As you may be aware, I helped start a separate ERISA §3(16) fiduciary service and the reason I did was because I thought there was a need for a 3(16) administration service that was not connected to any third party administrator (TPA) and give plan sponsors the choice to hire a separate fiduciary who was not tied to any TPA especially if that plan sponsor’s TPA didn’t offer that service.
In addition, it allows the TPA who have no interest in offering the service on their own to refer work to someone who isn’t a competitor for their own TPA services.
So the 3(16) service is completely separate from my law practice and will eventually be staffed with its own personnel. Any questions, let me know.