"[W]hether the employer itself retains and directly exercises the discretionary authority to select and retain a service provider or appoints a committee or member of its staff to perform these responsibilities as a designated fiduciary, an accurate understanding of which service providers ... now will be considered fiduciaries and the requirements of the Rule flowing from this status is essential ... to ensure that the Rule and ERISA's other requirements for prudent credentialing, bonding, contracting, compensation [are considered]."

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