3(21) Fiduciary Advisory Support

Shared fiduciary investment oversight and governance guidance for retirement plan sponsors.

Headquartered in Richmond, Virginia, we serve clients nationwide. 

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When Your Committee Retains Investment Authority

Under ERISA, a 3(21) fiduciary advisor provides investment recommendations while the plan sponsor retains final decision-making authority.


For many organizations, this structure committee involvement while maintaining professional guidance for investment monitoring, fund selection, and fiduciary documentation.


As part of our broader plan sponsors framework, we help plan sponsors strengthen governance processes, clarify fiduciary responsibilities, and support disciplined investment oversight.


A 3(21) structure preserves committee authority while introducing structured advisory guidance.

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What a 3(21) Fiduciary Structure Means

Under a 3(21) arrangement:


  • The advisor provides investment recommendations and analysis
  • The retirement plan committee retains final authority over decisions
  • Fiduciary responsibility for those decisions remains with the plan sponsor


This model is often appropriate for organizations with experienced committees that prefer to maintain control over investment decisions while benefiting from professional advisory support.


For organizations seeking full delegation of investment authority, a 3(38) fiduciary structure may be considered.

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How 3(21) Advisory Strengthens Governance

A 3(21) structure does not reduce the need for fiduciary discipline. In fact, maintaining decision authority requires clear documentation, structured monitoring, and consistent governance practices.


Our role is to support retirement plan committees by providing disciplined analysis, documented recommendations, and governance support aligned with ERISA standards.


This approach allows committees to remain actively involved while strengthening fiduciary processes and decision documentation.

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3(21) Fiduciary Advisory Services We Provide

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Investment Recommendations

We provide formal recommendations for fund selection, replacement decisions, and lineup adjustments based on performance analysis and fiduciary standards.
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Investment Monitoring and Performance Analysis

We evaluate investment performance relative to benchmarks, peer groups, and IPS criteria to identify funds requiring committee review.
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Fee Benchmarking and Cost Review

We assess investment and administrative costs to ensure fee structures remain reasonable and aligned with fiduciary obligations.
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Investment Policy Statement Alignment

We help establish and maintain IPS documentation defining monitoring standards, evaluation criteria, and decision protocols.
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Committee Reporting and Documentation Support

We provide structured reporting materials and guidance that support documented committee decision-making.

Our 3(21) Advisory Process

Strong advisory support follows defined structure.

  • Step 1: Assess

    We evaluate your current fiduciary framework, investment lineup, governance practices, and committee oversight processes.

  • Step 2: Recommend

    We provide documented investment recommendations and analysis aligned with your Investment Policy Statement and fiduciary standards.

  • Step 3: Decide

    Your committee reviews recommendations and retains authority for final investment decisions.

  • Step 4: Monitor

    We continue ongoing performance monitoring, reporting support, and governance alignment.

This model preserves committee authority while strengthening fiduciary discipline.

Is a 3(21) Structure Right for Your Organization?

If your committee prefers to maintain investment authority while receiving structured fiduciary guidance, a 3(21) advisory model may be appropriate.



We work with retirement plan sponsors to evaluate whether shared fiduciary responsibility aligns with their governance capacity, internal expertise, and long-term oversight objectives.