Check list of To-Do's for 3(38) Eval and Monitoring from Unified Trust and Dr. Greg Kasten.

1. Steps Required to Prudently
Delegate to a 3(38) Manager
1
The fiduciaries must engage in a preliminary screening process to identify a range of qualified candidates;
The fiduciaries must document the process;
Fiduciaries must obtain and review the following:
 Assets under management
 Historical results
 Experience with plans similar to proposed plan
 Proposed fee structure
 Client references
 Capitalization and financial condition
 Bonding
 Fiduciary liability insurance
 Written description of proposed investment style
 Qualifications and experience of the professionals involved
 Any pertinent regulatory action or litigation; regulatory agencies such as SEC, DOL, and NASD must be
contacted to screen for any such action
 Business structure and affiliations
 Full disclosure of how affiliates will be involved in servicing the client and any compensation received by
affiliates in connection with the client relationship
 Procedures for compliance with prohibited transaction rules
 Fiduciaries must verify through independent sources any information provided by vendors.

2. Steps Required to Prudently
Monitor a 3(38) Manager
2
Quarterly review:
 Compliance with investment guidelines
 Compare investment manager reports to custodian reports to identify any discrepancies
 Ensure all assets have been properly valued
 Compare portfolio returns versus benchmark; break down by asset class and sector
 Verify each manager’s fee computation
Annual review (including an annual face‐to‐face meeting):
 Review brokerage and trading practices, including brokerage costs, soft dollars, turnover, and best execution
 Proxy voting policy and performance
 Procedures for communicating investment information
 Investment performance
 Changes in corporate or capital structure
 Changes in investment style
 Changes in brokerage affiliation or practices
 Changes in investment process
 Changes in professional staff