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SERVICES

Fiduciary
Responsible for Invesment Lineup
Provided by iQ401k
Third-Party Administrator
Responsible for Administration & Form Filings
Provided by Vanguard/Farmer & Betts
Recordkeeper
Responsible for Managing & Tracking Plan Participant Activities
Provided by Vanguard
Custodian
Responsible for Custodying Plan Assets
Provided by Ascensus

There are four different components to consider when establishing and maintaining a workplace retirement plan:

Fiduciary (ERISA 3(38) or 3(21))
Administrator
Recordkeeper
Custodian

We can act as your Plan’s ERISA 3(38) or ERISA 3(21) Fiduciary.  Under ERISA 3(38) Fiduciary capacity, we will have discretionary authority over the investments of the Plan assets.  This authority may include:

Create and maintain Investment Policy Statement

Create investment lineup

Add, remove, or replace investments

Create asset allocation models

Add, remove, or replace asset allocation models

Make investment recommendations for plan participants

Others Services

In addition to the aforementioned services, we also provide the following services:

Plan designing

Provide annual fee benchmarking reports

Provide educational services for plan participants

Conduct investment committee meetings

Conduct plan participant risk evaluations

Conduct periodic reviews with plan fiduciaries

Provide quarterly monitoring reports

Our involvement under ERISA 3(21) Fiduciary capacity will vary depending on the terms the Plan Sponsor and we have agreed upon.  There are three levels of ERISA 3(21) involvement in a Plan: Limited Scope, Full Scope, and Specific Scope.

ERISA 3(38) vs ERISA 3(21)

A “Limited Scope” fiduciary is where we are hired for a specific purpose.  Responsibilities may include monitoring and replacing recommended investments, and advising on drafting and following an Investment Policy Statement.  Limited Scope is the more common option, and what we currently provide for most Plans.

A “Full Scope” fiduciary is where we effectively take over the role of the ultimate fiduciary in regards to the operation and administration of the Plan as well as the investments of Plan assets.  Responsibilities may include hiring and monitoring other Plan service providers, including Limited Scope fiduciaries.  Full Scope fiduciaries are less common.  If we operate under the Full Scope, additional fees will apply.

“Specific Scope” option falls somewhere between Limited Scope and Full Scope, generally accepting a specific assignment by assuming discretion over a specific aspect of the Plan’s operations.  If we operate under the Specific Scope, additional fees will apply.

 ERISA 3(38)ERISA 3(21)
RoleInvestment ManagerInvestment Advisor
Risk ProtectionHighModerate
Fiduciary ResponsibilitySharedPlan Sponsor
Investment LineupMakes the Actual DecisionsMakes Recommendations
MonitoringYesYes
Research & AnalysisYesYes
Co-Fiduciary MeetingsYesYes

While the ERISA 3(21) fiduciary may share fiduciary status, the Plan Sponsor, through its board of directors and those whom it delegates, retains the ultimate decision-making authority.

Other three components – Recordkeeping, Administrator, and Custodial services can be provided under a “Bundled” or an “Unbundled” package.  Recordkeeping, Administrator, and Custodial services are provided by respective third-parties.  Vanguard Retirement Plan Access™ (VRPA) offers a “Bundled” and an “Unbundled” package.  The Bundled package includes Recordkeeping, Administrator, and Custodial services.  The Unbundled package only offers Recordkeeping and Custodial services.  Under the Unbundled package, Administrator services can be provided by an outside company.  The Unbundled package is the suitable choice for a retirement plan with a Defined Benefit Plan (or Cash Balance Plan).  We currently partner with Farmer & Betts to provide Administrator services for Defined Benefit Plans or Cash Balance Plans.