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Fiduciary Fitness Requires Training, or At Least the DOL Thinks So
Benefits Bryan Cave 
Jan. 23, 2013 "While there is no express ERISA requirement that fiduciaries be trained, the DOL seems to take the view that training is evidence of a fiduciary properly exercising his or her duty of prudence.... The first step is deciding who to include. Basically, a fiduciary is (1) anyone with discretionary authority over the management or administration of an ERISA plan, (2) anyone with discretionary authority over the management or disposition of its assets, or (3) anyone who provides investment advice for a fee. (Individuals in category (3) should have their own training already.)" |
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