Credentials
The foundation upon which the Fiduciary Firewall℠ is built gives plan sponsors, employers, and key decision makers the confidence that their decision to retain Fiduciary Firewall was prudent and defensible.
Fiduciary Firewall provides comprehensive and discretionary fiduciary services for over $200M in institutional and retail client assets — covering more than 50 employers across 80+ worksite locations in Michigan, Ohio, Indiana, Kentucky, Iowa, Florida, Georgia, Mississippi, Nevada, Pennsylvania, and South Carolina.
Plan fiduciaries are specifically protected by a contractual framework which formalizes Fiduciary Firewall's acceptance of fiduciary responsibility and liability for duties that would otherwise burden plan fiduciaries.
Five Ways We Protect Our Clients
Experience
The principals of Fiduciary Firewall have been serving as independent fiduciaries for qualified retirement plans since 2004 — when they designed the first Total Fiduciary Solution℠ and implemented it for a large multi-employer 401(k) plan that included the A&P/Farmer Jack grocery store chain with over 100 locations and 7,000 eligible employees.
Fiduciary Firewall provides comprehensive and discretionary fiduciary services for over $200M in institutional and retail client assets. This includes 401(k) plans covering over 50 employers in more than 80 locations in Michigan, Ohio, Indiana, Pennsylvania, Iowa, Kentucky, Florida, Georgia, Mississippi, and Nevada.
Our partners include some of the largest independent recordkeepers and institutional custodians in the USA.
The Fiduciary Firewall℠ process has been successfully tested in actual Department of Labor audits.
Adherence to Defined Standards
Fiduciary Firewall's processes and controls are grounded in the standards and practices established by fi360 and the Center for Fiduciary Studies in the Prudent Practices for Investment Stewards handbook.
Fiduciary Firewall's founder served as a contributing editor for the revision of the handbook.
ISO-Certified Fiduciaries
The Center for Fiduciary Excellence (CEFEX) is a global assessment, standards, and certification organization. Its assessment process is based on ISO 19011 and is conducted in accordance with ISO 17021 — an international standard and guideline for auditing management systems.
In 2011, Fiduciary Firewall Consulting became the 2nd firm in the USA to receive the Fiduciary Support Services Certificate from CEFEX (#CFX10128). Fiduciary Firewall Advisers became the 72nd CEFEX-certified investment adviser nationwide in 2016 and is now one of only two in Michigan (#CFX10319).
Certification is subject to an annual recertification audit of Fiduciary Firewall’s books, records, and processes. CEFEX certification provides plan fiduciaries with independent due diligence and third-party verification of Fiduciary Firewall’s qualifications to serve as a professional fiduciary.
Fiduciary Support Services
Investment Adviser
Iron-Clad Contracts
Plan fiduciaries are specifically protected by a contractual framework which formalizes Fiduciary Firewall’s acceptance of fiduciary responsibility and liability for duties that would otherwise burden plan fiduciaries.
Fiduciary Firewall’s service contracts include two key features:
- An affirmative declaration of our status as an ERISA fiduciary responsible for a specific list of services.
- Indemnification against liability resulting from our actions or which would not have been incurred but for following our advice.
“…Furthermore, Fiduciary Firewall Consulting indemnifies Client against claims incurred that are a result of fiduciary breach(s) and liability under ERISA §404(a) that would not have been incurred but for engaging FFC’s service and (i) result from FFC’s own actions, or (ii) result from Clients’ following FFC’s advice and recommendations.”
— Fiduciary Firewall Consulting Service Agreement
Insured by Lloyd’s of London
As a last line of defense, Fiduciary Firewall maintains professional liability insurance policies through Lloyd's of London.
These policies provide affirmative and explicit coverage for the fiduciary services being provided to the plan, to plan fiduciaries, and to plan participants.
Regulatory Disclosures
CEFEX (Centre for Fiduciary Excellence) is an independent global assessment and certification organization that has conducted voluntary third-party assessments of Fiduciary Firewall Consulting, Inc. (FFC) and Fiduciary Firewall Advisers, Inc. (FFA) to evaluate their adherence to a defined fiduciary standard. The CEFEX assessment process is based on ISO 19011 and conducted in accordance with ISO 17021. More information about ISO 19011 can be found at www.iso.org/standard/70017.html. The CEFEX audit process is set forth at www.cefex.org/process.shtml.
CEFEX charges a fee to cover costs related to initial and annual recertification audits. FFC’s initial certification audit in 2012 was $5,000 plus travel costs; annual recertification audits have ranged from $2,000 to $4,000 plus travel costs. FFA’s initial certification audit in 2016 was $5,000 plus travel costs; annual recertification audits have ranged from $2,000 to $4,000 plus travel costs. The fees paid have no bearing on the outcome of the audit or the determination of the CEFEX Registration Committee. Neither FFC nor FFA paid any additional fees after receiving certification in order to use the CEFEX mark or to refer to their certification.
Receipt of CEFEX certification is not indicative of future performance and should not be construed by a client or prospective client as a guarantee that they will experience a certain level of results. CEFEX certification should not be construed as a current or past endorsement by any client. According to CEFEX, approximately 95% of firms that undergo assessment are determined to be in conformance with the defined fiduciary standard. For more information, visit www.cefex.org.
Fiduciary Firewall Advisers, Inc. is a federally registered investment adviser.
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