Our Mission and Philosophy
At MJM401k, our mission is very straightforward:
As a professional ERISA fiduciary, we provide support to our client companies in helping them manage the risks and challenges that come with operating a 401(k) plan, and in so doing, maintain a plan that will help their employees accumulate the assets needed for a financially dignified retirement.
We do this with the fundamental belief that it is our job to provide plan committees with both the knowledge and data they need to make good decisions and to properly discharge their fiduciary responsibilities. We endeavor not simply to relay information, but to delve more deeply into the reasons behind our advice.
Fulfilling Fiduciary Responsibilities
Our firm is dedicated to assisting our clients in fulfilling their fiduciary duties under ERISA, so we provide a wide range of support, tools and processes to help them manage their 401(k) plans. We offer fiduciary training for both committee members and internal benefits staff. MJM401k also equips its clients with checklists to ensure that all plan-related fiduciary functions are being completed on a timely basis, and we discuss applicable administrative/compliance issues at each of the quarterly committee meetings. In order to further ensure that fiduciary responsibilities are being met, we encourage Committee members and internal staff members to call us whenever they have plan-related questions. We do not expect our clients to be experts on ERISA fiduciary issues – what is most important is that they have sufficient training to recognize issues that should be presented to us for resolution.
As part of our responsibilities, we will:
- Help you maintain a fiduciary process that accurately reflects the provisions in your Committee Charter and Investment Policy Statement.
- For each of your quarterly fiduciary committee meetings, prepare detailed agendas and minutes which cover topics of plan administration/compliance and investment related issues.
- Monitor all plan-related fees and expenses to make certain that they are both reasonable under ERISA and marketplace competitive.
- Help maintain plan documents in compliance with all applicable DOL/IRS rules and regulations.
- Provide guidance in assuring that participants receive all required notices and fee disclosure statements.
Our Standard of Care
MJM401k serves as a fiduciary to all of our clients’ 401(k) plans. We explicitly document this fiduciary standard of care in our engagement agreement and can structure our relationship with a plan as either an ERISA §3(21) investment consultant or as an ERISA §3(38) investment manager. Under a §3(21) arrangement, all of our recommendations are subject to the approval of the Committee, and thus the fiduciary liability is shared with the Committee. Under a §3(38) arrangement, we assume all of the fiduciary liability by having the sole discretionary responsibility for the recommendations and their implementation, thus relieving the Committee of this particular responsibility and liability.
As fiduciaries to a 401(k) plan, we are bound by the same standard of conduct and are responsible to the same extent as is the Committee. Therefore, any failure to meet fiduciary obligations would inure to MJM401k as well as to the 401(k) plan sponsor. We find that failures to meet fiduciary obligations are generally a result of the failure to:
- Establish a process of plan governance.
- Follow governing documents such as the plan document and the IPS in making plan decisions.
- Properly document the actions of all fiduciaries under the plan.
MJM401k has significant experience in 401(k) plan governance matters, and has worked with numerous employers in helping them establish and maintain process discipline around the fiduciary function. This experience forms the basis for the manner in which we fulfill our client services.
Creativity, Innovation and Forward Thinking
Keeping up with the ever-changing sphere of 401(k) plans requires plan sponsors to exercise creativity and innovation in the design and operation of their plans. MJM401k has been at the forefront of emerging industry trends, and as such, we are able to position our clients on the cutting edge of 401(k) best practices. Our firm boasts a distinguished history of forward thinking. We were among the first to:
- Offer independent flat fee advisory services to 401(k) plans
- Bring the investment management and fiduciary principles of ERISA §3(38) to defined contribution plans
- Receive certification by CEFEX for best practices as an investment fiduciary
- Conduct comprehensive fund-agnostic plan provider fee benchmarking
- Demand plan provider full fee transparency and the creation of ERISA budget accounts
- Emphasize the power of plan design over plan education especially with regard to automatic features and QDIA-type mapping
- Perform in-depth target date fund analysis
- Promote focused plan architecture – target date funds and IDAs (elimination of core fund options)
MJM401k is dedicated to superior client service and satisfaction. This pledge is supported by the fact that we have never lost a client due to service issues. We solidify our clients’ expectations and objectives at the outset of our relationship so that they can feel assured that all of our services will be directed toward accomplishing their goals. If our services fail to satisfy our clients, we will make the appropriate corrections immediately, and/or refund fees for any services they do not feel were performed appropriately.