FGA Default Investment Governance Suite™
Fiduciary Governance Advisors provides independent fiduciary governance consulting focused on default investments and Qualified Default Investment Alternatives (QDIAs) in defined contribution retirement plans.
Our work helps fiduciaries, advisors, and trustees understand, govern, and document the design and oversight of default investments — without managing assets, recommending products, or providing legal advice.
Engagements are project-based and designed to support advisors and counsel, not compete with them.
Our Focus: Governance, Not Product Selection
Default investments play a central role in participant outcomes. Yet fiduciary oversight of those investments often relies on simplified labels, marketing summaries, and backward-looking reports that do not fully explain how risk is being taken on behalf of participants.
We focus on:
How default investments are designed
What risks participants are exposed to
How those risks align with fiduciary intent
How oversight decisions are documented and revisited over time
Our role is not to decide what investment should be used, but to clarify how the investment that is used is governed.
What Our Work Typically Addresses
Our engagements commonly involve:
Glide-path design and risk framing
Alignment between participant characteristics and default assumptions
Embedded active management and fee tradeoffs
Benchmarking limitations and proper use
Monitoring practices tied to design intent rather than short-term performance
Documentation quality and fiduciary recordkeeping
These issues increasingly sit at the center of fiduciary scrutiny.
What We Do Not Do
To avoid confusion, we are explicit about what we do not provide.
We do not:
Manage assets
Recommend, replace, or select investment options
Act as plan Advisor or ERISA counsel
Provide legal or compliance advice
Evaluate individual participant outcomes
Our work complements existing advisors and legal counsel by strengthening fiduciary governance, not by duplicating other roles.
Why the Suite Exists
For most plans today, the default investment functions as the de facto plan design.
Yet fiduciary oversight often emphasizes:
Relative performance
Peer rankings
Fee comparisons
While important, these tools alone do not explain:
Why a particular risk profile was accepted
How glide-path decisions align with participant realities
What the committee intended to monitor over time
The Governance Suite exists to address those gaps.
It is a two-part framework designed to help fiduciaries:
Understand how their default investment works
Identify governance gaps that create exposure
Establish a clear, forward-looking governance framework
The Suite is designed to sit alongside existing advisory and legal relationships and to form part of the plan’s fiduciary record.
Part I — QDIA Governance Diagnostic™
The QDIA Governance Diagnostic™ is an independent assessment of how the plan’s default investment is governed.
It evaluates governance quality across key dimensions, including:
Glide-path rationale and risk exposure
Participant alignment and behavioral assumptions
Embedded active management and fee structure
Benchmarking framework and limitations
Monitoring practices and documentation quality
The Diagnostic is analytical and educational in tone.
It does not recommend investment changes.
Its purpose is to clarify what is happening beneath the surface of the default investment and where fiduciary understanding or documentation may be incomplete.
Part II — QDIA Governance Framework™
The QDIA Governance Framework™ is a proposed, forward-looking governance record written in committee voice.
Reflects best-practice fiduciary framing
Incorporates insights from the Diagnostic
Articulates how the committee governs the default investment
May be adopted or referenced by the committee going forward
This document is designed to:
Sit in fiduciary files
Provide continuity through committee turnover
Support clear explanation under hindsight review
It does not rewrite history and does not require investment changes.
How the Two Parts Work Together
The Diagnostic identifies where governance clarity is needed.
The Framework provides a structured way to address those needs going forward.
Together, they form a complete default investment governance record.
Who Uses the Suite
Advisors seeking to strengthen fiduciary oversight
Trust companies supporting fiduciary committees
Committees without dedicated internal investment staff
Education & Committee Briefings
Fiduciary Governance Advisors also provides governance-focused education for advisors, trustees, and investment committees on default investments and QDIA oversight. These sessions are designed to support fiduciary understanding and documentation practices and do not include investment recommendations or legal advice.