Fee-only, by charter — not by marketing.

Our engagement letter specifies either a flat annual retainer or a PEPM (Per-Employee-Per-Month) fee, disclosed in writing before the engagement begins. We do not accept commissions, contingent overrides, performance bonuses, or finder's fees from any carrier, PBM, TPA, or vendor we recommend.

The mathematical consequence is that our revenue cannot rise as your premium rises. The behavioral consequence is that we have no economic incentive to steer you toward a higher-cost product.

ERISA §3(21)(A) defines a fiduciary as anyone who exercises discretionary authority over plan management or compensation, or who renders investment advice for a fee. Plan sponsors carry this duty personally. Traditional brokers do not, because doing so would invalidate their commission income.

Our standard engagement makes us a named §3(21) co-fiduciary. The CFO who signs the plan document is no longer the only signature on the page. Where the engagement requires it, we accept §3(38) investment-manager status with full discretionary authority.

The Consolidated Appropriations Act of 2021 extended ERISA's 408(b)(2) compensation-disclosure rule from retirement plans to group health plans. Every broker is now legally required to disclose direct and indirect compensation in writing to the plan sponsor — and most do so under duress, on the last possible day.

We publish ours at /legal/408b2 for any visitor to inspect, attest to it quarterly, and refresh it any time our compensation arrangement changes. There is no separate "client version" of the disclosure.