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Understanding Fiduciary Responsibilities
Who is a Fiduciary?
• Anyone who has discretionary control over management/administration of the plan, exercises control
over plan assets, or renders investment advice for compensation
• Fiduciary status is based less on any named role and more on actual functions performed for the plan.
• Every plan must have at least one named fiduciary, identified by office or by actual name. Most plans
have more than one.
• Fiduciaries typically include:
– Plan Sponsors (the employer)
– Trustees
– Investment Advisors
– Individuals exercising discretion in plan administration
– All members of a plan’s administrative/investment committee
• Plan recordkeepers, auditors, and accountants are usually not fiduciaries, since their roles are ministerial
in nature.
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