3(38) Investment Manager Services
Delegate investment responsibility while strengthening your fiduciary process.
Managing a retirement plan investment lineup requires ongoing monitoring, documented decision-making, and timely action when investments no longer meet expectations. For many plan sponsors, maintaining that level of oversight has become increasingly complex.
PointOak Retirement Advisors provides independent 3(38) investment manager services, serving as the discretionary investment manager within the scope delegated by the plan fiduciary. We select, monitor, and replace plan investments within that scope, while the appointing fiduciary remains responsible for prudently selecting and monitoring the investment manager.
- 3(38) investment manager services
- Fee-only, SEC-registered investment adviser
- Discretionary investment management
- Quarterly monitoring and documented oversight
Benefits of 3(38) Investment Manager Services
Delegate Day-to-Day Investment Decisions
A 3(38) investment manager has discretionary authority within the delegated scope over the investment lineup, allowing designated investment changes to be made without waiting for committee approval.
Reduce Committee Workload
Investment research, performance monitoring, fund replacements, and documentation become our responsibility, allowing your committee to focus on strategic oversight rather than day-to-day investment management.
Strengthen Your Fiduciary Process
ERISA requires plan fiduciaries to prudently select and monitor investments. A documented investment management process helps demonstrate ongoing oversight and supports a stronger governance framework.
Independent Investment Management
PointOak is independent and does not receive investment-product commissions. Investment recommendations and decisions are made within the fiduciary scope of the engagement.
Continuous Investment Monitoring
Markets evolve, investment managers change, and fund performance shifts over time. We continuously monitor your investment lineup and make changes when appropriate to keep your plan aligned with its Investment Policy Statement.
How 3(38) Investment Manager Services Work
Under ERISA Section 3(38), PointOak becomes the plan's discretionary investment manager. After establishing an agreed-upon Investment Policy Statement, we assume responsibility for selecting, monitoring, and replacing investments within the plan.
Rather than bringing every investment change back to the committee for approval, we make decisions as conditions warrant while maintaining complete documentation of our process and keeping your committee informed.
Investment oversight is ongoing, with decisions and follow-up documented as part of the delegated investment-management process.
Who Benefits from 3(38) Investment Manager Services?
A 3(38) investment manager relationship may be appropriate for organizations that want to delegate designated investment decisions while maintaining oversight of the investment manager and the broader fiduciary process.
Your Committee Doesn't Want Day-to-Day Investment Responsibility
Many retirement committees prefer focusing on governance rather than researching funds, monitoring managers, and approving investment changes every quarter.
Investment Decisions Are Delayed
If your committee only meets quarterly, designated investment changes may otherwise wait for scheduled approval. A 3(38) investment manager can act within its delegated authority as conditions change.
Your Plan Has Become More Complex
As retirement plans grow, investment oversight requires greater expertise, documentation, and monitoring. Outsourcing investment discretion allows your committee to keep pace with that complexity.
Your Organization Wants Greater Fiduciary Documentation
Delegating investment discretion to a qualified 3(38) investment manager can shift responsibility for designated day-to-day investment decisions to the manager, while the appointing fiduciary remains responsible for prudently selecting and monitoring that manager.
You Need Ongoing Investment Oversight
Monitoring investment managers, reviewing performance, replacing underperforming funds, and documenting every decision requires continuous attention that many internal teams simply don't have time to provide.
When a 3(38) investment manager may not be the right fit: Organizations that prefer making every investment decision internally may be better served by a 3(21) investment fiduciary relationship, where the committee retains final authority while receiving independent guidance.
3(38) vs. 3(21) Fiduciary Services
Both fiduciary arrangements strengthen retirement plan governance, but they differ in who makes investment decisions.
Choosing between the two depends on your committee's experience, available time, and preferred level of involvement.
What To Expect
AnalyzeImplementMonitor- 1
Analyze
We review your current investment lineup, Investment Policy Statement, governance process, and committee objectives.
- 2
Implement
Once engaged as your 3(38) investment manager, we assume discretionary responsibility for selecting, monitoring, and replacing plan investments.
- 3
Monitor
Your investment lineup receives ongoing oversight through quarterly reviews, documented monitoring, performance analysis, and timely investment changes when appropriate.
Why Choose PointOak for 3(38) Investment Manager Services
Delegating investment discretion requires trust. That's why PointOak combines independent investment management with a transparent, well-documented fiduciary process.
PointOak brings deep retirement-plan experience to plan sponsors, with founder Darsh Makim, CRPC®, advising retirement plan sponsors since 2005.
PointOak is fee-only and independent of proprietary investment requirements. Investment decisions are made within the fiduciary responsibilities and scope of the engagement.
Our investment management process also integrates with broader retirement plan services including investment analysis, provider and fee benchmarking, committee governance, and fiduciary documentation, giving plan sponsors coordinated support beyond investment management alone.
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(38) investment manager?
A 3(38) investment manager has discretionary authority, within the scope delegated by the appointing fiduciary, to select, monitor, and replace retirement plan investments.
What's the difference between a 3(21) investment fiduciary and a 3(38) investment manager?
A 3(21) investment fiduciary provides investment recommendations while the committee makes the final decisions. A 3(38) investment manager has authority to make designated investment decisions within the delegated scope.
Does hiring a 3(38) investment manager eliminate our fiduciary responsibility?
No. The appointing fiduciary remains responsible for prudently selecting and monitoring the 3(38) investment manager. Responsibility for designated investment decisions within the delegated scope is assigned to the investment manager.
How often are investments monitored?
PointOak continuously monitors investment performance and formally reviews the investment lineup on a regular basis, making changes whenever appropriate under the Investment Policy Statement.
Can we still receive committee reports?
Yes. Even though PointOak makes investment decisions, we provide ongoing reporting, documentation, and regular updates so your committee remains informed and engaged.
Is PointOak affiliated with any investment companies?
No. PointOak is a completely independent, fee-only fiduciary advisor. We receive no commissions or compensation from investment managers, fund companies, or recordkeepers.
Ready to Delegate Investment Decisions?
Let PointOak take responsibility for selecting, monitoring, and replacing plan investments while keeping your committee informed.