401(k) Fiduciary Governance & Investment Oversight

Fiduciary Capital Management LLC

An effective 401(k) plan requires disciplined fiduciary governance, documented oversight, fee transparency, and informed participants. Under the Employee Retirement Income Security Act of 1974 (ERISA), plan fiduciaries must act solely in the interest of participants and beneficiaries and with prudence, skill, and diligence.

Fiduciary Capital Management LLC supports plan sponsors in meeting those responsibilities through structured process, objective analysis, and consistent documentation.

Fiduciary Governance & Investment Committee Support

Fiduciary Capital Management LLC assists plan sponsors and investment committees with:

  • Investment Policy Statement (IPS) development and refinement
  • Clearly defined fiduciary roles and responsibilities
  • Structured committee meeting support and materials
  • Ongoing fiduciary education
  • Formal documentation of monitoring and decision-making

Our emphasis is on process discipline and regulatory awareness to support prudent oversight under ERISA.

Investment Monitoring & Benchmarking

Prudent monitoring requires objective evaluation. The oversight framework of Fiduciary Capital Management LLC includes:

  • Performance review relative to stated benchmarks
  • Peer group and risk-adjusted analysis
  • Qualitative manager evaluation
  • Watch list criteria and replacement protocols
  • Documentation of committee actions

Benchmark comparisons are provided for informational purposes and do not guarantee future performance.

ERISA 3(21) & 3(38) Fiduciary Engagement

Fiduciary Capital Management LLC offers flexible fiduciary structures aligned with sponsor governance preferences:

ERISA §3(21) Investment Fiduciary
We provide investment recommendations and monitoring support. The plan sponsor retains final decision-making authority.

ERISA §3(38) Investment Manager
We accept discretionary authority to select, monitor, and replace plan investments. The sponsor’s responsibility shifts to prudently selecting and monitoring the 3(38) manager.

Fee Transparency & Revenue-Sharing Oversight

Fee awareness is central to fiduciary responsibility. Fiduciary Capital Management LLC assists with:

  • Review of plan-level and investment-level fees
  • Share class and expense evaluation
  • Revenue-sharing analysis
  • Recordkeeping and administrative cost benchmarking
  • Ongoing fee monitoring documentation

Our objective is to support a clear, defensible fiduciary review process consistent with ERISA fiduciary standards.

Participant Education & ERISA §404(c) Support

Fiduciary Capital Management LLC provides structured participant education programs designed to support informed decision-making, including:

  • Enrollment and annual education meetings
  • Investment fundamentals and retirement readiness sessions
  • Digital educational resources
  • One-on-one educational meetings (educational in nature unless separately engaged for fiduciary advice)

For plans seeking to rely on ERISA §404(c), structured communication and access to information may assist sponsors in supporting participant control requirements.

Process-Focused. Governance-Driven.

ERISA emphasizes prudence of process. Fiduciary Capital Management LLC centers its approach on documented oversight, objective benchmarking, fiduciary alignment, and regulatory awareness — designed to support plan sponsors in meeting their ongoing fiduciary responsibilities.endations.

Fiduciary Capital Management LLC


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The information provided by the Fiduciary Capital Management LLC, (“FCM” or “Fiduciary CM”) website is for educational and informational purposes only and is not intended as tax, legal, or investment advice. You should consult with a qualified legal or tax professional regarding your individual circumstances. The opinions expressed are those of the author and are subject to change without notice. This material should not be considered a solicitation for the purchase or sale of any security. We take protecting your personal information and privacy seriously. In accordance with the California Consumer Privacy Act (CCPA), California residents may exercistheir privacy rights by visiting this link. Advisory services are offered through Fiduciary Capital Management,LLC (“FCM”) a registered investment adviser. Insurance products are offered through independent insurance agencies, not affialted with FCM. Copyright © Fiduciary Capital Management LLC 2026. All rights reserved.