Review Fiduciary Duties and Responsibilities
Understanding Fiduciary Duties and Responsibilities lays the groundwork for everything about the Plan.
A Plan generally has many Fiduciaries. Some may not relieve themselves of their duties while others can.
KISC’s approach to managing Fiduciary issues revolves around the Fi360 program. Fi360 helps financial intermediaries use prudent fiduciary practices to profitably gather, grow and protect investors’ assets. KISC employees are AIF®, Accredited Investment Fiduciary.
Assess Plan Success against Plan Purpose
The plan was initially installed with a purpose.
- Has it met that purpose?
- Is it accomplishing all that was expected?
- Is it expected to accomplish more or different objectives now?
Are metrics used to measure success?
- Employee turnover
- % Participant participation
- Participant contribution %
- Participant Asset Stability
What else is of concern to the Plan Sponsor?
Review Plan Documents
The Plan Documents are critical.
- Are they up to date?
- Are they being followed?
Review Plan Expenses
Expenses are among the most difficult area to evaluate unless the plan is kept simple. A Fiduciary must consider the prudence of adding complexity with its inherent expense. Stated another way, does the Fiduciary believe Plan complexity benefits the asset growth of the Participant?
Expenses are of many types, and further the lowest expense may not be prudent.
The most basic expenses are Explicit. They are documented and can be verified through a check register or published investor report.
Implicit expenses are difficult, if not nearly impossible to decifer. A hint of an Implicit expense can be seen in disclosures of Revenue Sharing or marketing costs. Organizations go to great lengths to disguise these types of expenses. They are not necessarily illegal, but if not disclosed it may be because they are execssive and the organizations know it.
Assess Plan Risks
Plan risks might be considered another expense. Because if the risks come to bear, the plan, the Plan Sponsor, or a Fiduciary will experience the expense.
Risks might arrise from inappropriate administration, fraud, misrepresentation of the plan or giving inappropriate financial advice.
Being sued by participants for inappropriate expense management may be a significant expense. Research 401(K) LAWSUITS FIGHT HIGH FEES, MISMANAGEMENT LAWSUIT to assess the risk of a disgruntled employee.
Review Investment Menu
Many consultants believe this is one of the most critical Plan considerations. Quarterly they provide pages of reviews. They go into great depth on the status of the national and global economy, the current returns, a management score card, and detailed fund information. Further they capture the EXPLICIT fees by fund. Little effort is expended to understand Implicit fees or the impact on your participants’ asset accumulation.
Producing fancy reports is one of the Smoke and Mirror tactics that does not benefit participants.
Fiduciaries are not responsible for investment return. Participants choose where to invest their assets.
KISC looks at the bigger picture. Through different studies, KISC believes participants are better served with top notch low fee funds that they will contribute to and stay with in their time horizon.
KISC, LLC IARD# 286634 is registered as an investment adviser in Colorado. Such registration does not imply a certain level of skill or training.
Current Form ADV Parts 2A and 2B, which provides information about the qualifications and business practices of KISC, LLC, is available for download under the Documents and Articles tab.