TrueNorthFiduciary Risk Advisors
Service · Fiduciary Co-Pilot

A named §3(21) co-fiduciary on every committee — with the documented record to prove it.

We sign as a §3(21) co-fiduciary on every engagement, chair the plan-governance committee on a documented cadence, and produce the audit-quality record that a DOL investigator would expect. The CFO is no longer the only signature on the page.

Request a Fiduciary AuditTalk to a principal
Scope

Governance as deliverable — committee, charter, minutes, calendar.

Fiduciary co-pilot is the umbrella engagement. It can be combined with stop-loss, pharmacy, and plan-design or stand alone. The scope is governance documentation and committee operation.

In scope

  • Plan-governance committee charter and membership recommendation
  • Quarterly committee meeting agenda, materials, and minutes
  • Annual fiduciary training for committee members
  • 408(b)(2) compensation disclosure (TrueNorth's, refreshed quarterly)
  • Vendor 408(b)(2) collection and storage in the fiduciary file
  • DOL audit-readiness file: prudent-process documentation, vendor due diligence, decision register

Out of scope

  • Legal advice (ERISA counsel of record)
  • Plan administration (TPA)
  • Investment advice on the retirement plan (separate engagement with 401(k) advisor)
Methodology

How we operate — step by step, in writing.

  1. 01

    Co-fiduciary signature

    Our standard engagement letter makes TrueNorth a named §3(21) co-fiduciary. Where engagement scope calls for it — typically large self-funded plans or plans with documented governance gaps — we accept §3(38) investment-manager status with full discretionary authority.

  2. 02

    Committee charter and cadence

    We draft (or rewrite) the plan-governance committee charter, recommend membership composition, and operate the committee on a quarterly cadence. The committee meets, the minutes record the prudent process, and the file builds the defense.

  3. 03

    Vendor due diligence file

    Every vendor — TPA, PBM, stop-loss carrier, network, captive — is documented in the fiduciary file with selection criteria, 408(b)(2) disclosure, performance review, and recommended retention or replacement. The file is built continuously, not 72 hours before a DOL inquiry.

  4. 04

    Audit-readiness register

    We maintain a decision register — what was decided, when, on what basis, who was present — that survives litigation discovery. Under ERISA §404(a)(1)(B), the prudent process is the standard; the decision register is the contemporaneous record of that process.

Deliverable schedule

What lands on the committee table, and when.

DeliverableCadenceDetail
  • Co-Fiduciary Engagement LetterOn engagementNamed §3(21) status, Schedule A fee disclosure, conflicts attestation.
  • Quarterly Committee MaterialsQuarterlyAgenda, pre-read, minutes template, post-meeting decision register entry.
  • 408(b)(2) Disclosure (TrueNorth)QuarterlyPublished at /legal/408b2; same document delivered to the plan sponsor.
  • Annual Fiduciary TrainingAnnually90-minute committee training; attendance recorded in the fiduciary file.
  • DOL Audit-Readiness FileContinuouslyPrudent-process documentation, vendor due diligence, decision register. Inspection-ready at all times.
Fee structure
Flat annual retainer$36,000 – $144,000 per plan-year

Range scales with covered lives, plan complexity, and §3(21) vs. §3(38) status. Quoted in writing in Schedule A.

The corresponding 408(b)(2) compensation disclosure is published at /legal/408b2 and refreshed quarterly.

Related engagements

Most engagements bundle these services into a single Schedule A.

The next step is a fiduciary audit, scoped to fiduciary co-pilot.

Two minutes to scope the engagement. One business day to a calendared 30-minute call with a principal. No carrier in the room. Engagement letter follows in writing.

Request a Fiduciary AuditRead our 408(b)(2) disclosure