The Non-Fiduciary Financial Professional Value Proposition
To Be or Not To Be?
Broker/dealers are determining whether or not to allow their financial professionals to act as ERISA fiduciaries by providing plan and participant-specific investment advice. Financial professionals who have been given the fiduciary “green light” by their broker/dealer are deciding if it makes sense to serve as a fiduciary for small plans based on economics, time management, risk management, and other plan characteristics. Financial professionals who are not permitted by their broker/dealer to act as an ERISA fiduciary, and those who choose not to serve in a fiduciary role (if allowed by their broker/dealer) for some or all of their clients, need to create and articulate a viable and visible value proposition that explains the assistance and education they provide to their retirement plan sponsor clients.
Building a New Retirement Value Proposition
Now is the time to document all the ways you may be assisting your plan sponsor clients. If your service model has traditionally been more narrowly focused, consider how your skills and interests best match plan sponsor and participant needs. Here’s how non-fiduciary financial professionals can add value:
1. Service Provider Review and Assistance
While the plan sponsor has the fiduciary responsibility to ultimately make a decision on service provider selection, you can provide education, information, and insights to help them decide.
How you can help:
- Educate sponsors on what the various service providers offer
- Educate sponsors on benefits and weaknesses of service providers
- Educate sponsors on pricing and fees of service providers
- Help plan sponsors navigate discussions with service providers
- Assist with service provider selection
- Assist with plan conversion and change in service providers
2. Plan Administration Education & Information
Plan sponsors, as fiduciaries, have a long list of responsibilities – but most have neither the time nor the expertise to adequately manage all of their plan obligations.
How you can help:
a) Pre-Sale: Plan Assessment Assistance
- Review existing plan objectives
- Review existing plan design
- Review available fiduciary support service
- Review education services
- Review investment offering
b) Post-Sale: Plan Due Diligence Assistance
- Provide plan sponsor education on regulatory changes
- Provide a document checklist
- Review and update plan document files
- Provide a compliance calendar
- Provide a sample Investment Policy Statement (if fiduciary support services are not being utilized)
- Assist with on-going service provider assessment and fee analysis
- Assist with annual fiduciary review
- Assist with annual plan review
3. General Information about Qualified Plans
While you may not realize it, you probably spend a significant time educating plan sponsors about qualified plans in general. This is an important part of your value proposition.
Provide information about:
- Types of services provided by different service providers
- Fiduciary responsibilities
- Accessing fiduciary support services
- ERISA Standards of Conduct
- Limiting liability with ERISA Section 404(a)
- Fee disclosure
- Administrative responsibilities
- Participant education responsibilities
4. Employee Education and Post-Employment Planning
Not only does ongoing participant communication and education reinforce your relationship with sponsors and participants, but it’s a vital component in helping participants reach desirable retirement outcomes.
How You Can Help:
- Design, coordinate and deliver plan-specific enrollment programs
- Create and implement a series of ongoing participant communications and education programs
- Offer retirement income planning and counseling
- Provide plan distribution and IRA counseling and support
- Offer college fund planning and insurance services
The Next Steps
The key to ensuring plan sponsors understand and appreciate the value you bring is to clearly identify the assistance, expertise and education you can offer across a wide-range of areas. As you’re thinking about your value proposition as a non-fiduciary financial professional, it’s important to:
- Decide what assistance you want to provide and how it relates to your compensation
- Develop an action plan for meeting with your clients to discuss your role
- Draw upon the resources of your firm and others
Guardian Retirement Solutions™ has created information to assist financial professionals in understanding the implications of the fee disclosure regulations and fiduciary issues – and offer strategies to help re-define their retirement value proposition in this new regulatory environment. Ask your Guardian Retirement Solutions™ sales team for more information.
FOR PRODUCER/BROKER-DEALER USE ONLY
This article is not intended by The Guardian Life Insurance Company of America, The Guardian Insurance & Annuity Company, Inc. (GIAC) or any of its employees or agents to be considered as investment, tax or legal advice. You and your clients should consult your own independent tax, investment and legal advisors for information that is specific to your situation.