Are You a Retirement Plan Fiduciary? Know Your Role

Why does being a fiduciary matter?

What is a fiduciary?

In simple terms, a fiduciary is someone entrusted to act in the best interest of others. For employers, that means making decisions about your retirement plan with your employees—not your business or yourself—as the top priority.

It’s a relationship rooted in trust. Employees count on their employer to offer a plan that’s fair, transparent and managed responsibly. Unlike non-fiduciary roles, where “good enough” may sometimes pass, fiduciaries must operate at the highest standard—ensuring that every decision truly serves plan participants.

The key concepts of a fiduciary relationship

As a plan sponsor, your fiduciary duty is guided by four timeless principles:

• Loyalty – Always act in the best interests of your employees as plan participants.
• Prudence – Make decisions with care, skill and diligence.
• Transparency – Ensure fees, processes and decisions are clear and well-communicated.
• Accountability – Own your role, because your choices affect your employees’ long-term financial security and well-being.

These aren’t abstract legal terms—they’re practical guideposts for how you manage your plan day to day.

Examples of fiduciary relationships in the workplace

Employer fiduciary roles often show up in:

• Plan sponsors who establish and maintain retirement plans.
• Retirement plan committees who select investment options and service providers.
• HR and finance leaders who oversee plan operations.

In every case, the takeaway is the same: employees rely on you to act in their best interest.

Are you a fiduciary? How to tell

Not sure if you’re a fiduciary?

Ask yourself:

• Do you decide which investment options are available in your retirement plan?
• Do you evaluate and select service providers (such as advisors)?
• Do you monitor fees and performance for your plan?

If you answered “yes” to any of these, you’re almost certainly a fiduciary—even if “fiduciary” isn’t in your job title.

Craig Roskom, Senior Director of Client Services for Retirement Plan Solutions at Associated Bank, drives the point home further. “If you're picking the providers that are going to work with your retirement plan, you're a fiduciary. If you're a plan sponsor, you're a fiduciary. If you're monitoring providers, you're a fiduciary. If you're picking the retirement plan committee members that will pick a provider, choose the type of plan and/or monitor the investments, you're a fiduciary.”

Understanding your fiduciary role and responsibilities

For employers, fiduciary responsibilities generally include the following:

• Acting in employees’ best interests
• Offering a diversified menu of investments
• Following your plan documents faithfully
• Monitoring fees and service providers to ensure fairness
• Keeping clear records of how and why decisions were made

This framework helps you protect your employees’ retirement readiness—and your organization from unnecessary risk.

Roskom shares that while hiring a partner can help carry the weight, it does not pass on the fiduciary responsibility entirely. “One of the benefits of working with Associated Bank is that we take as much of the fiduciary responsibility as we can to lessen the burden on the plan sponsors.”

“For example, when our Retirement Plan Solutions team takes on the investment manager role, we also assume the role of discretionary trustee,” explains Roskom. “In this role, we have the ultimate fiduciary responsibility for investment funds that are made available to plan participants. When acting as the discretionary trustee our role expands beyond taking on the responsibility of selecting, monitoring, and making decisions on the plan’s investments. Also, there are additional duties we become responsible for that go beyond managing the plan’s investments. Examples of that include; The overall management and control of the plan’s assets, including the collection and application of revenue owed to the trust and ensuring the plan's investment options comply with ERISA.”

The opportunity within the responsibility

It’s easy for some to view fiduciary duty as a burden of compliance, but employers who embrace it see something more—an opportunity to lead with integrity and impact.

When you fully understand and embrace your fiduciary role, you help ensure the retirement plan is managed efficiently, investments are prudent and employees are positioned for lasting financial security. By fulfilling your fiduciary responsibility, you achieve the following:

• Strengthen employee trust in your organization.
• Improve retirement outcomes for your workforce.
• Build credibility and protect your company’s reputation.

On the other hand, missing the mark can be costly. Poor investment choices, excessive fees or administrative missteps can erode employee savings—and even expose your company to legal and financial risk.

Ultimately, fiduciary duty is about leadership. You’re not just overseeing a plan—you’re safeguarding futures, building confidence and creating a legacy of responsibility that benefits both your people and your organization.

Moving forward with confidence

For employers, being a fiduciary comes down to three things: loyalty, care and prudence.

When assessing your needs, Roskom relays that it’s good to pick a partner like Associated Bank who will “stand in front of the plan sponsor if an issue should ever arise with the investments in their plan.” Standing up and out in front when it comes to fiduciary responsibility makes all the difference.

This is not a responsibility to be rushed or taken lightly. Take the time to evaluate your plan practices, tighten your processes and seek guidance where needed.

Reach out to our retirement plan solutions team if you’d like support navigating your fiduciary responsibilities with clarity and confidence.

Because fiduciary responsibility isn’t just a legal box to check—it’s your chance to lead, protect and empower your employees where it matters most.