Page 433 - DCAC Feb 2026 Files
P. 433
Summary
• Most defendants created potential liability by failing to execute a prudent process to monitor
investments, services, fess and expenses.
• Conducting periodic recordkeeper RFI/RFPs, investment performance reporting and benchmarking, and
annual share class reviews are all part of the Innovest/DCAC prudent process.
• Another common failure was related to proper documentation. Some defendants claim to have
conducted benchmarking and share class reviews, but could not produce documentation as evidence.
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