recommend that clients buy or sell any security in which a related person to Guideline or Guideline has a material financial interest.
Guideline’s representatives may buy or sell mutual funds for themselves that Guideline also recommends to our clients. Though this may provide an opportunity for our representatives to buy or sell the same securities before or after Guideline recommends the same securities to 401(k) plan participants or IRA clients, Guideline does not believe any such transaction could potentially create a conflict of interest because all advice is generated through our proprietary system.
From time to time, Guideline’s representatives may buy or sell securities for themselves at or around the same time as clients. Though this may provide an opportunity for our representatives to buy or sell securities before or after Guideline recommends securities to 401(k) plan participants or IRA clients, our representatives do not profit off of the recommendations they provide to 401(k) plan participants or IRA clients. Guideline does not believe such transactions could potentially create a conflict of interest because all advice is generated through our proprietary system.
Guideline requires our clients to use Benefit Trust Company as their custodian.
Guideline does not maintain relationships with any broker-dealers. In the event that we do so, Guideline is committed to negotiating reasonable fees for our clients, which includes selecting only commission-free, low expense ratio mutual funds that trade at NAV at the end of a given day.
Guideline conducts our own investment research. Currently, Guideline does not have a soft dollar program or any plans to implement one.
Guideline does not receive referrals from a broker-dealer and/or third party in exchange for use of that broker-dealer and/or third party’s services.
Guideline does not allow clients to execute transactions through a specified broker-dealer.
Guideline maintains the ability to block trade across accounts. While block trading may benefit clients by purchasing or selling larger blocks in groups, we do not feel that clients are at a disadvantage because mutual funds invested in receive the same NAV.
Guideline reviews our managed investment portfolios on a regular basis to ensure portfolio characteristics and investment performance adhere to the defined portfolio goals. Guideline reviews the funds in our investment menu on a regular basis, evaluating the funds’ performance, fees, and representations of the underlying assets.
Non-periodic reviews may be triggered by material market, economic, or political events, or by changes in 401(k) plan participants’ or IRA clients’ financial situations, such as retirement, termination of employment, or disability.
Guideline provides 401(k) plan participants and IRA clients with a monthly report detailing their account, including: assets held, asset value, and calculation of fees. 401(k) plan participants and IRA clients may also view their account balance and transactions from their online dashboard, updated daily.
Guideline does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to Guideline’s clients.
From time to time, Guideline enters into written arrangements with third parties to act as solicitors for our 401(k) services. Guideline integrates our services with third-party payroll providers, benefits providers, and other service providers. Under these arrangements, Guideline agrees to compensate the third-party provider.
As a result of these compensatory arrangements, (i) Guideline does not charge any additional fees to the 401(k) plan sponsor or any 401(k) plan participant, (ii) third-party fees are not paid from 401(k) plan funds, (iii) these third parties do not provide any fiduciary or administrative services to the 401(k) plan or 401(k) plan participants regarding the 401(k) plan, and (iv) neither the 401(k) plan sponsor nor 401(k) plan participants are responsible for any fees paid to these third parties. Compensatory relationships with third parties will be fully disclosed to each client to the extent required by applicable law. All such referral activities will be conducted in accordance with the Advisers Act Rule 206(4)-3, as applicable.
Guideline has custody of client funds and securities because we are authorized or permitted to withdraw client funds or securities maintained at our custodian (Benefit Trust Company) upon our instruction to the custodian. Guideline does not act as a “qualified custodian” but is subject to the SEC’s Custody Rule. Guideline is therefore obligated to comply with the following requirements as imposed by the Custody Rule:
- Use of “qualified custodians” to hold client assets. Guideline maintains client funds and securities with a “qualified custodian” that maintains the client’s funds and securities in a separate account under the client’s name.
- Client Notification. Guideline has notified the clients whose funds and securities we have custody over in writing of the qualified custodian’s name, address, and the manner in which the funds or securities are maintained.
- Account statements for clients detailing their holdings. Clients will receive statements on at least a quarterly basis directly from the qualified custodian(s) that holds and maintains their investment assets. Clients are urged to carefully review all custodial statements and compare them to any reports provided by Guideline.
- Annual surprise exams. Guideline has entered into a written agreement with an independent public accountant to examine the assets of which it is deemed to have custody on a surprise basis every year.
Guideline exercises discretionary trading authority with regard to funds invested in our managed portfolios. This enables Guideline to buy, sell, and specify the number of securities in a 401(k) plan participant and IRA client’s account without first obtaining the 401(k) plan participant or IRA client’s specific consent. This authority is limited to the transfer or exchange of 401(k) plan participant or IRA client funds between asset classes within mutual fund families and/or other securities to achieve results consistent with the goals of the 401(k) plan participant or IRA client’s selected investment portfolio. This discretion does not extend to 401(k) plan participants or IRA clients who have created a custom portfolio.
Proxy voting is carried out by the mutual fund manager for each security the fund holds. 401(k) plan participants and IRA clients should direct all proxy questions to the mutual fund manager. Should a fund require proxy votes for its own management, Guideline will assume voting authority for 401(k) plan participants and IRA clients in accordance with our proxy voting policies. 401(k) plan participants and IRA clients may request a copy of our Proxy Voting Policy by contacting us at support@guideline.com.
Guideline is not required to include a balance sheet with this brochure because we neither require nor solicit prepayment of more than $1,200 in fees per client.
Neither Guideline nor our management have any financial condition that is likely to reasonably impair Guideline’s ability to meet contractual commitments to clients.
Guideline has not been the subject of a bankruptcy petition at any time during the last ten years.
Updated: September 1, 2021
Guideline, Inc. is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”). Brokerage and investment advisory services and fees differ, and it is important for you to understand these differences. There are free and simple tools available to research firms and financial professionals at www.investor.gov/CRS, which also provides educational materials about investment advisers, broker-dealers, and investing.
We offer our investment advisory services to retail investors. Where selected, we provide investment management services to Individual Retirement Accounts (IRAs), Simplified Employee Pension (SEP) IRAs, and 401(k) plans, including selecting, monitoring, and managing the investment menu and portfolios for your account. We also recommend managed portfolios composed of mutual funds via our proprietary software. We review our managed investment portfolios on a regular basis to ensure that portfolio characteristics adhere to the portfolio’s stated goals. We also act as the sponsor of IRAs, SEP IRA clients, and 401(k) plans, providing account set-up, administration, recordkeeping, certain tax reporting, and maintenance.
You can choose to invest in one of our managed portfolios comprised of mutual funds and recommended by our proprietary software based on your reported risk tolerance and estimated time of retirement (“discretionary account”), or you may choose to create a custom portfolio from our menu of mutual funds (“nondiscretionary account”). The type of account is determined and authorized by you in your account contract, which will remain in place until you make applicable investment changes, or we terminate the relationship.
Additional information about our advisory services is located in Item 4 of our Brochure which is available online at www.adviserinfo.sec.gov by searching CRD #281515.
For IRA accounts, you will be charged a recurring monthly base fee based upon the average daily balance of your account assets. The monthly base fee is $2 a month for accounts with $10,000 or less in assets or $4 a month for accounts with more than $10,000 in assets. For SEP IRA accounts, you will be charged a recurring monthly base fee of $8. We charge IRA and SEP IRA clients an annual account fee of 0.08% on assets under management based on their account balance on the last day of the month. Fees are non-negotiable.
For 401(k) accounts, we charge a plan administration and service fee directly to the 401(k) plan sponsor, which includes a monthly participant fee of $8 per active employee and a monthly base fee which ranges from $49-$129. These fees are negotiable for larger employers. We charge 401k plan participants an annual account fee of 0.08% on assets under management based on their account balance on the last day of the month. 401(k) plan participants who have terminated employment with the plan sponsor are charged an additional monthly base fee of $4 per month after an initial 90-day grace period following termination of employment, or after the end of the blackout period if the retirement plan was recently transferred to Guideline from another 401(k) provider. 401(k) plan participant fees are non-negotiable. 401(k) plan participants may have a third-party advisor’s fee deducted from their account if the 401(k) plan sponsor engages a third-party advisor to assist with administering the plan.
Guideline provides a detailed schedule of fees at the time of enrollment. Fees are subject to change at any time with thirty (30) day notice. Lastly, the mutual funds within your portfolio charge fees to you which will reduce the value of your investments over time. Information on these fees can be found in each fund’s prospectus, made available upon request.
You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.
Additional information about our fees is located in Item 5 of our Brochure, which is available online at www.adviserinfo.sec.gov by searching CRD #281515, and on our website at https://www.guideline.com.
When we act as your investment adviser, we have to act in your best interest and not put our interests ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they affect the investment advice we provide you.
Here is an example to help you understand what this means:
Additional information about our conflicts of interest can be found in our Brochure under Items 10, 11, and 14, which is available online at www.adviserinfo.sec.gov by searching CRD #281515.
Our financial professionals are employees of the firm and are paid a fixed monthly salary. They do not receive or accept compensation for the sale of securities or other investment products. Employees also receive compensation in the form of equity grant options in Guideline, Inc. Sales team members receive incentive compensation based on the number of participants in a plan and/or the number of plans brought to Guideline.
No, our firm and/or financial professionals do not have any legal and disciplinary history. Visit www.investor.gov/CRS for a free and simple search tool to research our firm and our financial professionals.
You can find additional information about our firm’s investment advisory services on the SEC’s website at www.adviserinfo.sec.gov by searching CRD# 281515. You may also contact our firm at (888) 228-3491 and talk to any one of our investment professionals or support staff.
1645 E 6th Street, Suite 200, Austin, TX 78702
(888) 228-3491 - legal@guideline.com