Investment Governance for Trust Companies and Defined Contribution Plans
Independent fiduciary governance consulting focused on how investment oversight is structured, executed, and documented.
We help trust companies, fiduciaries, advisors, and investment committees define and implement consistent investment governance frameworks—without managing assets, recommending products, or providing legal advice.
Start with a Governance Discussion
Many engagements begin with a structured discussion of how investment oversight is currently performed—and where gaps may exist.
Educational and governance-focused review. No investment recommendations.
Governance Briefings & Fiduciary Education
Many engagements begin with a structured discussion of how investment oversight is currently performed—and where governance gaps may exist.
These sessions are designed for trust companies, advisors, and investment committees seeking clarity around fiduciary responsibilities without initiating a formal consulting engagement.
Topics may include:
Investment governance frameworks across trust accounts and DC plans
Default investment (QDIA) oversight and fiduciary considerations
The role of documentation in fiduciary process
Aligning Investment Policy Statements (IPS) with actual practices
Sessions are educational in nature and do not include investment recommendations, manager evaluation, or legal advice.
Why This Matters
Across both trust accounts and defined contribution plans, fiduciary responsibility increasingly depends not just on what decisions are made—but how those decisions are understood, structured, and documented.
In many organizations:
Investment Policy Statements exist but are not fully operationalized
Monitoring practices are informal or inconsistent
Oversight relies heavily on third-party tools without a defined framework
Documentation does not clearly reflect how decisions are made
At the same time, fiduciary expectations have evolved.
Regulators, courts, and best-practice standards now focus on:
clarity of fiduciary roles
consistency of oversight processes
and the ability to document and explain decision-making over time
What We Do
Fiduciary Governance Advisors provides independent consulting focused on:
the structure, process, and documentation of investment oversight
Our work helps fiduciaries:
clarify roles and responsibilities related to investment decisions
define consistent monitoring and review processes
align Investment Policy Statements (IPS) with actual practices
establish documentation standards supporting fiduciary oversight
create repeatable governance frameworks across accounts and plans
We do not evaluate investments for replacement.
We focus on how they are governed.
Investment Governance Services
Trust Account Investment Governance
We support trust companies and fiduciaries in structuring and documenting investment oversight across accounts.
This includes:
role clarity and fiduciary responsibility alignment
IPS governance and applicability
monitoring process definition
documentation standards
consistency across accounts
escalation and review triggers
Engagements are designed to strengthen fiduciary process without altering underlying investment relationships.
Defined Contribution (DC) Investment Governance
With Emphasis on Default Investments
In defined contribution plans, the default investment often functions as the primary portfolio for participants.
We provide governance support focused on:
oversight of target-date funds and QDIAs
glide-path structure and embedded assumptions
definition and prioritization of risk
oversight of manager discretion
alignment between plan objectives and default design
consistency of governance across both default and designated investments
documentation supporting fiduciary review
Default investment governance is a central focus of our work.
Our Approach
Our engagements are:
independent — no asset management, product selection, or implementation
project-based — clearly scoped and designed to produce durable outputs
governance-focused — centered on process, not performance
documentation-oriented — designed to support fiduciary records over time
To maintain independence and clarity of role, we do not:
manage assets
recommend or replace investments
perform manager due diligence
act as plan advisor or ERISA counsel
provide legal or compliance advice
Our role is governance—not investment selection or implementation.
Our Flagship Deliverable
FGA Investment Governance Suite
Our work is typically delivered through a structured, two-part governance process:
Part I — Governance Assessment
A structured evaluation of current investment oversight practices, including:
role clarity and alignment
monitoring processes
documentation practices
IPS applicability
consistency across accounts or plans
This component identifies gaps and areas requiring clarification.
Part II — Governance Framework
A forward-looking governance framework that:
defines oversight structure and responsibilities
establishes monitoring and documentation standards
outlines escalation and review triggers
is written in a format suitable for fiduciary use
This component is designed to support a consistent and defensible oversight process going forward.
How They Work Together
Part I identifies where governance is unclear or inconsistent.
Part II provides a structured framework for governing investment oversight over time.
Who We Work With
We primarily support:
Trust Companies and Fiduciaries
Firms seeking to define and document investment oversight processes across accounts.
Advisors to Defined Contribution Plans
Advisors who want to strengthen fiduciary governance without disrupting client relationships.
Investment Committees
Committees seeking clarity around oversight responsibilities, monitoring structure, and documentation.
Engagements are typically initiated through introductions and scoped on a project basis.
Our Perspective
The fiduciary question is no longer:
“What investments have we selected?”
It is:
“Can we clearly explain how investment decisions are governed—and how that governance is documented?”
That is where we focus.
Insights
We regularly publish short, trustee-focused essays on investment governance, including topics such as:
investment oversight as a fiduciary process
default investments as structural decisions
the role of documentation in fiduciary oversight
governance frameworks across trust and DC environments
These are written for fiduciaries, advisors, and institutional audiences.
Start the Conversation
If your organization is evaluating how investment oversight is structured, documented, or aligned with fiduciary responsibilities, we are happy to discuss.