What Does an ERISA 3(21) Fiduciary Advisor Do?
Updated August 20, 2026
A 3(21) advisor provides fiduciary investment recommendations and support while the plan sponsor retains final decision-making authority.
Key takeaways
Advice with retained sponsor authority
A limited-scope ERISA 3(21) advisor can help a plan sponsor evaluate investment options, monitor the investment menu, review fees and services, document meetings, and provide participant education. The sponsor remains responsible for making the final decisions.
What Qmulate can support
Qmulate's retirement plan services may include liaison work with independent providers, general education, group enrollment support, investment recommendations, plan reviews, and participant guidance as defined in the engagement.
- Evaluate and monitor available investment options
- Review investment expenses and plan-level services
- Support a repeatable sponsor review process
- Provide participant education and investment guidance
- Coordinate with recordkeeping, administration, and custody providers
What the sponsor still decides
The plan sponsor retains final authority over the plan, including whether to accept recommendations, which providers to hire, and which investment options to make available. The sponsor should understand and document those retained responsibilities.
Put the scope in writing
Titles alone are not enough. Review the advisory agreement, Form ADV, provider agreements, and plan documents to understand the services, decision authority, compensation, conflicts, and limitations that apply to the specific plan.
Questions business owners ask
Does Qmulate hold plan assets?
No. Plan assets are maintained through the plan's independent custodial arrangement and are not held by Qmulate.
Does Qmulate make final plan decisions?
No. Qmulate provides non-discretionary recommendations and support; the plan sponsor retains final authority.
Official resources
Continue your research
This article provides general educational information and is not legal or tax advice. Plan requirements and provider responsibilities depend on the plan documents, service agreements, and applicable law.
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