Page 53 - DCAC December 2024 Files

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 Not Fiduciaries

• Plan Sponsor • Recordkeeper

• Committee / Board • Plan Auditor

Members • Outside Counsel

• Investment Consultant

• Trustee

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