Manifest is the easiest way to consolidate retirement accounts. Our responsive web application is distributed through employers and accessed by retirement investors as a voluntary benefit.

Manifest is exempted from acting as fiduciary under 5-Part Test from DOL's 1975 ERISA regulations, but we think and act like we are a fiduciary that meets the higher standard of care and requirements.

DOL Fiduciary Rule 3.0 and Manifest's response

Below are six main conditions for an exemption under PTE 2020-02 in DOL Fiduciary Rule 3.0, and how Manifest deals with each:


Manifest's response

1. Admission

We acknowledge our fiduciary status, details of services provided, and any material conflicts of interest in our filings with the SEC/FINRA (Form ADV and Form CRS).

2. Advanced Disclosure

We acknowledge our fiduciary status, details of services provided, and any material conflicts of interest on our website. Participants have a clear knowledge of Manifest's services and conflict of interest by reading Terms of Service and User agreement before signing up for Manifest.

3. Impartial Conduct Standards

Manifest is a unique third-party intermediary that facilities transfer between fiduciaries and Participants. Because Manifest does not manage Participants' accounts or any funds, Manifest will not take on the same category of businesses as fiduciaries. We do not compete with fiduciaries such as T. Rowe Price. Manifest will always be in compliance with the requirements under the impartial conduct standards.

4. Compliant policies and Procedures

Manifest's policies and procedures are updated continuously and in compliance with DOL Fiduciary Rule 3.0's requirements, particularly with the impartial conduct standards, without any conflicts of interest that would place its interest ahead of the Participants' interest. Participants would also have access to policies and procedures on Manifest's platform, public filing documents with the SEC/FINRA, and Manifest's website.

5. Documentation

Any rollover transactions under Manifest are voluntary under the full discretion of Participants. Retirement providers would have the assurance and security that rollover transfers completed through Manifest's platform are done in the best interest of the Participants. By the time each Participant comes to use Manifest's platform, each Participant has already decided to roll over accounts. Hence, we would have the Participants' permission to create rollover documents and make the best recommendation for them.

6. Annual Retroactive Compliance Review

Manifest provides an annual compliance review of its rollover recommendations, policies, and procedures in place for the rollover advice and the process to modify any rollover advice as well as policies and procedures on a periodic and timely basis.

Manifest Business model's implication to providers

Benefits of Manifest's business model:

Manifest helps retirement providers to be more compliant and cost-effective because Manifest offers a platform that meets all of the standards and requirements under DOL Fiduciary Rule 3.0.

With that said, retirement providers can leverage Manifest platform without further duplicative effort to easily comply with DOL's rules on advance disclosures to engage Participants properly.

We would alleviate retirement providers' burden to timely comply with all the requirements while saving retirement providers' time, money and manpower in achieving the compliance standards.

Retirement providers can utilize Manifest to ensure all rollover advice and recommendations are subject to an annual compliance review.


On our Manifest's platform, Manifest uses artificial intelligence called Henry. Henry is designed to learn about Participant's financial situation and preferences via a series of questions. Henry objectively makes rollover proposals to Participants by keeping money in the plan, rolling over to an IRA, rolling over to a managed IRA, or transferring into a new plan. Each Participant also has the choice to refuse Henry's recommendations.

We share clear disclaimers about how Henry can not know the entire situation of a person. We follow FINRA 13-45 and DoL fiduciary guidelines to ensure Henry remains trustworthy for participants.