Administrator vs. Named Fiduciary under ERISA

[Guest pension222]

ERISA defines the term "administrator" in section 3(16)(A).

ERISA defines the term "named fiduciary" in section 402(a)(2).

I assume that everytime the term "plan administrator" appears in the law or the code that this means the ERISA 3(16)(A) administrator.

Every legal document I have ever seen separately defines who is the plan administrator and who is the named fiduciary.

What is the difference between these two? It seems to me that the administrator would be a fiduciary and from reading about the duties of the named fiduciary, it appears that the named fiduciary might be the plan administrator.

[QDROphile]

Plans may have many fiduciaries, whether or not they are named and whether or not they know they are fiduciaries. If one does fiduciary things, one is a fiduciary.

Named fiduciaries are simply fiduciaries who are expressly identified as a fiduciary, usually for specified purposes. The purpose may be general, such as plan administration, or limited, such as naming participants as plan fiduciaries solely for purposes of tendering company stock in their accounts.

It is difficult to imagine a plan administrator that is not a plan fiduciary.

[Jon Chambers]

A plan must have at least one "named fiduciary". This is usually the plan administrator, although occasionally it is the trustee (generally where the trustee has investment discretion). Some plan service providers will attempt to gain a strategic advantage by agreeing to act as the "named fiduciary". Naive sponsors think this mitigates their liability. I disagree with this conclusion, since the plan sponsor hires the plan service provider, and consequently has control over the "named fiduciary".