Independent Assessment Report
Rogers Wealth Group, Inc.
CEFEX Retirement Plan Service Provider Certification
Service Provider Definitions
Recordkeeping: Bookkeeping for retirement plans’ trading transactions and individuals’ accounts (the major activity in recordkeeping).
Administration: Administrative functions including compliance testing against relevant pension and tax laws and filing
of government reports such as form 5500.
ASPPA: American Society of Pension Professionals and Actuaries.
SECTION 1 – COMPANY INFORMATION |
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| CEFEX File No.: |
CFX10074 |
| Company Name: |
Rogers Wealth Group, Inc. |
| Address: | 1330 Summit Avenue, Fort Worth TX 76102 US |
| Phone: | 817-334-0351 |
SECTION 2 – ASSESSMENT DETAILS |
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| Date of Registration: | 2018.09.30 |
| Assessment Number: | R10 |
| Assessment Team: | |
| Position | Name | Company |
|---|---|---|
| Analyst | Donald K. Denton | Roland Criss Fiduciary Services |
| Reviewer | Kimberly St.Pierre | Setaway, LLC |
CEFEX Registration Committee (CRC)
The CEFEX Registration Committee is responsible for ensuring the consistency, impartiality and technical merit of CEFEX assessments. Members of the CRC include: Blaine F. Aikin, CFP®, CFA, AIFA® founder and principal Fiduciary Insights, J. Richard Lynch, AIFA®, consultant, instructor and subject matter expert for Fi360, David A. Vriesenga, Senior Partner Vriesport Consulting Services, Kimberly St. Pierre, APA, President Setaway, LLC, Matthew Boyle, AIFA® Director of Operations, CEFEX and Carlos Panksep, Vice President, CEFEX.
Attestation
The Lead Analyst is independent of the registered firm. He/she has not been employed or compensated by the registered firm for a period of at least 2 years prior and 6 months following this assessment, for the purposes of providing consulting services for this certification.
The Lead Analyst has the expertise and proficiency to perform this assessment. The Analyst must also hold at least one of the following ASPPA designations: Qualified 401(k) Administrator (QKA), Qualified Pension Consultant (QPA), Certified Pension Consultant (CPC) or Fellow, Society of Pension Actuaries (FSPA).
Purpose and Scope of this Assessment:
To evaluate the firm’s conformance to the practices and associated criteria as defined in the document “Standard of Practice for Retirement Plan Service Providers” (the Standard) for the declared scope of registration.
A full copy of the Standard which is the basis for this assessment, can be found in the Standard here.
The scope of registration is as follows:
Full service recordkeeping through multiple alliances
Summary of Assessment Methodology:
The assessment requires that the Analyst plan and perform a review of a representative sample of the firm’s written records, interviews with appropriate personnel of the firm and, on a test basis, evidence supporting the actions taken by the firm in providing services to its clients. Assessment elements include:
- Document review including organization chart, financial statements, partnership agreements, mission statement, business plan, succession plan, client materials, risk management policy, service agreements, vendor agreements, operational flow charts, policy manuals, Conflict of Interest manual, SOC Type 2 or SSAE16 audit report (if applicable), sales/marketing policy, proof of insurance, and trading procedures.
- Historical review of operations including number of vehicles and staff turnover.
- Review of client types including concentration.
- Review of affiliations and/or alliances with other Service Providers.
- Review of Information Technology including record retention policy, maintenance plan, development plan, disaster recovery plan, and security measures.
- Review of human resource functions including job descriptions, staff credentials and training programs.
- Financial statement analysis, as described in Section 3 below.
SECTION 3 - ASSESSMENT FINDINGS
The following Practices were assessed within the 3 months prior to the Date of Registration shown above and found to be in conformity.
Show All Details Hide All Details
| No. | Practice | Status |
|---|---|---|
| 1.1 | Senior management demonstrates expertise Show Detail Hide Detail | Conformity |
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Detail 1.1.1 The organization has the depth of experienced management to mitigate key man risk. 1.1.2 There is a defined succession plan for senior management to deal with sudden, unexpected disruption. 1.1.3 The recruiting process for senior management includes proper background checks and active involvement by external management. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.2 | Clear authority, mission, ops, resources are coherent. Show Detail Hide Detail | Conformity |
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Detail 1.2.1 There is a well-defined mission statement for the organization as a whole that is communicated to all levels of personnel. 1.2.2 There is a focus and coherence to the organization. 1.2.3 Significant organizational changes are reported to clients on a timely basis. 1.2.4 There is a disciplined performance review process. 1.2.5 The roles and responsibilities of all parties are defined, and documented. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.3 | Organization has capacity to service client base. Show Detail Hide Detail | Conformity |
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Detail 1.3.1 The organization has a suitable distribution and support structure (physical locations and staff) for each type of client. 1.3.2 The organization provides timely and appropriate communications with clients. 1.3.3 The organization monitors and manages the concentration of individual clients and client types. 1.3.4 The organization can demonstrate that it has the capability to process instructions in accordance with its service contracts. 1.3.5 There is a well-developed methodology for providing investment options and/or trading platforms. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.4 | IT has strong infrastructure, staff support and security. Show Detail Hide Detail | Conformity |
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Detail 1.4.1 The organization has a well documented technology plan addressing hardware and software maintenance and development needs. 1.4.2 Back-up procedures and disaster recovery plans are in place. 1.4.3 The organization has up-to-date technology, which is supported by qualified staff. 1.4.4 There are adequate processes and procedures to ensure that client assets and information are protected from theft and embezzlement. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.5 | Developed programs to attract, retain, train and motivate employees. Show Detail Hide Detail | Conformity |
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Detail 1.5.1 Employees demonstrate an understanding of how their individual tasks and objectives fit with the organization’s mission statement. 1.5.2 A formal system is in place to foster open communications from employees at all levels, including questions, comments and complaints. 1.5.3 Well-defined employee training and professional development programs are available. 1.5.4 Compensation and benefit packages are competitive and suitable for attracting qualified employees. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.6 | Effective procedural and operational oversight. Show Detail Hide Detail | Conformity |
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Detail 1.6.1 The organization has defined policies and procedures that are kept current. 1.6.2 There is a regular management review process to ensure that policies and procedures are appropriate. 1.6.3 The organization has an appropriate quality control process. 1.6.4 A formal review system exists to ensure that the organization upgrades its policies and procedures in order to meet regulatory changes as they occur, that affect its business type. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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| 1.7 | Effective risk-management process. Show Detail Hide Detail | Conformity |
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Detail 1.7.1 There is an effective process for evaluating business risk and ensure business continuity. 1.7.2 The organization has adequate and current proof of comprehensive general liability and errors and omissions insurance coverage. 1.7.3 The organization has defined policies and procedures and designated senior staff tasked with the responsibility of overseeing and managing the organization’s conflicts of interest policies. 1.7.4 Service agreements and contracts are in writing, and the terms serve the needs of plan fiduciaries. |
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Substantiation Coming soon. Please see CEFEX Analyst. |
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SECTION 4 - ASSESSMENT CONCLUSIONS AND RECOMMENDATION
Based on the findings obtained during the Assessment, the Company is in substantial conformity to the Standard, and is recommended for CEFEX registration.
This assessment has been reviewed by the CEFEX Registration Committee to maintain impartiality and consistency in the registration process. For details on the complete assessment process, please visit www.fi360.com/cefex.
Note to Report
The information contained in this report is a summary of an assessment conducted by CEFEX, Centre for Fiduciary Excellence and is valid for 1 year from the Date of Registration shown. The report is suitable for public distribution at the discretion of the certified firm. For any questions related to this report, please contact CEFEX at admin@cefex.org. The certification is not a source of legal or investment advice, a financial audit or expression of opinion regarding the completeness or accuracy of financial statements, a compliance or regulatory audit, a guarantee that the firm is in compliance with applicable fiduciary laws or standards, or a guarantee that the firm is adhering to the standard with respect to any specific client.
CEFEX, Centre for Fiduciary Excellence is an independent certification organization, and is part of Broadridge Fi360 Solutions. CEFEX works closely with industry experts to provide comprehensive assessment programs to improve the fiduciary practices of investment stewards, advisors, recordkeepers, administrators and managers.
Broadridge Fi360 Solutions is a fiduciary education, training and technology company, and helps financial intermediaries use prudent fiduciary practices to profitably gather, grow and protect investors’ assets. Since 1999, the firm has provided financial professionals with the tools necessary to act as a fiduciary in their work with investors. Broadridge Fi360 Solutions is also the home of the Accredited Investment Fiduciary® (AIF®) designation, the Fiduciary Focus Toolkit™ and the Fi360 Fiduciary Score®.
