DOL Greenlights Diverse Asset Manager Program for ERISA Plans

Thompson Hine LLP

The Department of Labor has issued a groundbreaking opinion letter confirming that Citibank’s conduct in voluntarily establishing a diverse asset manager program under which Citibank agrees to pay some or all of a diverse investment manager’s fees in connection with its ERISA plans is settlor, rather than fiduciary, in nature.

For those plan sponsors who wish to have investment managers for their ERISA plans included in overall corporate DEI initiatives, the opinion provides an alternative that does not require the plan fiduciaries to consider those DEI initiatives as relevant to the risk and return analysis when considering an investment or investment course of action in order to do so. At the same time, whether to establish a program similar to that described in the opinion is voluntary – the opinion creates no requirements, mandates, or negative implications for plan sponsors who do not wish to do so.

During this webinar, you will hear directly from the individuals who worked with Citibank and the Department of Labor to obtain this opinion letter. This webinar will allow for a Q&A session immediately following the presentation.

Presenters:

• Dominic DeMatties, Partner, Thompson Hine LLP
• Brian L. Gaj, Senior Counsel, Thompson Hine LLP

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