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Form ADV Part 1A Item 2A(7) · Answer type: yn · Item 2 - SEC Registration
Item 2A(7) asks whether the firm is a pension consultant with respect to assets of plans having an aggregate value of at least $200 million and that qualifies for the exemption in rule 203A-2.
A pension consultant provides advisory services to employee benefit plans - retirement plans, pension funds, and similar institutional clients. The firm helps plan sponsors select investment options, evaluate fund performance, design plan structures, and meet fiduciary obligations under ERISA and other regulations.
The $200 million threshold refers to the total value of plan assets for which the firm provides consulting services. This is not the firm's regulatory AUM but rather the combined value of all the pension and benefit plans it advises. A firm might advise ten plans of $20 million each to reach the threshold.
Rule 203A-2 creates a specialized registration path for pension consultants that recognizes their unique role in retirement plan oversight. These consultants often work with plan sponsors rather than individual participants, requiring different regulatory treatment from traditional wealth managers.
Do not confuse 2A(7) with large adviser status in Item 2A(1) or other AUM-based registration paths. Pension consulting involves different asset calculations and regulatory considerations than standard advisory services.
Yes
The firm reports that it qualifies as a pension consultant with at least $200 million in plan assets under Item 2A(7).
No
The firm does not meet the pension consultant criteria - it may qualify under different registration paths or serve other client types.
2A(7) - Are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2 (Yes / No).
This appears in Item 2, SEC Registration, which explains the firm's basis for SEC registration eligibility.
Pension consultant status indicates specialization in retirement plan advisory services and institutional fiduciary responsibilities. These firms typically work with corporate plan sponsors, government entities, and nonprofit organizations to manage employee benefit programs.
The $200 million threshold ensures that only consultants with significant institutional responsibilities qualify for this registration path. Smaller pension consultants may register with states or operate under different regulatory frameworks.
However, pension consultant status does not guarantee expertise in individual retirement planning or superior investment returns. These firms focus on plan governance, vendor selection, and institutional fiduciary matters rather than personal financial planning.
The status also does not reveal specific plan performance, investment strategies, or client industries. Pension consultants may work across different sectors and plan types with varying investment approaches.
Use 2A(7) to understand the firm's institutional focus and retirement plan expertise. This matters for plan sponsors evaluating consultants or individuals whose employers work with the firm on benefit plan design.
Yes
The firm reports pension consultant status under Item 2A(7). On Best Investors, review client types in Item 5D to see pension and profit-sharing plan categories that align with consulting services.
Check services in Item 5G for pension consulting services in Item 5G(6) which should be marked Yes to correspond with this registration basis.
Look at regulatory AUM in Item 5F(2)(c) to understand the firm's overall asset scale, keeping in mind that pension consulting assets and regulatory AUM are calculated differently.
Review other business activities in Item 6A for related services like actuarial consulting, recordkeeping, or benefit administration that complement pension advisory work.
No
The firm does not qualify as a pension consultant under this rule. Check other Item 2A boxes for the actual registration basis. The firm might qualify as a large adviser under 2A(1) or use different specialized categories.
Some firms provide retirement planning services to individuals without meeting the institutional pension consultant thresholds that trigger this checkbox.