Plan administrators, pursuant to ERISA Section 3(16) can delegate fiduciary responsibility to another. This company ERISA Fiduciary Administrators, LLC is a company that exists to serve as the “Named Plan Administrator” and, as a result, becomes a fiduciary under the plan.
1-Do you like that a plan administrator can “delegate” or name a “plan administrator” and delegate her fiduciary obligations?
2- Do companies like ERISA Fiduciary Administrators, LLC serve a useful purpose?
3-Can the true plan administrator, not the “Named Plan Administrator” still be liable as a fiduciary even if she delegated the plan administrator functions to another? If, yes, how so?
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