In a practical sense there is no better motto than "do what you say and say what you do" when it comes to the fiduciary aspects of a qualified plan. We take this exact approach towards our fiduciary duties as well as the fiduciary obligations of our clients.

We are aided in this pursuit by our fee-only, conflict-free approach. For example, when retained to find a fund that meets the specific criteria outlined by a plan's investment policy statement we can do just that using internal research and avoiding entanglements caused by selling agreements, approved fund lists or the need to produce commissions.

In our view the word fiduciary is often invoked by those who actually do something other than what they say or have some other self-serving need that must be satisfied. In that environment "fiduciary" is used to inspire fear and the vendor selling that approach promises (in our view over-promises) to shield the plan sponsor from this threat.

To be clear, in our view we are a fiduciary for every action we take. We strive at all times to be prudent, reasonable and impartial. We endeavor to create a paper trail for our clients that illustrates that they do indeed "do what they say" even as the various documents to the plan say what they do.

The vast majority of our clients choose to have the final word on the investments selected for their respective plan. They also choose to make the final choice as to the recordkeeping vendor. We can not absolve the client of their fiduciary duties if they choose to have the final word on the decisions that have a direct impact on their plan (if a client chooses to turn all responsibility for selection and oversight of plan-related decisions over to us then, yes, we can take sole responsibility).

What we can provide is the research, analysis, screening and oversight to bring our clients to the handful of options that best fit their stated needs. Our work extends to all documents related to the plan (investment policy statements, resolutions, summary plan descriptions, enrollment kits, vendor contracts, etc.), insurance coverage, and, of course, investments.

As a way to start the discussion, please click on the following link for further information from the Department of Labor.