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The Many Faces of Fiduciary Outsourcing: ERISA Sections 3(16), 3(21) and 3(38) (PDF)
Russell Investments 
July 20, 2015
"In this article [the authors] review the meaning under ERISA of the terms 'fiduciary' (ERISA 3(21)), 'administrator' (ERISA 3(16)) and 'investment manager' (ERISA 3(38)). [They] then consider, in each case, how those terms are used when discussing outsourcing. Finally, [the authors] briefly discuss the significance of these distinctions for purposes of the outsourcing relationship and contracting."
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