As many of you know, a substantive part of my income is independent fiduciary work. Whether it’s an ERISA §3(16) administrator, trustee, or Pooled Plan Provider (PPP), my other business Austin 3(16) Fiduciary Limited, is almost as successful in income as the law practice.
There are times when Third Party Administration (TPA) firms ask me to serve as a PPP, and I raise the issue of whether they can do it independently. I’m turning down the business of getting basis point income in favor of doing what’s right by the TPA. Drafting a PPP agreement for them doesn’t net the income as being a PPP, but it’s what’s right for the client. If they’re already doing 3(16) work, being a PPP is a no-brainer. Sure, it’s taking food out of my mouth, but it’s done right by the client.
