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The Future of Outsourcing: ERISA Sec. 3(16) Plan Administration Services
David Donaldson, former EBSA Senior Investigator, via TPAresources.com Feb. 16, 2015
"Unlike [ERISA sections] 3(21) and 3(38), where software can be used to scrub investments based on a preset screen that follows an Investment Policy Statement, 3(16) deals with the actual day to day administrative activities of a plan that must follow not only ERISA regulations but must follow the governing plan document that can be unique to each plan.... Unlike a 3(21) and 3(38) who are regulated by FINRA and the SEC, a 3(16) Administrative Fiduciary is not required to be licensed, tested, or regulated. When hiring a 3(16) Administrative Fiduciary, follow these steps. [1] Check Credentials... [2] Reporting & Monitoring... [3] The fees charged should be consistent with industry standards.... [4] A 3(16) administrative fiduciary should be independent of any other services provided to the plan."
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