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3(38) Investment Fiduciaries
3(38) Investment Fiduciaries manages institutional retirement plan assets under an ERISA 3(38) fiduciary mandate — discretionary authority over plan...
3(38) Investment Fiduciaries
The firm's name derives from ERISA Section 3(38), the federal statute that defines an investment manager with discretionary authority over retirement-plan assets. By accepting 3(38) fiduciary status, the firm assumes legal liability for investment decisions — a step beyond the advisory role of a 3(21) co-fiduciary. 3(38) Investment Fiduciaries focuses on constructing and monitoring diversified portfolios for defined-contribution plans. Its strategy combines multiple asset classes — typically including private credit, hedge funds, and real estate — alongside traditional equities and fixed income. The firm does not publish a list of specific portfolio holdings, but its mandate requires continuous due diligence on the underlying funds and managers it selects. The firm operates without publicly named principals or a disclosed AUM figure. Its team size, office locations, and any adjacent vehicles (such as philanthropic structures or plan-sponsor consulting arms) are not part of the public record. No dated operational event from the last 24 months has been identified. >The structural differentiator is the fiduciary architecture itself. By operating under ERISA 3(38), the firm accepts a legal standard of care higher than most asset managers — with the personal liability for prudent portfolio decisions. That binding obligation shapes its sourcing, manager-selection, and fee-transparency posture in ways that conventional discretionary managers do not face.
General information
Firm type
RIA
Year founded
—
AUM
Undisclosed
Location
Region
North America
Country
United States
City
United States
Corporate office
—
Sector focus
Frequently asked questions
What does the '3(38)' in the firm's name mean?
The name refers to ERISA Section 3(38), which defines an investment manager with discretionary authority over retirement-plan assets. By accepting this designation, the firm assumes legal liability for investment decisions — a step beyond a 3(21) co-fiduciary, which provides advice but leaves final decisions to the plan sponsor.
Who runs investment decisions at 3(38) Investment Fiduciaries?
The firm does not publicly name its principals or investment committee. The 3(38) structure, however, means that whoever holds discretionary authority is personally liable under ERISA for portfolio outcomes. Without public disclosures, the internal decision-making process remains opaque.
Is 3(38) Investment Fiduciaries a single-family office or an institutional manager?
It is neither a family office nor a traditional asset manager. It is an RIA operating under a fiduciary mandate specific to retirement plans. Its business model is purpose-built for ERISA-governed accounts, not for managing family wealth or institutional endowments.
Does the firm invest directly in private companies or only through funds?
Public information does not specify direct or indirect investment channels. Given its 3(38) mandate, the firm likely selects commingled funds and separate accounts for plan portfolios. Direct co-investments are possible but not confirmed.
What asset classes does 3(38) Investment Fiduciaries typically use?
The firm is known in the retirement-plan space for including private credit, hedge funds, and real estate alongside traditional equities and fixed income. Its focus is diversification within the constraints of ERISA prudence rules.
How does the 3(38) fiduciary status affect the firm's fees?
A 3(38) fiduciary's fee must be reasonable under ERISA. The firm cannot accept hidden compensation or kickbacks from underlying fund managers. Any revenue-sharing or 12b-1 fees must be disclosed and credited to the plan — a transparency requirement not shared by most investment advisors.
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