3 pages. Excerpt: Generally, the members of a defined contribution plan's governing board or committee ('plan board'), particularly when they are determining the plan's investment array, default investment, etc., are plan fiduciaries, while 'plan sponsor' activities in establishing, amending and terminating a plan do not involve fiduciary duties. The issue of whether the staff who are involved in the day to day operation of the plan and/or who provide administrative support to the plan board are plan fiduciaries is less clear cut.

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