An article published last week by Employee Benefit News titled, “Which type of fiduciary should plan sponsors hire?” compares the differing responsibilities of 3(16), 3(21), and 3(38) fiduciary providers. In short, the roles broke down as follows:
- 3(16) – Plan administrator (full scope fiduciary has discretion over plan policies and procedures)
- 3(21) – Investment advisor (no discretion over plan assets)
- 3(38) – Financial advisor (full discretion over plan assets)
While this article helped to distinguish between the three roles, we thought a deeper dive into each of those providers’ responsibilities would be helpful. So, here are a few links of our own related content addressing this very conundrum – what is the real difference between these fiduciary providers, and how do plan sponsors determine which vendor will provide them with the services they need most?
- Understanding the Difference Between ERISA 3(21), 3(38), and 3(16) Vendors
- Do You Know Your Fiduciary Job Description? The Three Fiduciary Roles
- The Right Way to Construct a TPA/3(16) Service Provider Model
- 3(16) Fiduciary: New Flavor, or Simply a Matured Palate?
- Talking Points About the 3(16) Role: Key Facts You Want to Know
- The Gold Standard
Still have questions? Email us at admin@rolandcriss.com. We’ll aim to get back to you just as quickly as possible – because we know how complex the fiduciary question can be, and we’re here to help.
For more information, you may also visit our website, at www.rolandcriss.com.
