ERISA Guidance Reframes ESG Share Large institutional investors, including pension funds, insurance companies and major university endowments, have historically been slow to adopt the integration of environmental, social and governance (ESG) factors into the investment process. Greatly expands the number of market participants that are ERISA fiduciaries by reason of providing investment advice Doesn't change "discretionary" fiduciary definition Advice is fiduciary investment advice if both (A) and (B) are met (No requirements of (i) regular basis, (ii) primary basis or (iii) mutuality): Investment Options. The federal government doesn't have a list of approved investments for ERISA plans. Standard options include mutual funds, "collective investment" funds that pool money from The creation and implementation of a written investment policy statement is one of the most important steps that plan fiduciaries can take to demonstrate a prudent investment process under the Employee Retirement Income Security Act of 1974 (ERISA), as amended. An investment manager to whom such investment policy applies would be required to comply with such policy, pursuant to ERISA section 404(a)(1)(D) insofar as the policy directives or guidelines are consistent with titles I and IV of ERISA. Although it is not required under ERISA, Callan recommends the plan' s investment committee adopt an investment policy statement (IPS). The IPS should reflect the plan sponsor's basic decisions about overall strategy and set basic guidelines for how the plan sponsor designs the fund menu and select s, monitors, and replaces managers. Listen as our authoritative panel of attorneys discusses ERISA 3(38) investment managers and offers guidelines for selecting investment managers, negotiating and drafting IMAs, and documenting the investment manager partnership from perspectives of both the plan sponsor and the investment manager. Requires accountability of plan fiduciaries. ERISA generall