2022 Trust Forum Presentations

Internal Use Only

Definition of “Fiduciary” • A person is a “fiduciary” to a plan to the extent that person – • Has any authority or control over the management or disposition of plan assets, • Has discretionary authority over plan administration, OR • Renders investment advice to the plan for a fee.

Internal Use Only

Definition of “Fiduciary” • The definition is “functional” ⎯ This means that you can be a fiduciary regardless of whether you’re identified as a fiduciary in any document or whether you accept fiduciary status. ⎯ Your conduct—not your official role or duties—determine whether you are a fiduciary.

“Wow, I had no idea that I was a fiduciary!”