ERISA 3(21) & 3(38) Investment Advisors/Managers

Multnomah Group White Paper
July 2017

Authors:
Brian Montanez, CPC, TGPC, AIF®, CPFA 
Principal

Erik Daley, CFA
Managing Principal

Bonnie Treichel, J.D.
Senior Consultant & Chief Compliance Officer


With the Department of Labor’s new definition of investment advice, we are frequently asked about the difference between an ERISA 3(21) and a 3(38) investment fiduciary.

While we are glad to hear more and more plan sponsors are interested in prudent investment management, we are concerned about the basic lack of understanding between these important distinctions.  Frequently, these conversations start with a basic discussion of what is an investment fiduciary.

In this white paper, we take an in-depth look at both 3(21) and 3(38) investment advisors and how to choose which one best suits your company’s needs.

To read the full white paper, please use the submission box in the right-hand column.

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