3(21) Fiduciary Services

Independent investment guidance while you retain decision-making authority.

Not every retirement plan committee wants to delegate investment authority completely. Many plan sponsors want experienced fiduciary guidance while maintaining control over the final decisions that affect their plan.

PointOak Retirement Advisors provides 3(21) fiduciary services for employers seeking independent investment recommendations, committee support, and documented fiduciary guidance. As your 3(21) investment fiduciary, we help your organization make informed decisions while strengthening the governance process behind each recommendation.

  • 3(21) investment fiduciary services
  • Independent, fee-only fiduciary advisor
  • Quarterly investment monitoring
  • Committee and governance support

Benefits of 3(21) Fiduciary Services

Maintain Decision-Making Authority

Unlike a 3(38) arrangement, a 3(21) fiduciary allows your committee to retain final authority over investment decisions while benefiting from independent recommendations and ongoing fiduciary expertise.

Strengthen the Fiduciary Process

ERISA requires plan fiduciaries to act prudently and maintain an appropriate record of their process. A structured review process supported by an experienced 3(21) investment fiduciary can strengthen that process and help document prudent oversight.

Independent Investment Guidance

PointOak operates as a fee-only advisor with no investment-product commissions or proprietary investment lineup. Our recommendations are made within our fiduciary role, with the interests of plan participants and beneficiaries at the center of the analysis.

Ongoing Investment Monitoring

Investment oversight doesn't stop after fund selection. We provide quarterly reviews, watch lists, performance monitoring, and recommendations designed to keep your investment lineup aligned with your Investment Policy Statement.

Stronger Committee Governance

Retirement plan committees benefit from experienced guidance during meetings, investment reviews, benchmarking discussions, and governance decisions throughout the year.

How 3(21) Fiduciary Services Work

A 3(21) investment fiduciary provides investment advice and recommendations under ERISA. We provide documented recommendations regarding investment selection, monitoring, and replacement decisions, while your committee retains final approval authority.

This collaborative approach allows plan sponsors to benefit from institutional investment expertise without giving up control over the retirement plan.

PointOak integrates investment monitoring, provider benchmarking, committee governance, and fiduciary documentation into a repeatable process that supports both regulatory coordination and better participant outcomes.

Who Benefits from 3(21) Fiduciary Services?

A 3(21) fiduciary relationship is often the right fit when your organization wants expert guidance while maintaining oversight of the retirement plan.

Your Committee Wants Independent Investment Expertise

Committee members understand their fiduciary responsibilities but want professional investment recommendations before making decisions.

Your Organization Wants to Retain Investment Authority

Some employers prefer maintaining control over investment decisions while receiving objective guidance from an experienced ERISA fiduciary.

Investment Reviews Have Become More Complex

Monitoring fund performance, documenting decisions, and evaluating replacements requires significant time and expertise. A 3(21) fiduciary provides the analytical support needed for confident decision-making.

You Need Better Fiduciary Documentation

Well-documented committee decisions strengthen your fiduciary process and help demonstrate compliance with ERISA's prudent process requirements.

Your Plan Hasn't Been Reviewed Recently

If investment performance, fees, or plan design haven't been reviewed against current market standards, a 3(21) engagement provides a structured process for evaluation and improvement.

When a 3(21) investment fiduciary may not be the best fit: Organizations that want to delegate day-to-day investment discretion may benefit more from a 3(38) investment manager arrangement, where the investment manager assumes discretionary authority within the delegated scope.

3(21) Fiduciary vs. 3(38) Investment Manager Services

Both fiduciary structures improve retirement plan oversight, but they assign decision-making responsibilities differently.

Many organizations begin with a 3(21) relationship before transitioning to a 3(38) structure as committee responsibilities grow or internal resources change.

What To Expect

AnalyzeRecommendMonitor
  1. 1

    Analyze

    We review your current investment lineup, governance process, committee responsibilities, and Investment Policy Statement.

  2. 2

    Recommend

    You'll receive documented investment recommendations, benchmarking insights, and fiduciary guidance tailored to your retirement plan.

  3. 3

    Monitor

    We provide ongoing quarterly investment reviews, committee support, fiduciary documentation, and recommendations throughout the year.

Why Choose PointOak for 3(21) Fiduciary Services

Effective 3(21) fiduciary support requires more than selecting investments. It requires an ongoing partnership built around prudent governance, documented recommendations, and independent advice.

PointOak brings deep retirement-plan experience to plan sponsors, with founder Darsh Makim, CRPC®, advising retirement plan sponsors since 2005.

Unlike advisors affiliated with investment companies or recordkeepers, we remain independent. Our fee-only structure means our recommendations are not tied to product sales or platform incentives.

About PointOak Retirement Advisors

PointOak Retirement Advisors is an independent, fee-only fiduciary advisory firm providing private wealth management and retirement plan consulting to clients throughout the DC Metro area and nationwide. We offer personalized financial planning and investment management for individuals and families as well as comprehensive retirement plan consulting for businesses.

Frequently Asked Questions

What is a 3(21) fiduciary?

A 3(21) investment fiduciary provides investment advice and recommendations under ERISA while the plan sponsor or committee retains final decision-making authority.

What's the difference between a 3(21) investment fiduciary and a 3(38) investment manager?

A 3(21) investment fiduciary recommends investments, while the committee makes the final decisions. A 3(38) investment manager has discretionary authority within the delegated scope to select, monitor, and replace plan investments.

Does hiring a 3(21) fiduciary eliminate our fiduciary responsibility?

No. A 3(21) relationship shares fiduciary responsibility. Your committee continues making investment decisions and retains responsibility for those decisions.

How often should our investment committee meet?

Most retirement plan committees meet quarterly to review investments, fees, fiduciary documentation, and plan performance. Additional meetings may be appropriate during provider changes or major plan updates.

What services are included in a 3(21) engagement?

Typical services include investment monitoring, fund recommendations, benchmarking, committee support, fiduciary documentation, governance guidance, and ongoing ERISA consulting.

Is PointOak independent?

Yes. PointOak is a fee-only, SEC-registered investment adviser with no proprietary investment products, commissions, or recordkeeper affiliations.

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Keep Control Without Managing It Alone

Work alongside an experienced 3(21) investment fiduciary while your committee retains final authority over investment decisions.