The team of Reish and Ashton, reviewing the process plan fiduciaries need to follow, the participant disclosure requirements and the implications of participants selecting an RIA to manage their accounts using the window.
Topics covered by the team at Drinker Biddle include:
• Whether offering a brokerage window is a fiduciary decision
• Defining a prudent process
• Participant disclosure requirements
• Considerations in selection and oversight of an RIA
• The effect of a brokerage window on fiduciary liability
Though few participants use brokerage windows, many plans offer them — as detailed by NEPC — so advisors and plan sponsors need to follow a prudent process and clearly understand the obligations of fiduciaries relating to these types of investment alternatives.
