Human Investing responded to 10 questions from the SEC regarding potential conflicts of interest. They stated that they are a registered investment advisor with the SEC and do not receive any payments from money managers. They also do not allow clients to pay consulting fees through brokerage commissions and have policies to prevent conflicts of interest from influencing advice. Human Investing acknowledged having fiduciary obligations to clients and said they would act as a 3(21) or 3(38) ERISA fiduciary depending on client preference.

1. Our Response to SEC Questions:
The Department of Labor and the Securities and Exchange Commission have recommended that all
plan fiduciaries ask their pension consultants the following 10 questions:
1. Are you registered with the SEC or a state securities regulator as an investment adviser? If
so, have you provided me with all the disclosures required under those laws (including Part II
of Form ADV)?
Yes, we are a Registered Investment Advisor with the SEC and have provided all clients with
all required disclosures. Our Form ADV, including Part I and II are also located on our
website at www.humaninvesting.com
2. Do you or a related company have relationships with money managers that you recommend,
consider for recommendation, or otherwise mention to the plan for our consideration? If so,
describe those relationships?
No. We do not have any relationships with money managers, whether we recommend them
or not. Our only form of revenue comes from our clients directly in the form of transparent
cash-based fees.
3. Do you or a related company receive any payments from money managers you recommend,
consider for recommendation, or otherwise mention to the plan for our consideration? If so,
what is the extent of these payments in relation to your other income (revenue)?
No
4. Do you have any policies or procedures to address conflicts of interest or to prevent these
payments or relationships from being considered when you provide advice to your clients?
Yes, by not accepting any form of revenue from any source other than our client directly. We
also do not permit any money manager or other service provider to sponsor and fund
conferences or other client meetings/seminars that we may hold for clients. We do not
permit any employees to receive gifts, dinners or any similar transfers from money managers
nor assume travel expenses for our firm.
5. If you allow plans to pay your consulting fees using the plan’s brokerage commissions, do you
monitor the amount of commissions paid and alert plans when consulting fees have been
paid in full? If not, how can a plan make sure it does not over-pay its consulting fees?
We do not allow plans to pay any portion of our consulting fees using brokerage
commissions. 100% of our revenue is generated from cash-based fees from our clients
directly.

2. 6. If you allow plans to pay your consulting fees using the plan’s brokerage commissions, what
steps do you take to ensure that the plan receives best execution for its securities trades?
We do not allow plans to pay our consulting fees using brokerage commissions.
7. Do you have any arrangements with broker-dealers under which you or a related company
will benefit if money managers place trades for their clients with such broker-dealers?
No, we have no such arrangements with any broker-dealer.
8. If you are hired, will you acknowledge in writing that you have a fiduciary obligation as an
investment adviser to the plan while providing the consulting services we are seeking?
Yes. Human Investing will acknowledge in writing that we have a fiduciary obligation as a
Registered Investment Advisor to the plan while providing consulting services.
9. Are you a fiduciary under section 3(21) or 3(38) of ERISA with respect to the
recommendations you provide the plan?
Yes. We act as a fiduciary under ERISA either as a section 3(21)a or 3(38) fiduciary,
depending on the client’s preference.
10. What percentage of your plan clients utilize money managers, investment funds, brokerage
services or other service providers from whom you receive fees?
0%
Source - http://www.sec.gov/investor/pubs/sponsortips.htm