3(38) Investment Fiduciaries

3(38) Investment Fiduciaries provides investment management and pension consulting primarily to participant-directed defined-contribution retirement plans (such as 401(k), 403(b), and 457 plans). The firm serves as an ERISA 3(38) fiduciary that constructs and maintains an "Investment Series" lineup and, under discretionary agreements, has authority to select, add, remove, and replace plan investment options (subject to recordkeeper limitations), overseeing roughly $1.035 billion in assets.

The firm evaluates investment managers using a pass/fail, 0–100 scoring methodology that combines quantitative measures (about 80% of the score, including style, risk/return, and peer rankings) with qualitative factors (about 20%, such as manager tenure and expense ratios), and generally recommends diversified allocations of mutual funds and ETFs. Research relies on publicly available information and periodic plan scoring, and the firm emphasizes asset allocation and diversification while acknowledging the risks inherent in pooled investment vehicles.

Distinctive aspects include its registered pension-consultant status and its affiliations with a separately registered adviser and a technology company that offers recordkeeper bidding—relationships that the firm discloses and manages as potential conflicts of interest. The brochure also notes occasional insurance-licensing activity by firm personnel and describes procedures to evaluate recommended funds and recordkeepers independently and to disclose and mitigate related conflicts.