Retirement Plan Consulting


Integrated Process Team (IPT) using an open architecture platform

Mr. Neal Kaye has created an Integrated Process Team (IPT) that is a multidisciplinary group of professionals who are collectively responsible for delivering a compliant retirement plan. This Integrated Process Team (IPT) is composed of professionals who plan, execute, and implement a coordinated process to address your particular circumstances using an open architecture platform.

What are the principal features of this Integrated Process Team (IPT)?

  1. Our mission is to provide a superior participant experience.  Attracting and retaining employees may be the highest priority for a sponsor (company owner). Our process is designed to help deliver a retirement plan that will distinguish your firm from your competition in the eyes of the staff you would like to attract or retain.
  2. We aim to deliver an improved retirement plan solution that will be functional, affordable, cost-effective, and perhaps most importantly, legally supportable to fulfill the fiduciary responsibilities of the sponsor.
  3. Our process is a risk management concept that is forward-looking, structured, informative, and continuous.  The key to this successful risk management is careful implementation and ongoing documentation. 
  4. Shifting a large part of the fiduciary responsibility off of the shoulders of the plan sponsor is a critical distinction – and one of the core advantages – of using our integrated process team. The ever increasing litigation surrounding retirement plans has many plan sponsors asking for this extra layer of protection.  

The know-how to get the job done

This Integrated Process Team (IPT) includes empowered representatives (stakeholders) from all of the functional areas involved with the plan—all who have a stake in its success, such as design, record keeping, investment test & evaluation, and logistics personnel. The entire team supports the sponsor.
Because the activities of a plan evolve over its life cycle, the roles of various IPT members change. Laws and the economy change which requires that one team member or another, with a particular expertise, may lead while the other team members coordinate their areas of responsibility within a defined process. Ours is a continuous improvement process. It is an ongoing effort to improve our deliverables, services, and process.

What are the responsibilities of the Integrated Process Team members?

The Employee Retirement Income Security Act of 1974 (“ERISA”) is the primary law governing the operation of employee benefit plans. Plan Sponsors may delegate certain fiduciary responsibilities to service providers.  These are a 3(21), 3(16), and 3(38) ERISA fiduciary.  An Employer’s fiduciary risk is never eliminated by hiring outside fiduciaries.

Neal Kaye is the Integrated Process Team Leader and coordinates delivery of 3(21) fiduciary services

ERISA contains the definitions of the terms used in the act. 
The 21st definition (ERISA Section 3(21)) is the definition of a fiduciary:
  • Anyone who makes decisions about managing the plan or its investments,      such as selecting the investment choices for participants or hiring persons who provide services to the plan. 
  • Anyone who makes decisions about administering the plan, such as determining the eligibility of participants, providing benefit statements and making determinations on benefits claims. 
  • Anyone who is paid to provide investment advice to the plan 3(21) fiduciaries provide investment recommendations to the plan sponsor/trustee. The plan sponsor/trustee retains ultimate decision-making authority for the investments and may accept or reject the recommendations. Both share the fiduciary responsibility. 

We search for and recommend an independent 3(16) Fiduciary

Section 3(16) defines who may serve as the Plan Administrator. Unless the Plan Document expressly provides otherwise, the Plan Sponsor is considered the Plan Administrator. Plan Sponsors may hire an independent 3(16) Fiduciary who serves as the Plan Administrator. In that case, the independent 3(16) Fiduciary assumes the responsibility as the Plan Sponsor for plan administration.
A 3(16) Fiduciary should not be confused with a third-party administrator (“TPA”). The primary difference here is the level of discretionary control over the administration of the Plan. With a TPA, the Plan Sponsor delegates some of its administrative duties to the TPA, but retains discretionary control; whereas with an independent 3(16) Fiduciary, the Plan Sponsor delegates both its obligations and discretionary power.

We search for and recommend an independent 3(38) Fiduciary

Section 3(38) requires that a 3(38) Fiduciary Investment Manager accept in writing the fiduciary delegation and be solely responsible for the selection, monitoring, and replacement of the Plan’s investment options. Plan Sponsors can delegate fiduciary responsibilities relating to the investment of Plan assets to an independent Investment Manager. A 3(38) fiduciary shall be a bank, an insurance company, or a Registered Investment Advisor (under the Investment Advisers Act of 1940.
  • A 3(38) Fiduciary Investment Manager should not be confused with a 3(21) fiduciary Plan Advisor.  A 3(21) fiduciary Plan Advisor provides recommendations and advice regarding investment options. The Plan Sponsor maintains the discretionary authority to accept or reject the recommendations of a 3(21) fiduciary Plan Advisor.

We search for and recommend an independent Record Keeper 

The Record Keeper keeps the records of “who” owns “what.” Since the record keeper has a website where employees log in, and payroll data is uploaded, this is likely the 401(k) Investment Process Team player that your company’s employees are most familiar.
What does a 401(k) record keeper do? They process employee enrollment, manage and track employee investments. The record keeper produces 401(k) plan documents that the employer will need to deliver to employees.  Most record keepers will mail these to employees for a fee. We do it for free. The most important service a record keeper may provide is retirement plan participant support.
Participants will receive a DALBAR award-winning record keeping experience.  Listening, understanding, and responding to each participant's needs are crucial distinctions– and these are the core advantages of using our Integrated Process Team (IPT).
Wells Fargo Advisors Financial Network is not a legal or tax advisor.