The Value of Professional Fiduciary Services
3(38) investment managers accept discretion for investments; 3(21) advisors provide co‑fiduciary advice without discretion. Both can strengthen governance and documentation.
What Providers Do
3(38) investment managers accept discretion for investments; 3(21) advisors provide co‑fiduciary advice without discretion. Both can strengthen governance and documentation.
When to Delegate
Limited internal resources
Need for documented investment process
Desire to reduce liability exposure
Oversight Still Required
Sponsors retain duty to prudently select and monitor any fiduciary they hire.
Plan Sponsor Action Checklist
Checklist
Define whether you need 3(21) or 3(38) support.
Checklist
Set quarterly review meetings and metrics (fees, performance, service).
Checklist
Maintain minutes and renewals on a set cadence.
Talk to our team
References
- ERISA fiduciary roles (3(21) vs. 3(38)) general guidance.