Who retains all investment decision‑making authority regarding investment data under ERISA?

• A. Plan sponsor
• B. Plan fiduciary
• C. Investment adviser
• D. Plan participant

Answer: (B)

Under ERISA, the party who actually controls and makes decisions about the plan’s assets is the fiduciary. A plan fiduciary has discretionary authority over investments and over the data used to guide those investments, and they must act in the best interests of participants and beneficiaries with prudence and loyalty. While a plan sponsor may appoint fiduciaries and may provide assets or guidance, the ultimate investment decisions rest with the fiduciaries themselves. A plan participant typically does not have authority to steer investments on behalf of the plan. An investment adviser can provide advice, but they only hold the final decision-making power if they are acting as a fiduciary under the plan’s governance; otherwise they do not retain all investment decision-making authority. Therefore, the entity that retains all investment decision-making authority regarding investment data is the plan fiduciary.