What Is a Model Portfolio in a 401(k)?

A 401(k) model portfolio is often not a fund at all. It can simply be an allocation blueprint that tells the recordkeeper how to divide a participant's account among investments already available in the plan. That distinction determines what the participant owns, which disclosures apply, who controls rebalancing, how fees should be measured and whether the model itself is treated as a designated investment alternative.^[1][2]

A plan might offer:

• Conservative Model
• Moderate Model
• Growth Model.

Participant chooses:

Growth Model

The account is then allocated:

• 55% U.S. equity fund
• 20% international equity fund
• 15% bond fund
• 10% stable value.

If the participant directly owns those four plan investments, the word:

model

describes the allocation instructions.

It does not necessarily describe a separate security.

Start With the Ownership Question

The fastest way to understand a model portfolio is to ask:

What does the participant actually own after selecting it?

There are two very different answers.

Structure 1: Direct ownership of underlying plan investments

The statement shows:

• U.S. Equity Fund
• International Fund
• Bond Fund
• Stable Value.

The allocation rule determines the percentages.

Structure 2: One separate model or pooled interest

The statement can show:

Moderate Portfolio Units

or another single investment interest.

That entity then owns the underlying investments.

The allocation may look similar.

The legal structure is not.

DOL Draws This Exact Distinction

Field Assistance Bulletin 2012-02R addresses model portfolios directly in:

Q&A 28.^[1]

DOL describes a plan with:

• ten designated investment alternatives
• three model portfolios labeled conservative, moderate and growth
• each model assembled from different combinations of the ten plan investments.

The Department says an allocation-only model ordinarily does not have to be treated as a separate designated investment alternative when it is clearly presented as a means of allocating the individual's account among specific plan DIAs.^[1]

That is the basic rule.

Example: Model Is Not a Separate DIA

Plan menu:

1. U.S. Stock Index
2. International Stock Index
3. Bond Index
4. Stable Value.

Model:

Moderate

• 45% U.S. stock
• 20% international
• 25% bonds
• 10% stable value.

The account holder selects Moderate.

Statement shows four underlying positions.

That arrangement ordinarily can remain an allocation method rather than a separate designated investment alternative under the DOL framework.^[1]

The four underlying investments remain the DIAs.

When the Allocation Structure Becomes a DIA

DOL gives the opposite example too.

Suppose selecting the portfolio causes the account holder to acquire:

• an equity security
• unit participation
• similar interest

in an entity that itself owns the underlying investments.^[1]

Now the account holder owns:

the separate portfolio vehicle

rather than merely holding the component funds according to an allocation formula.

In that structure, the portfolio ordinarily would be treated as a designated investment alternative.^[1]

The Difference Is Not Cosmetic

Compare:

Allocation-only model

Participant account:

• 50 shares Fund A
• 30 shares Fund B
• 20 shares Fund C.

Unitized model

Participant account:

• 100 units Moderate Portfolio.

The first structure gives the individual direct account-level exposure to the underlying plan funds.

The second gives the account holder an interest in the portfolio entity.

That can change:

• disclosure
• pricing
• performance presentation
• trading mechanics
• fund substitution
• voting/ownership mechanics.

The name:

Moderate

does not reveal which structure exists.

A Third Situation Forces Model-Level DIA Treatment

DOL also addresses a less obvious design.

Suppose a plan offers only:

• Conservative Model
• Moderate Model
• Growth Model

and the investments inside those models are not separately designated under the plan.^[1]

The participant cannot independently choose the underlying components.

In that situation, DOL says each model would have to be treated as a designated investment alternative.^[1]

That makes sense.

Something has to be the investment alternative account holders are actually choosing.

An Allocation Layer Cannot Disappear Into a Disclosure Gap

The practical principle is:

If the underlying investments are separately offered and the portfolio framework is clearly just an allocation layer, the underlying DIAs can carry the investment-level disclosure. If the portfolio itself is effectively the account holder's actual investment choice, model-level DIA treatment can become necessary.^[1][2]

That prevents a plan from using the word:

model

to avoid showing meaningful investment information.

The Administrator Must Explain How the Portfolio Framework Works

FAB 2012-02R requires clarity even when the allocation layer is not a separate DIA.^[1]

The plan administrator should explain:

• how the portfolio framework functions
• how it differs from the plan's designated investment alternatives.

A participant should be able to tell whether:

Growth Model

means:

• one fund
• several funds
• investment advice
• managed-account service
• standing allocation instruction.

If the answer requires reading five disconnected documents, the explanation is weak.

DOL Allows Additional Portfolio-Level Information

Even when the allocation framework ordinarily does not have to be treated as a DIA, DOL says a plan administrator can voluntarily include appropriate additional information on the comparative chart, provided it is:

• not inaccurate
• not misleading.^[1]

That can be useful.

Participants often want to know:

• model allocation
• model risk label
• weighted expenses
• historical or hypothetical performance
• rebalance policy.

But voluntary information creates another responsibility:

label it correctly.

"Conservative" Is Not a Standardized Federal Allocation

One provider's Conservative Model might hold:

• 30% stocks
• 70% fixed income.

Another might hold:

• 45% stocks
• 55% fixed income.

A third might include:

• real assets
• stable value
• inflation-protected securities.

There is no federal rule saying:

Conservative = 30/70.

The same is true for:

• Moderate
• Balanced
• Growth
• Aggressive.

The allocation matters more than the adjective.

A 60/40 Model Still Needs Look-Through Analysis

Suppose a model is described as:

60% growth / 40% defensive.

That sounds clear.

But what is inside the 60%?

It could include:

• U.S. large-cap stocks
• international equities
• small-cap stocks
• emerging markets
• real estate securities.

The 40% could include:

• core bonds
• high yield
• stable value
• inflation-linked bonds.

Two 60/40 models can have very different:

• volatility
• credit risk
• duration
• currency exposure
• concentration.

Percentages are the beginning of the analysis.

Not the end.

Allocation Model vs. Balanced Fund

A balanced fund usually is a pooled investment vehicle.

Participant owns:

shares or units of the balanced fund.

The fund itself owns:

• stocks
• bonds
• other assets.

An allocation-only model works differently.

Participant directly owns several plan investments and the allocation framework determines the target percentages.

The portfolio economics can look similar.

The ownership architecture differs.

Allocation Model vs. Target-Date Fund

A target-date fund normally changes its strategic allocation as the target year approaches.

A static risk model can maintain:

60/40

until:

• participant changes it
• adviser changes model
• manager changes methodology.

The target-date fund has a:

glide path.

A Conservative/Moderate/Growth lineup typically has:

risk categories.

That distinction is important.

A Model Can Also Have a Glide Path

Nothing prevents an account-level allocation framework from being age-based.

The QDIA regulation expressly recognizes qualifying:

model portfolios that change allocation with age or target retirement date.^[3]

So the term does not automatically mean a static risk target.

A plan can build target-date-like account allocations without using a packaged target-date mutual fund or CIT.

The participant can hold the plan's underlying funds directly while the model changes over time.

Why Plans Use Models

These portfolio frameworks can let a plan combine:

• a curated core fund lineup
• professionally designed asset allocation
• automatic rebalancing
• simple participant labels.

A plan might offer:

• Conservative
• Moderate
• Growth

instead of asking participants to build every allocation from scratch.

This can reduce decision complexity.

It can also create a new governance layer.

Someone still must decide:

• asset classes
• target weights
• underlying funds
• rebalancing
• model changes.

The Model Is an Investment Decision System

Even without a separate pooled vehicle, the design embeds several portfolio decisions.

A model designer can determine:

• U.S. vs. international equity
• active vs. passive
• bond duration
• stable-value allocation
• small-cap exposure
• rebalancing method
• replacement rules.

That means model oversight should not stop at:

"The underlying funds are good."

Good funds can still be assembled into a poor portfolio.

The Reverse Is Also True

A well-designed asset allocation can be implemented with expensive or weak underlying investments.

Suppose the model's strategic allocation is defensible:

• 60% equities
• 35% bonds
• 5% stable value.

But its underlying funds cost:

• 0.90%
• 1.05%
• 0.75%.

A cheaper core menu could implement nearly the same exposure at a fraction of the cost.

The allocation and implementation should be reviewed separately.

Model Portfolio vs. Managed Account

INV-140 covers managed accounts.

The key distinction is:

who has discretion?

Participant-selected model

Participant chooses Growth Model.

Recordkeeper allocates and rebalances according to the standing selection.

Managed account

A fiduciary manager determines or changes the participant's allocation under discretionary authority.

The managed account can use models internally.

But the participant did not necessarily select:

Model 3

as the final investment decision.

The manager selected the allocation under its mandate.

DOL Separates the Managed Service From the DIA Too

FAB 2012-02R Q&A 27 says a designated 3(38) investment manager's service—and the individually managed accounts—are not themselves designated investment alternatives under 404a-5.^[1]

That reinforces the architecture.

A plan can have:

• underlying DIAs
• model allocation layer
• investment-management service

without treating every layer as a separate fund.

Different disclosures can apply to each.

A Service Fee Can Exist Without a Model Expense Ratio

Suppose model components have weighted underlying expenses of:

0.08%.

Model/advice service charges:

0.25%.

Practical model-related cost:

0.33%

before other plan administrative expenses.

The statement:

"There is no separate model expense ratio"

can therefore be technically true and economically misleading.

Ask:

What does the complete implementation cost?

Example: $300,000 Account

Underlying weighted fund expense:

0.07% = $210

Model-management service:

0.30% = $900

Plan administration:

$60

Approximate annual cost:

$1,170

before balance changes.

The allocation service itself may show no fund expense ratio.

The account still incurs meaningful cost.

404a-5 Separates Investment and Individual-Service Fees

The participant-disclosure regulation requires information about designated investment alternatives and also covers certain individual account charges such as:

• investment-advice fees
• brokerage-window fees
• similar individual expenses.^[2]

That matters when the allocation is delivered as a service rather than a pooled fund.

The underlying investment costs and the model/service charge can appear in different disclosure sections.

Participants should combine them.

A Weighted Expense Ratio Is Better Than a Simple Average

Suppose:

• Fund A: 60% weight, 0.04% expense
• Fund B: 25% weight, 0.10%
• Fund C: 15% weight, 0.50%.

Simple average expense:

0.213%.

That is not the portfolio's weighted investment cost.

Weighted expense:

• A: 0.60 × 0.04% = 0.024%
• B: 0.25 × 0.10% = 0.025%
• C: 0.15 × 0.50% = 0.075%.

Total:

0.124%.

Then add any separate:

• advice
• management
• platform

fee.

Education Can Use Asset-Allocation Models

Interpretive Bulletin 96-1 expressly recognizes qualifying:

asset allocation models

as investment education.^[4]

The educational model can show hypothetical individuals with different:

• time horizons
• risk profiles.

The bulletin requires conditions including:

• generally accepted investment theories
• disclosure of material facts and assumptions
• specified statements when plan investments are identified
• reminder to consider outside assets and income.^[4]

That is a carefully defined educational safe zone.

Education Can Identify Specific Plan Investments

This point is often overstated.

IB 96-1 does not say an educational model can never identify a specific plan investment.

When the model identifies a specific plan alternative, it must be accompanied by a statement that:

• other alternatives with similar risk/return characteristics may be available
• information about those alternatives can be obtained at the identified source.^[4]

The bulletin also requires the model to be accompanied by a reminder to consider assets outside the plan.^[4]

Content and disclosures determine the result.

Educational Model vs. Recommended Model

Compare two screens.

Screen A

Shows:

• Conservative example
• Moderate example
• Growth example

for hypothetical investors.

Participant decides what, if anything, applies.

Screen B

Collects:

• age
• retirement horizon
• current allocation
• risk tolerance

and says:

"You should select Growth Model."

The second interaction is much closer to individualized recommendation.

That moves the analysis toward INV-142.

The Current Advice Test Still Matters

In 2026, the restored five-part fiduciary-advice test in 29 CFR 2510.3-21 governs the nondiscretionary ERISA advice analysis.^[6]

A model's existence does not itself establish fiduciary status.

The relevant facts include the advisory relationship and whether advice is:

• individualized
• provided on a regular basis
• subject to the required mutual understanding
• intended as a primary basis
• compensated.^[6]

A generic model can be education.

A personalized model recommendation can be advice.

The word:

model

does not answer the question.

408(g) Computer Models Are a Different Legal Category

INV-142 explains the participant-advice exemption.

29 CFR 2550.408g-1 has a formal:

computer-model

route for certain fiduciary investment advice.^[5]

That model must satisfy detailed conditions such as:

• generally accepted investment theories
• consideration of fees
• participant data
• objective criteria
• appropriate treatment of all designated plan options
• control of affiliated/revenue bias
• independent expert certification.^[5]

A normal three-model lineup does not automatically satisfy those conditions.

Do Not Confuse These Two Statements

"The plan offers model portfolios."

This describes an investment/allocation architecture.

"The advice program relies on the 408(g) computer-model exemption."

This describes a prohibited-transaction compliance structure.

They can overlap.

They do not mean the same thing.

QDIA Rules Explicitly Permit Portfolio Models

29 CFR 2550.404c-5 expressly uses the term:

model portfolio.^[3]

A qualifying long-term QDIA can be an investment fund product or model portfolio that uses generally accepted investment theories and diversified equity/fixed-income exposure.

Two relevant structures are:^[3]

Age/retirement-based

Allocation changes over time based on:

• age
• target retirement date
• life expectancy.

Plan-population risk model

A diversified portfolio uses a target level of risk appropriate for participants of the plan as a whole.

That second structure can resemble a balanced or target-risk model.

A Default Model Does Not Need Deep Individual Personalization

For the age-based default category, the regulation does not require allocation decisions to consider:

• individual risk tolerance
• outside investments
• other preferences.^[3]

For the group-risk default category, it likewise does not require individual age, risk tolerance, investments or preferences to drive the allocation.^[3]

Such an allocation can therefore be a lawful regulatory default without being a personal financial plan.

INV-074 covers that boundary.

Default Status Does Not Decide Whether the Portfolio Is Unitized

The QDIA regulation permits:

• investment fund products
• model portfolios
• investment-management services.^[3]

That flexibility is deliberate.

A qualifying default can be implemented through:

• pooled vehicle
• account-level model
• managed service

if the applicable requirements are met.

Do not infer legal wrapper from default status.

Model Performance Needs Careful Labeling

Suppose the Growth Model was introduced:

January 2025.

The website displays:

10-year annualized return.

That cannot be ten years of actual participant experience in the current model.

It might be:

• backtested
• reconstructed
• hypothetical
• derived from historical returns of current component funds.

Those methods can be analytically useful.

They are not the same as live model performance.

Model Return and Participant Return Are Different

Even when a model has live history, participants can earn different returns because they:

• joined on different dates
• contributed every payroll
• changed models
• took withdrawals
• had loans
• experienced fund substitutions
• entered during blackout or transition periods.

A model's time-weighted return does not equal every participant's money-weighted experience.

Performance communication should make that distinction visible.

Rebalancing Assumptions Change Model History

Hypothetical model:

60/40

Historical calculation could assume:

• monthly rebalancing
• quarterly rebalancing
• annual rebalancing
• no rebalancing.

Those methods can produce different results.

A model-performance presentation should explain:

• rebalance schedule
• component history
• fee treatment
• substitution assumptions.

Without that, a precise historical number can create false confidence.

The Portfolio Can Change Without Changing Its Name

Moderate Model in 2026:

• 45% Fund A
• 20% Fund B
• 25% Fund C
• 10% Fund D.

In 2027, committee replaces Fund B.

New Moderate Model:

• 45% Fund A
• 20% Fund X
• 25% Fund C
• 10% Fund D.

The label is unchanged.

The portfolio is not.

The new fund can change:

• expense
• manager
• benchmark
• active/passive mix
• risk
• tracking error.

Monitoring therefore needs version history.

Asset-Allocation Changes Are Even More Important

Suppose the same Moderate Model changes from:

60/40

to:

70/30.

That is not a routine underlying-fund substitution.

The target risk changed.

Participants who originally selected that risk category may now own a materially different allocation.

The governance process should identify:

• why
• who approved it
• effective date
• participant communication
• whether prior performance remains comparable.

Proprietary Funds Create a Conflict Question

Suppose the portfolio provider is affiliated with:

• Fund A
• Fund B
• Fund C.

The allocation directs:

85%

to those affiliated funds.

That is not automatically imprudent.

Possible reasons:

• lower institutional pricing
• strong investment fit
• efficient administration.

But if the provider or affiliate earns more when the allocation uses proprietary products, the fiduciary should understand:

• compensation
• methodology
• alternatives
• conflict controls.

Portfolio construction can encode incentives just as easily as a human adviser can.

408(b)(2) Can Matter at the Plan Level

Covered service-provider disclosure rules can require the responsible plan fiduciary to receive information about:

• services
• fiduciary status
• direct compensation
• indirect compensation
• related-party compensation

depending on the provider and arrangement.

That matters when a model portfolio is delivered by:

• adviser
• investment manager
• recordkeeper affiliate
• asset manager.

The participant sees the portfolio.

The committee needs to see the business model.

Underlying-Fund Replacement Can Reduce Conflicts

Suppose proprietary active fund costs:

0.75%

and substantially similar unaffiliated index exposure costs:

0.04%.

The model provider replaces the proprietary option after fiduciary review.

That can reduce:

• participant cost
• affiliate revenue
• conflict intensity.

But the model's expected:

• tracking characteristics
• active risk
• return profile

also change.

Cost is not the only model input.

A Model Can Be Too Complex for Its Label

Growth Model might contain:

• 12 underlying funds
• overlapping equity managers
• multiple bond sleeves
• tactical positions
• alternatives.

The word:

Growth

makes the selection feel simple.

The portfolio can still be operationally complex.

Complexity deserves a reason.

Every extra sleeve should contribute something identifiable:

• diversification
• implementation quality
• risk control.

More components are not automatically better.

A Simpler Model Can Be More Transparent

Example:

Model A

• 60% broad U.S. equity
• 20% international equity
• 20% broad bond.

Model B

• 14 funds
• overlapping large-cap strategies
• three international funds
• four bond funds
• tactical commodities sleeve.

Model B may be better designed.

It may also just be harder to understand.

A fiduciary should be able to explain what each additional component accomplishes.

Model Rebalancing Needs Its Own Rule

A model portfolio can specify:

• monthly
• quarterly
• annual
• tolerance-band

rebalancing.

INV-144 explains those mechanics.

The key question here is:

Who controls the rebalance rule?

Possible answers:

• participant
• model provider
• 3(38) manager
• plan fiduciary
• pooled-fund manager.

That answer tells you whether the model is:

• a template
• advice
• discretionary service
• fund.

Participant Selection Does Not Necessarily Mean Permanent Allocation

Suppose a participant selects:

Growth Model

with 80/20 target.

The program provider later changes Growth to:

75/25

under the program terms.

The participant's original election could mean either:

• own exactly 80/20 forever

or:

• follow whatever allocation the Growth strategy defines over time?

The governing service terms should answer that.

This is a critical distinction between:

selecting percentages

and:

selecting a managed model strategy.

Brokerage-Window Assets Can Be Outside the Model

INV-135 covers brokerage windows.

A model can allocate only:

core designated plan investments.

Participant also owns:

$100,000

of individual stocks through the brokerage window.

The model can be:

60% equity / 40% bonds

within its scope.

The participant's total 401(k) can still be:

85% equity

after the brokerage holdings are included.

A model should not be mistaken for total-account analysis unless it actually covers the total account.

Outside Assets Are Usually Even Further Away

The provider can know nothing about:

• IRA
• spouse's plan
• taxable account
• pension
• concentrated company stock outside the plan.

A participant selecting:

Moderate

might be very aggressive or very conservative at the household level.

This does not make the model defective.

It defines its scope.

Allocation Model vs. Balanced Fund vs. Target-Date Fund vs. Managed Account

The label is less useful than the structure.

Allocation-Only Model vs. Model Treated as a DIA

This is the central legal classification.

Educational Model vs. Advice vs. Discretion

The same Moderate Model can appear in all three columns.

Generic Model vs. 408(g) Computer Model

Calling software a:

robo model

does not put it into the right-hand column automatically.

Model-Level Metrics vs. Underlying Metrics

A participant needs enough information from both levels to understand the account.

What Should a Participant Check?

1. Does the account own the model or the underlying funds?
2. What are the actual target weights?
3. Does the target change over time?
4. Who can change the model?
5. How often is it rebalanced?
6. What underlying investments are used?
7. What is the weighted underlying expense?
8. Is there a separate model/advice fee?
9. Is displayed performance live, hypothetical or backtested?
10. Are brokerage-window assets excluded?
11. Does the model consider outside assets?
12. What happens when an underlying fund is replaced?

The marketing label answers none of those questions.

What Should a Fiduciary Review?

Structure

Is the model:

• allocation layer
• unitized investment
• advice program
• managed service
• QDIA?

Methodology

• asset classes
• target weights
• expected risk
• rebalancing
• glide path if any
• model-change authority.

Implementation

• underlying fund selection
• active/passive mix
• substitution rules
• transaction mechanics.

Fees

• weighted underlying expenses
• model fee
• advice fee
• recordkeeping/platform cost
• affiliate compensation.

Conflicts

• proprietary funds
• revenue sharing
• recordkeeper affiliation
• manager incentives.

Monitoring

• model performance
• benchmark
• allocation drift
• fund changes
• participant complaints
• model-version changes
• disclosure accuracy.

The allocation process deserves oversight as a portfolio-management system.

Not merely as a label on the website.

Frequently Asked Questions

Is the portfolio model itself a mutual fund?

Not necessarily.

It can simply be an allocation among several existing plan funds.

Is the allocation framework itself a designated investment alternative?

DOL says an allocation-only model ordinarily does not have to be treated as a separate DIA when it is clearly presented as a means of allocating among specific designated plan investments.^[1]

When would it become a DIA?

One example is when selecting the model causes the participant to acquire a unit, security or similar interest in a separate entity that invests in the underlying options.^[1]

What if the underlying investments are not separately offered?

If the plan offers only models made from investments that are not separately designated, DOL says the models themselves would have to be treated as DIAs.^[1]

Are conservative, moderate and growth standardized?

No.

Review the actual allocation.

Is a balanced fund the same structure?

A balanced fund is generally a pooled investment. An allocation-only model can instead leave the participant directly invested in several plan funds.

Is a target-date fund the same structure?

A target-date fund is usually a pooled product, but the QDIA rules also permit qualifying age-based model portfolios that can create target-date-like allocations at the account level.^[3]

Can an account-level model qualify as a QDIA?

Yes, if it satisfies the applicable QDIA requirements.^[3]

Is every allocation model investment advice?

No.

IB 96-1 expressly recognizes qualifying educational asset-allocation models.^[4] Individualized recommendations require separate analysis.

Is every personalized model fiduciary advice?

Not automatically. Apply the current fiduciary-advice test to the actual relationship and facts.^[6]

Is a 408(g) computer model the same thing?

No.

408(g) is a specific prohibited-transaction exemption with detailed model, certification, disclosure and audit requirements.^[5]

Does the allocation service have an expense ratio?

An allocation-only model may not have a separate fund expense ratio, but the underlying investments and any model/advice service can still create costs.

Can model performance be hypothetical?

Yes.

Check whether results are live, hypothetical, backtested or reconstructed and what rebalancing and fee assumptions were used.

Can the provider change the underlying funds?

Potentially, depending on the plan and service terms. The participant should know who has that authority and how changes are disclosed.

Are brokerage-window investments included?

Not necessarily.

The service's defined investment universe controls.

Model-Portfolio Structure Test

Start with the statement → identify what the participant legally owns → if the account owns separate plan funds, determine whether the portfolio framework is only an allocation layer → if the participant owns a unit or interest in a separate portfolio entity, analyze that vehicle as a potential DIA → if underlying investments are not separately designated and participants choose only among models, treat model-level DIA analysis as central → explain clearly how the allocation layer differs from the underlying plan investments → identify whether the arrangement is education, participant-selected allocation, individualized advice or discretionary management → if advice is involved, apply the current fiduciary-advice framework → if 408(g) is claimed, test the actual computer-model exemption conditions rather than the product name → if the arrangement is a default, test the complete QDIA requirements → look through the allocation to asset-class exposure → calculate weighted underlying expenses → add any model, advice or management fee → identify proprietary investments and affiliate economics → determine who can change weights, funds and rebalancing methodology → distinguish live performance from hypothetical or backtested results → track model versions and underlying-fund replacements → identify assets outside the model's scope → monitor both portfolio design and implementation

The useful question is not:

"Which model sounds right?"

It is:

"What does the account actually own, who controls the allocation, what does it cost, what legal structure governs it, and what changes when the allocation framework changes?"

The model name is a shortcut.

The underlying architecture is the investment.

Sources & References

1. U.S. Department of Labor — Employee Benefits Security Administration: Field Assistance Bulletin No. 2012-02R — Fee Disclosure Guidance — https://www.dol.gov/agencies/ebsa/employers-and-advisers/guidance/field-assistance-bulletins/2012-02r
2. Electronic Code of Federal Regulations / Legal Information Institute: 29 CFR §2550.404a-5 — Participant-Directed Individual Account Plan Disclosures — https://www.law.cornell.edu/cfr/text/29/2550.404a-5
3. Electronic Code of Federal Regulations / Legal Information Institute: 29 CFR §2550.404c-5 — Qualified Default Investment Alternatives — https://www.law.cornell.edu/cfr/text/29/2550.404c-5
4. Electronic Code of Federal Regulations: 29 CFR §2509.96-1 — Interpretive Bulletin Relating to Participant Investment Education — https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-A/part-2509/section-2509.96-1
5. Electronic Code of Federal Regulations / Legal Information Institute: 29 CFR §2550.408g-1 — Investment Advice—Participants and Beneficiaries — https://www.law.cornell.edu/cfr/text/29/2550.408g-1
6. Electronic Code of Federal Regulations / Legal Information Institute: 29 CFR §2510.3-21 — Definition of Fiduciary — https://www.law.cornell.edu/cfr/text/29/2510.3-21
7. U.S. Department of Labor — Employee Benefits Security Administration: Advisory Opinion 2025-04A — https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/advisory-opinions/2025-04a
8. U.S. Department of Labor — Employee Benefits Security Administration: Information Letter 10-23-2014 — https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/information-letters/10-23-2014
9. U.S. Securities and Exchange Commission — Investor.gov: Asset Allocation and Diversification — https://www.investor.gov/introduction-investing/getting-started/asset-allocation
10. FINRA: Asset Allocation and Diversification — https://www.finra.org/investors/investing/investing-basics/asset-allocation-diversification

Educational Disclaimer

ROIStreet publishes educational content about retirement-plan investments, model portfolios, participant disclosures, investment advice, QDIAs and ERISA fiduciary duties. This article is not legal, fiduciary, tax, securities, investment or plan-administration advice. Model portfolios differ materially in ownership structure, discretion, underlying investment universe, fees, rebalancing, participant data, performance methodology and regulatory treatment. The plan document, participant disclosures, service agreement, investment-management agreement and current law control.

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