PNN-1238AO.3 Private IRON 3.38 Investment Management AgreementSignature - DRAFT-1.doc 2025

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3(38): The fiduciary can make investment decisions on the clients behalf. In general, a 3(38) fiduciary must be a registered investment advisor (RIA) under federal or state law, an insurance company, or a bank.
To become an Investment Manager, you usually need financial management experience in, for example, accountancy, banking, economics or insurance, and a relevant degree. Some degrees include investment and financial analysis. There are also postgraduate courses in investment and in investment analysis.
Professionals in this field generally hold various credentials to prove their expertise in investment management and other aspects of finance, such as being a Certified Financial Planner (CFP), Certified Wealth Strategist (CWS) or Certified Trust and Fiduciary Advisor (CTFA).
What is a 3(21) advisor? A 3(21) advisor provides advice to the plan sponsor but doesnt make the final decisions regarding the plans investment lineup. A plan sponsor who hires a 3(21) advisor is typically looking for outside investment expertise but wants to retain final discretion over the plan.
An investment manager is a type of investment adviser and is regulated by the Securities and Exchange Commission.
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