I am the PLAN SPONSOR – Does the new investment advisory rule mean I should do something?
You already know you are a fiduciary, but the issuance of the new investment advice fiduciary rule is a good occasion to revisit your duties and take some “best practices” actions.
1. Act solely in the interest of plan participants and their beneficiaries, with the exclusive purpose of providing benefits to them;
2. Carry out all fiduciary duties prudently – follow a process and document that process;
3. Follow the plan documents (unless they are not consistent with ERISA, in which case, you’ll want to reach out to your trusted employee benefits advisor);
4. Diversify plan investments;
5. Pay only reasonable plan expenses; and
6. Hire plan advisors prudently, and continuously (and reasonably) monitor their performance.