Retirement Insights
Beyond Performance: A Modern Approach to Retirement Plan Oversight
August 11, 2026
Investment oversight and fiduciary governance remain top priorities as employers navigate evolving regulatory requirements, SECURE 2.0 implementation, heightened scrutiny and increased litigation activity. While selecting and monitoring investments remains a core responsibility, retirement plan committees must also demonstrate prudent oversight through fee benchmarking, service provider evaluation, fiduciary governance and ongoing documentation of decisions.
In this environment, fiduciary success is not measured solely by investment returns. The U.S. Department of Labor (DOL) does not expect committees to select the best performing investment options for a plan, but rather to have a prudent process in place to select and monitor investments. Regulators, auditors and plaintiffs' attorneys frequently evaluate how decisions were made, whether alternatives were considered, and how thoroughly those decisions were documented.
To properly meet fiduciary duties, retirement plan committees must:
- Establish and maintain a documented governance framework
- Monitor investments and service providers on an ongoing basis
- Evaluate fees for reasonableness and competitiveness
- Maintain detailed records of committee meetings and decisions
- Review investment options against established criteria
- Act solely in the best interests of plan participants and beneficiaries
- Proactively identify and address fiduciary and operational risks
A thoughtful governance process helps committees demonstrate procedural prudence while supporting long-term retirement outcomes for participants.
The 5P Process Supports Comprehensive Fiduciary Oversight
Historically, many investment reviews focused primarily on returns. Today, effective fiduciary oversight requires a broader perspective. USI has developed a disciplined, repeatable framework to evaluate and monitor investment managers. Known as the 5P Process, this approach combines both quantitative and qualitative analysis to help retirement plan committees make informed fiduciary decisions.
The framework evaluates investment managers through five dimensions that help fiduciaries assess both historical results and factors that influence future outcomes:
While past performance remains important, the 5P Process seeks to uncover factors that may not be apparent through performance data alone, including:
- Leadership or investment personnel changes
- Organizational restructuring
- Investment philosophy shifts
- Resource constraints
- Compliance or operational concerns
USI’s retirement team evaluates managers through investment research, industry conferences, in-person meetings, virtual reviews and on-site visits. This analysis provides fiduciaries with a more complete view of potential opportunities and risks.
Independent investment due diligence helps retirement plan committees make decisions based on goals for participant outcomes, prudent process and fiduciary best practices — not proprietary products, revenue-sharing arrangements or compensation incentives.
|
Why Governance Matters
|
Fiduciary Liability Insurance: An Additional Layer of Protection
While a disciplined governance process can help fiduciaries demonstrate prudence and support participant outcomes, it cannot eliminate all risk. Fiduciary liability insurance can provide an additional layer of protection for organizations, committees and individual fiduciaries (e.g., directors, officers, employees and administrators) of a company’s employee benefit plan in the event of a claim alleging a breach of fiduciary duty.
The insurance covers defense expenses, settlements, judgments and penalties arising from claims that allege:
- ERISA violations
- Fiduciary breaches
- Administrative errors and omissions
- Failure to follow plan documents
- Improper investment oversight
- Excessive fees or imprudent decision-making
A layered approach to risk management can strengthen fiduciary protection and governance.
USI’s fiduciary liability insurance specialists can:
- Prepare organizations for underwriting questions
- Discuss emerging areas of fiduciary risk
- Benchmark liability limits, retention levels and premium ranges against peer organizations
- Assist in evaluating appropriate levels of fiduciary liability protection
Case Study: Strengthening governance while reducing costs
An information technology company with a rapidly growing retirement plan sought assistance after multiple mergers and acquisitions increased plan complexity and assets.
USI’s retirement team conducted a comprehensive review and implemented a solution that included:
- Development of a revised investment policy statement
- Independent investment manager evaluation and selection
- Fee benchmarking and expense review
- Ongoing investment monitoring and reporting
- Enhanced fiduciary governance and documentation practices
The review resulted in an 80% reduction in investment-related costs, generating $30,000 in savings while strengthening investment oversight, fiduciary governance and risk management practices.*
Take the Next Step Toward Stronger Governance
USI’s retirement specialists help organizations move beyond traditional investment reviews by providing comprehensive support for governance, investment oversight and risk management. Combining rigorous investment analysis with broader governance expertise, we help retirement plan committees make informed decisions while maintaining a disciplined and well-documented fiduciary process.
To learn more, please contact your USI retirement representative, visit our Contact Us page or reach out to us at information@usicg.com.
* Actual results will vary. The use of any stated benefits in this case study is intended for illustrative purposes only and may not be used to predict or project future results.
Investment advice provided to the Plan by USI Advisors, Inc. Under certain arrangements, securities offered to the Plan through USI Securities, Inc. Member FINRA/SIPC. Both USI Advisors, Inc. and USI Securities, Inc. are affiliates of USI Consulting Group.
This information is provided solely for educational purposes and is not to be construed as investment, legal or tax advice. Prior to acting on this information, we recommend that you seek independent advice specific to your situation from a qualified investment/legal/tax professional. | 1026.S0731.0020
INSIGHTS BY TOPIC
Not receiving our newsletter?
Stay up to date with retirement plan updates and insights by subscribing to our email list.