Our Investment lineup consists of two types of investment products:

1. Low-cost mutual funds covering a broad spectrum of asset-classes (“mutual fund lineup”)

2. Risk-based, tactical asset allocation models from professional money managers (“models”)

ERISA 3(38) Fiduciary

One of the largest aspects of fiduciary responsibility is investment selection. Your risk as a plan sponsor can be reduced by sharing this responsibility with an Investment Manager, who will serve as an ERISA 3(38) fiduciary over the plan’s mutual fund lineup. This means that the Investment Manager has discretionary control over the mutual fund lineup only; it does not have discretion on any investment models offered in the plan. A 3(38) fiduciary may only be a bank, an insurance company, or a registered investment adviser (RIA) subject to the Investment Advisers Act of 1940 or applicable state securities regulations.

Delegating 3(38) responsibilities to an Investment Manager limits your legal liability associated with the selection, ongoing monitoring and replacement of the plan’s mutual fund lineup. The Investment Manager will select an initial mutual fund lineup and monitor these funds to ensure they remain in compliance with the Investment Policy Statement. The decision to replace any of the funds within the plan’s mutual fund lineup will reside solely with the Investment Manager.