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In such engagements, the extent to which plan fiduciaries may be shielded from prospective liability is determined by the scope of authority delegated. The most common types of professional outsourced fiduciary engagements fall into one of three categories:

Fiduciary Outsourcing

Roles & Responsibilities Overview

Administrative Oversight

General Services:

  • Plan design consulting
  • Plan document interpretation
  • Fidelity bond procurement & review
  • Compliance testing assistance
  • Form 5500 Processing
  • Audit support (if applicable)

Reporting Services:

  • Summary Plan Description (SPD)
  • Annual QDIA Notice
  • Annual 404(a)(5) Notice
  • Summary Annual Report (SAR)
  • Annual Safe Harbor Notice (if applicable)
  • Annual EACA/QACA notice (if applicable)

Investment Oversight

3(21) Fiduciary Consultant

  • Non-discretionary Investment Consultant
  • Evaluates permissible investment alternatives
  • Recommends suitable investment options
  • Quarterly investment tracking & reporting

3(38) Fiduciary Advisor

  • Discretionary Investment Manager
  • Evaluate permissible investment alternatives
  • Manages plan's investment options
  • Quarterly investment monitoring report

Outsourced Fiduciary Engagements

3(16) Fiduciary Administrator

The designated 3(16) Plan Administrator performs as an appointed fiduciary, who exercises discretionary authority around the routine management of the Plan, in conformance with the applicable Plan Documents.

Outsourced plan management:

  • Distribute mandatory employee notices
  • Manage employee deferral elections
  • Manage beneficiary designations
  • Process loan & distribution requests

Manage plan compliance:

  • Monitor deferral remittance
  • Perform annual non-discrimination testing
  • Prepare & file required annual tax filings

3(21) Fiduciary Advisor

An Investment Consultant is generally deemed to be a co-fiduciary, who performs in a non-discretionary advisory role. An Investment Consultant appointed under section 3(21) of ERISA generally provides information and guidance around investment evaluation and selection to aide the Plan Trustee(s) in making decisions for the Plan.


  • Drafts Investment Policy Statement for approval
  • Provides information on available investment alternatives for review
  • Recommends Investment Options for Trustee approval
  • Monitors the Plan Trustee-designated Investment Options
  • Prepares & delivers quarterly investment monitoring reports

3(38) Fiduciary Manager

The Plan's designated "Investment Manager" performs as an appointed fiduciary, who exercises discretionary authority around the initial evaluation of investment alternatives and selection of the Plan's Investment Options. A Investment Manager appointed under section 3(21) of ERISA generally provides a fiduciary indemnification and is responsible to maintain ERISA Fidelity Bond for every Client-Plan.


  • Installs formal Investment Policy Statement (IPS)
  • Evaluates available investment alternatives
  • Selects & Manages Plan's Investment Options
  • Prepares & delivers quarterly investment management reports
  • Constructs & manages Model Portfolios for Participants