Tending the Flock - Index Funds Advisors

Tending the Flock: Shepherding Catholic Retirement Plans
• Sometimes referred to as a “full scope” 3(21) fiduciary
• An investment advisor is not the full scope 3(21) fiduciary unless
the advisor is the Named Fiduciary with authority to hire, monitor,
fire and replace service providers and other fiduciaries
• Plan Administrator - Defined in section 3(16) of ERISA
and should not be confused with a “pension administrator” or a “Third
Party Administrator”
•The Plan Administrator ensures that all filings with the federal
government are made; makes disclosures to plan participants;
hires plan service providers; and fulfills other responsibilities as
set forth in plan documents
• Trustee - Defined in sections 403(a) and 403(b) of ERISA.
The Trustee is a person or group of persons recognized as having
exclusive authority and discretion over the management and control
of plan assets.
•These duties are distinct from those of the Named Fiduciary who
has the duty to control, manage and administer the plan, but the
Named Fiduciary can also serve as the Trustee
• When the Trustee is a separate person, the Trustee is accountable
to and monitored by the Named Fiduciary
•The Named Fiduciary can appoint an ERISA 3(38) Investment
Manager to provide directions to the Trustee
• 3(38) Investment Manager – Defined under ERISA
section 3(38) as a fiduciary with full discretionary powers for selecting,
monitoring and/or replacing the investment options in a qualified plan.
When the 3(38) is appointed by the Named Fiduciary:
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