Plan Sponsors and Fiduciaries have a responsibility to ensure the costs associated with their retirement program, directly or indirectly, are reasonable and competitive to the marketplace.  BFSG provides a Plan Cost & Fiduciary Evaluation that will outline the current fee structure and arrangement between the Plan and the retirement plan provider.  The assessment will separate service costs from management costs to provide complete transparency in all Plan-related expenses, as well as, identify any conflicts of interest that may arise from violations of ERISA Section 404(a), 406(a) and 408(b).
This service includes the following:

• Report outlining the current fee structure and arrangement between the Plan and the retirement plan service provider 
• Detailed comparison of overall Plan costs and revenues compared to other similarly sized plans (customized “industry average”)
• Detailed analysis of revenue distribution to provider(s) and all related parties
• Review and analysis of Investment Policy Statement
• Establishment or review of the Committee Charter

All ERISA-covered plans are required to have a plan administrator and a named fiduciary.  The employer usually designates a Benefits or Retirement Plan Committee to serve this function.  A Committee Charter formally delegates fiduciary responsibility from the Board of Directors to the Committee, and establishes the Committee’s authority in fulfilling both fiduciary and settlor functions. BFSG can assist in drafting a Charter, delineating duties of the Committee by designating when acting in the best interest of the plan (non-fiduciary / settlor function) and when acting in the best interest of participants (fiduciary function).

Persons serving as fiduciaries of retirement plans must follow standards defined by governing law to properly perform duties and avoid liability. Governing law may be ERISA, the California Constitution, or the Government Code, depending on the type of retirement plan administered.  BFSG’s services include initial and on-going assistance to help clients maintain compliance with the Uniform Fiduciary Standards of Care.
The Standards of Care are as follows:

1. Know standards, laws, and trust provisions
2. Diversify assets to specific risk/return profile
3. Maintain investment policy statement
4. Use “prudent experts” and money managers – document due diligence
5. Control and account for investment expenses
6. Monitor money managers and service vendors
7. Avoid conflicts of interest and prohibited transactions

Additional Compliance Consulting Services help monitor your Recordkeeping and Administration processes:

• Plan Design Review
• Plan Document Updates
• Summary Plan Description (SPD) Review
• 5500 Assistance
• Plan Audit Assistance
• Discrimination Testing Evaluation
• Payroll / Funding Complexities Assistance
• Qualified Domestic Relations Order (QDRO)

Formalized processes are necessary to accurately monitor, track and evaluate investments.  Our Investment Research Team utilizes sophisticated analytical tools to develop an evaluation methodology and ranking system incorporating qualitative and quantitative analysis.  The outcome is a comprehensive report that helps fiduciaries make sound decisions about their Plan’s investment options.
Our Investment Services include:

• Drafting an Investment Policy Statement (IPS), which incorporates a process and methodology for reviewing and monitoring Plan investment options and annual review to ensure it is meeting the needs of the Client and the Plan participants
• Providing a comprehensive quarterly investment analysis review of all Plan investment options to ensure they are meeting the IPS parameters, as well as provide recommendations on additional options and asset classes to consider 
• Providing a market overview addressing the major markets, indices, sectors and the economic statistics that are affecting them
• Providing an in-depth portfolio summary, including fund and benchmark returns, style analysis and overall portfolio return 
• Analyzing the Plan asset allocation by fund and underlying sector. The fund lineup will also be analyzed to determine the amount of overlap that may be occurring
• Meeting with the Investment Committee, or other designated fiduciaries, to present the quarterly reports and findings, make recommendations and answer questions related to the Plan

Making recommendations of possible alternatives to funds when, in conjunction with the Investment Committee, it is determined a change in fund line-up is necessary.

Fiduciaries are required to periodically benchmark all Plan vendors to the marketplace.  BFSG has developed a 7-Step Search and Selection Process to assist Plan fiduciaries with the process of selecting a new provider or benchmarking their current provider.  We will manage the entire process and prepare a final provider analysis using our own ranking system.
Our process includes:

• Conducting a review of the universe of vendors in the marketplace to determine who will receive the RFP
• Preparing a customized Request for Proposal (RFP) based on Client’s Plan specifics, demographics, and needs. RFP is sent to a minimum of 8 – 10 providers
• Compiling the responses and preparing a summarized presentation incorporating a review of the vendors’ recordkeeping / administration capabilities; investment offerings; and education / communication abilities. The presentation is presented to the Client’s Retirement Plan Committee so that the search may be narrowed to one or two finalists
• Coordination of in-person interviews with each of Client’s chosen finalists.  The interviews take place in the Client’s offices. Your BFSG Consultant will help prepare interview questions, and will develop scorecards to make the decision-making process efficient during the actual interviews (if applicable)
• Facilitating a tour of the finalist’s vendor’s facilities (if applicable)
• Negotiating final details on behalf of client (if applicable)
• Preparing Management Letter to quantify and summarize process findings
• Documentation of entire evaluation process for client’s fiduciary file

Should a new retirement benefits provider be selected, BFSG will work to integrate the necessary components of the Plan Conversion, investment selection, and all other fiduciary and non-fiduciary elements of the retirement benefit plan.  We have proven to be an industry leader in streamlining the conversion process.  The services we provide include:

• Assistance with Plan document review for consistency (and legislative update, as required) from old to new provider
• Consultation on Plan issues / agreements
• Fund mapping strategy including all supporting documentation for mapping selection
• Preparation of notices to participants throughout conversion (including required Sarbanes-Oxley blackout notices)
• Assistance with thorough communications campaign to participants
• Complete project coordination with both new and existing provider to help ensure a smooth transition 

One of the keys to a successful retirement plan is to provide Plan participants with quality employee communication materials and investment education meetings that enable them to make solid investment decisions regarding their retirement assets. BFSG’s education specialists work with clients to develop a thorough enrollment campaign and effective employee communications.
BFSG will review the following:

• Is Employee Education satisfying the needs of employees?
• Does it satisfy the requirements of 404(c)? 
• How is the education program currently monitored and evaluated?

BFSG provides the following services for the Plan and its participants:

• Employee enrollment education meetings, which can be provided in both English and Spanish.
• BFSG’s toll free number for plan participants’ investment questions
• Train-the-trainer sessions for the Client’s HR / Management staff
• Toll free access to BFSG’s Investment Advisor Representatives (available Pacific Time)
• Customized Impact Statements for employees as requested

Newsletters, flyers, seminar handouts, and letters to Plan participants

A retirement plan committee may have the ability (based upon provisions stated in the Plan Document) to remove fiduciary liability in regards to selection and monitoring of the investment options in the Plan.  Designating BFSG as an ERISA §3(38) Investment Manager transfers fiduciary responsibility from the Investment Committee to the Consultant, and changes the role of the Investment Committee to that of an Advisory Committee. The Investment Manager is given sole discretion in managing the plan assets; however, the Advisory Committee may still provide input and guidelines as they see fit.  Under ERISA, the Advisory Committee maintains the responsibility of proper selection and monitoring of the Consultant / Investment Manager. This oversight can be accomplished through proper documentation and a thorough investigation into the consultant’s credentials and experience.  Selection and monitoring is most commonly accomplished via use of the DOL / SEC checklist.  To view BFSG’s responses to the checklist questions, click here.