Cowden Associates, Consultants and Actuaries

Defined Contribution Consulting

Fiduciary Review

As more focus shifts toward defined contribution plans and appropriate investments, what steps must the plan sponsor take to demonstrate compliance? Cowden Associates will walk plan sponsors through a thorough evaluation of their defined contribution plan to ensure that fiduciary practices follow the proper guidelines and that the best outcome is achieved for plan participants. We ask questions like:

  • Do the plan fiduciaries know their respective roles and responsibilities and have they acknowledged their positions in writing?
  • Does an IPS exist? If yes, does the IPS contain all suggested content?
  • What steps does the plan sponsor perform to demonstrate compliance with fiduciary best practices?
  • How are meetings and other reviews documented?
  • Are plan expenses clearly disclosed and understood and are they reasonable when compared to the level of services and general marketing practices?

An Accredited Investment Fiduciary Analyst can provide a thorough, independent review of all fiduciary issues and practices and can prepare a plan for certification through CEFEX.

Sample Fiduciary Issues We Cover

  • Identification of named and deemed fiduciaries and their duties
  • Processes for meeting fiduciary responsibility
    • Appropriate committees
    • Frequency of meetings
  • Investment selection and monitoring
    • Due diligence process
    • Documentation
  • Identification of prohibited transactions and conflicts of interest
  • Service contracts and agreements
  • Documentation of cash flow
    • Contributions
    • Forfeitures
    • Distributions
  • Expense monitoring and control
  • Use of prudent experts
    • Selection – due diligence process
    • Monitoring process