
ERISA Fiduciary Services
Four Components Of A Workplace Retirement Plan
Investment Fiduciary |
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Responsible for Investment Selection |
Provided by FPLCM |
Third-Party Administrator |
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Responsible for Plan Administration & Form Filings |
Provided by Farmer & Betts (or TPA of your choice) |
Recordkeeper |
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Responsible for Managing & Tracking Plan Participant Activities |
Provided by Vanguard |
Custodian |
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Responsible for Custodying Plan Assets |
Provided by Ascensus |
FPLCM, can act as your Plan’s ERISA 3(38) or ERISA 3(21) Investment Fiduciary. When operating under ERISA 3(38) Investment Manager Fiduciary capacity, we will have discretionary authority over the investment selection for the Plan. This includes:
- Create and maintain Investment Policy Statement
- Design and maintain investment selection
- Design and maintain asset allocation models
- Provide investment advice to plan participants
ERISA 3(38) vs ERISA 3(21)
- An ERISA 3(21) Fiduciary’s responsibility is to provide investment advice, and the final decision regarding the investment selection is the Plan Sponsor’s responsibility.
- An ERISA 3(21) Fiduciary is a good option for Plan Sponsors who are okay with sharing fiduciary responsibilities.
- An ERISA 3(21) Fiduciary will typically draft an Investment Policy Statement. Based on the IPS, investment advisor will monitor investments and recommend changes if needed.
ERISA 3(38) | ERISA 3(21) | |
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Role | Investment Manager | Investment Advisor |
Risk Protection | High | Moderate |
Fiduciary Responsibility | Advisor | Plan Sponsor |
Investment Lineup | Advisor Makes Investment Decisions | Plan Sponsor Makes Investment Decisions |
Monitoring | Yes | Yes |
Research & Analysis | Yes | Yes |
Co-Fiduciary Meetings | Yes | Yes |
Recordkeeping services will be provided Vanguard Retirement Plan Access™ (VRPA). VRPA is one of the industry leaders in Recordkeeping for qualified retirement plans. Unlike most other Recordkeeper platforms, VRPA uses a flat participant fee model without any assets under management fees.
Third-Party Administrator services will be provided by Farmer & Betts. They currently support over 2,500 qualified retirement plans throughout the nation. However, plans do have the option of selecting their own TPA.
Custodial services will be provided by Ascensus, one of the largest custodians in the nation with over $748 billion in assets and winner of multiple Best-in-Class awards over the last several years.