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Questions Sponsors Need to Ask When Hiring a 3(38) Fiduciary DC plan sponsors should examine a potential investment manager’s approach to governance as well as investing, and they should review past performance results. Reported by Hiring a 3(38) investment manager fiduciary to oversee the investments in a retirement plan lineup is an important step that sponsors should take seriously, experts say. They need to ensure that they are looking at the right criteria to judge and assess a potential 3(38) fiduciary. “I would be pretty confident that most organizations moving from a 3(21) fiduciary to a 3(38) fiduciary are doing so because the adviser has suggested they make the move,” Metzger says. “They may feel comfortable with their current relationship and just make the change, but we think that is imprudent. Even if they are moving upmarket with an organization they have been comfortable with, they still need to have a process to assess various criteria, and ....