3(16) Fiduciary Services Market Update

Watch FuturePlan’s experts as they give an update on 3(16) Fiduciary Services, what they’re hearing and seeing in the market and how FuturePlan can help support you in delivering value to your clients.
  • Jessica Marson, Vice President, 3(16) Practice Leader
  • Aaron McIsaac, Divisional Vice President of Sales
Differentiating 3(16) from 3(21) and 3(38) Fiduciaries:

An ERISA Section 3(16) Plan Administrator is responsible for the delivery and approval of administrative tasks associated with operating the plan.

An ERISA Section 3(21) Investment Advisor shares responsibility with the Plan Sponsor for the plan investments. They recommend the selection and replacement of plan investment options. The Plan Sponsor must also approve the changes.

An ERISA Section 3(38) Investment Manager assumes full responsibility for the investment selection, monitoring and replacement of plan investment options. Their responsibilities are lifted from the Plan Sponsor.

Named Vs. Delegated Fiduciaries:

The 402(a) Named Fiduciary is designated in the plan document, outranks all other fiduciaries, and has complete control over all aspects of the plan, including selection of service providers and reasonableness of compensation.

A Delegated Fiduciary enters into written Fiduciary contract with the Plan Sponsor and “opts in” to defined administrative duties allowing the Plan Sponsor to maintain control over most aspects of the plan.

Here are 4 ways that you can deliver value to your clients:
  1. Identify Clients with Historical Compliance Issues
    1. Engaged VCP & DFVCP, EPCRS
    2. DOL and IRS Audits
    3. Self-Correction
  2. Identify Clients with Capacity Challenges
    1. Business owner operates the plan
    2. Business lacks HR support or has imbalance of resources
  3. Identify Clients Subject to Annual Audit
    1. Large Plan Filers with >120 Eligible Participants
    2. Multiple Employer Plans
  4. Identify Clients with Service Provider Limitations
    1. Multiple Systems/Platforms
    2. Administrative Fulfillment Solutions
    3. 3(16) Accommodators


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