NAPA CPFA Certification Exam 2026/2027 |
Certified Plan Fiduciary Advisor | Verified
Questions & Answers | Grade A
Q: Explain ERISA exclusive purpose and ERISA prudence rule
Answer
The Exclusive Purpose Rule: A fiduciary must act solely in the
best interest of plan participants.
The Fiduciary Standard of Care: Prudence, Loyalty, Diversification, Follow the Plan Document
Q: Identify actions that might establish a fiduciary relationship
Answer
assuming significant control over another person's property or finances, having a high degree of
trust and confidence placed in you by another party, making decisions on behalf of someone else
with their best interests in mind, providing professional advice in a field where expertise is
required, managing assets on behalf of another person, and entering into a legal agreement where
one party is explicitly designated as a fiduciary, such as a trust or will.
Q: Identify named fiduciaries
Answer
Persons or entities specifically
named in the plan document
Q: Explain roles and responsibilities of named fiduciaries
Answer
Discretionary authority over
management or the
administration of the plan
Q: Identify actions covered by the Best Interest Contract Exemption
Acknowledge fiduciary status for itself and its financial advisers;
Answer
Adhere to basic standards of impartial conduct, including: Giving prudent advice that is in the
customer's best interest (i.e., based on the investment objectives, risk tolerance, financial
circumstances, and needs of the retirement investors, without regard to financial or other
interests of the financial institution or financial adviser); Avoiding making misleading
statements; and Charging no more than reasonable compensation
Commit to the impartial conduct standards in an enforceable contract when providing advice to
an IRA owner
Implement policies and procedures reasonably and prudently designed to prevent violations of
the impartial conduct standards
Refrain from giving or using incentives for financial advisers to act contrary to the customer's
best interest
Fairly disclose the fees, compensation, and material conflicts of interest associated with their
recommendations.
Q: Differentiate investment advice and investment education
Answer
Education = guidance to help others makes their OWN decisions
Advice: significant detail about an employee's personal finances, goals and risk tolerance are
gathered in order to make projections.
Q: Describe the "best interest contract exemption" under the DOL fiduciary regulation
Answer
The Best Interest Contract Exemption permits financial advisers (i.e., an individual who is a
representative of an investment adviser, broker-dealer, insurance company, or bank or similar
financial institution) and the financial institutions that employ them to continue to rely on many
current compensation and fee practices, as long as they meet specific conditions intended to
ensure that financial institutions mitigate conflicts of interest and that they, and their financial
advisers, provide investment advice that is in the best interests of their customers.
Q: Differentiate between 3(16), 3(21) and 3(38) fiduciaries
3(16): • Ensure plan operates in accordance with ERISA
Answer
• Ensure plan follows its terms
• Provide participant notices/disclosures
• Sign and file Form 5500 (Annual return)
• Authorize distribution/loans
• Select and monitor service providers
• Ensure plan expenses are reasonable
Q: 3(21)
3(21): - Represents or acknowledges fiduciary status
Answer
Renders the advice pursuant to a written or verbal
agreement, arrangement, or understanding that the
advice is based on the particular investment needs
of the advice recipient, or
Directs the advice to a specific advice recipient(s)
regarding the advisability of a particular investment
or management decision
Usually advises plan sponsor or investment
committee, but does not make decisions alone
Q: 3(38)
3(38):Has authority to make all investment changes
Answer
Discretion to manage, buy, or sell plan assets
(pooled accounts)
Manager of "managed accounts"
Broker/dealers and brokers cannot be an
Investment Manager
Q: Identify ministerial functions performed by non-fiduciary service providers
Answer
• Not exercising any discretionary control
• Ministerial in nature
• Day-to-day job of administering the plan
• Eligibility
• Calculation of benefits
• Preparing Form 5500
Q: Identify required and additional documentation for maintaining plan records according to
fiduciary best practice
Required: • Current, SIGNED plan
document/amendments and SPD
Answer
• IRS determination/opinion letter for plan
document
• Form 5500
• Fidelity bond
• Contribution/loan deposit confirmation
reports (timeliness of deposits)
• 408(b)(2) and 404(a)(5) disclosures
• Notices: Safe harbor, QDIA, blackout, etc.
Additional: • Meeting minutes/agendas/how
decisions were "prudently" made
• Investment policy statement
• Monitoring/benchmarking reports
• Service provider agreements/contracts
Q: Explain service provider role in assisting with prudent process documentation
Answer
actively participating in the decision-making process, providing detailed information about their
services, performance metrics, and fees, allowing the plan fiduciary to thoroughly evaluate and
document the rationale behind selecting a particular service provider, thus demonstrating a
prudent approach to managing the plan and mitigating potential liability risks
Q: Identify when plan documents should be updated
Answer
whenever there is a change in the plan itself, relevant laws or regulations, or at least every few
years to ensure compliance, with most pre-approved plans requiring an update every six years to
reflect legislative changes and maintain IRS approval
Q: Identify parties-in-interest to the plan
Answer
• Employer, owners, officers, and certain relatives thereof
• Plan participants
• Fiduciaries, service providers (advisors, TPA, recordkeepers)
Q: Identify Prohibited Transactions and possible fiduciary breach events
PT: Any unauthorized transaction between a plan and a
"party-in-interest" (unless there is a specific exemption)
Answer
• Sale, exchange, or lease of property
• Lending of money or credit
• Furnishing goods or services
• Transfer or use of plan assets
• Holding certain employer securities/real property
Q: Breach = failure to fulfill any
obligation under ERISA
Answer
• Prudence, loyalty, diversification,
follow plan documents
• Maintain a plan document
• Provide information to participants
• Government reporting
Q: Identify possible consequences of Prohibited Transactions and fiduciary breach events
Answer
• Restore losses (make
plan "whole")
• Removal of fiduciary
• Civil/criminal charges
Q: Explain the DOL role in overseeing plans
enforce the Employee Retirement Income Security Act (ERISA) and PT rules
Oversees employee benefit plans
Q: Explain how common problems can be corrected using DOL and IRS correction programs
Answer
Voluntary Fiduciary Correction Program (VFCP)
• Late 401(k) contributions
• Improper benefit payments
•Improper/excessive fee payments
• Improper payment of fees to a fiduciary
• Improper loan to a party-in-interest
• Asset purchase/sale to/from a party-in-interest
Delinquent Filer Voluntary Compliance Program (DFVCP)
Employee Plan Compliance Resolution System (EPCRS)
Q: Analyze situations for possible Ethics issues under conflicts of interest
Financial interests:
Answer
Owning stocks in a company that your organization is considering doing business with.
Receiving personal gifts or benefits from vendors or clients.
Investing in a competitor company while making decisions that could impact their market share.
Family relationships:
Answer
Hiring or promoting a family member without a transparent selection process.
Favoring a project or business deal where a family member is involved.
Personal relationships:
Answer
Dating a colleague and making decisions that could benefit them.
Giving preferential treatment to friends or close associates.
Professional advancement:
Answer
Taking on extra work or responsibilities to curry favor with superiors.
Withholding negative information about a colleague to maintain a positive relationship.
Explain best practice for determining reasonableness of fees
Answer
• 408(b)(2) plan sponsor disclosure - Plan fees paid to service providers
• 404(a)(5) participant disclosure - Fees paid out of participant accounts
• Benchmarking fee reports -Helps determine value of services and Shows a prudent process is
being followed
and documented
Classify expenses as payable and not payable by the plan assets
expenses considered "administrative" or "fiduciary" are payable by plan assets, while "settlor"
expenses, which are related to employer decisions about plan design or structure, are not payable
by plan assets and should be paid by the employer
Examples of Payable expenses
Expenses payable by plan assets (administrative/fiduciary):
Recordkeeping fees
Investment and custodial fees
Compliance testing costs
Required reporting (Form 5500)
Participant communications (required disclosures)
Actuarial fees for plan administration
Claims processing and benefit calculations
Legal and consulting fees related to plan administration
Example of non-payable expenses
Expenses not payable by plan assets (settlor expenses):
Plan design studies and projections
Initial plan document creation
Discretionary plan amendments
Fees related to plan termination decisions
Consulting fees regarding plan design changes
Employer-driven communication campaigns not directly related to plan administration
Identify main consequences of not documenting prudent process for reviewing fees and services
personally liable to restore any losses to the plan, or to restore any profits made through
improper use of the plan's assets resulting from their actions. A fiduciary's liability for a breach
may also include a 20 percent penalty assessed by the Department of Labor (DOL), removal
from his or her fiduciary position, and, in extreme cases, criminal penalties
Compare and contrast a Fidelity bond and fiduciary insurance
ERISA Fidelity Bond: Required by law, protects the PLAN
ERISA Fidelity Bond: Required by law, protects the PLAN
List considerations when formulating plan goals and objectives
• Are tax benefits to owners a primary concern? (owner-driven plan?)
• It is important to maximize benefits to the owners? (owner-driven plan?)
• How important is it to attract/retain new employees? (EE-driven plan?)
• What are the employee demographics (age, salary, turnover)?
• Is there a group of employees unlikely to participate?
• Is company cash flow consistent, stable?
• Should employer contributions be flexible, or fixed?
• Is the company growing?
• What type of business entity is the plan sponsor?
Identify Plan Sponsor's business structure and related entities
Explain impact of family and related company ownership on plan design
The primary reason that the Internal Revenue Service (IRS) treats multiple entities as a single
employer for retirement plan purposes is to prevent the creation of multiple entities to
circumvent certain nondiscrimination requirements. In other words, employers with multiple
entities could take advantage of creative plan design approaches to provide a greater retirement
benefit to owners and highly compensated employees (HCEs) in one entity than to the rank-and
file employees of another entity.
Under Fidelity's Volume Submitter Adoption Agreement, any participating related employer must
be identified in your plan's Adoption Agreement by listing each related employer's name and its
Employer Tax Identification Number under section 1.02(b) & the Participating Employer's
Addendum. If a related employer has their own plan, they are not listed in the Adoption
Agreement for this plan.
Types of controlled group relationships
1. Parent-subsidiary - this exists if at least 80% of the stock of a company is owned by a parent
or another organization. 2. Brother-sister - this exists if 5 or fewer individuals collectively own
more than 80% of the stock of each brother-sister corporation. These same individuals would
own more than 50% of the stock of each corporation, when considering only the identical
common ownership in each corporation for each individual. 3. A combined group relationship -
this exists if the first two types both exist in the controlled group.
Describe impact of cash flow and budget on plan design
• May need to be treated as a SINGLE employer
• One related company may need to make contributions
to employees at another related company
• All employees may be required to be eligible under the
same plan
• As the advisor, always have plan sponsor contact an
experienced service provider or ERISA counsel
Compare and contrast IRA-based plans to 401(k) plans
SEP (Simplified
Employee Pension):
Similar to profit sharing,
invested in IRAs
Employer contributions
only, 100% vested
Compare and contrast IRA-based plans to 401(k) plans
SIMPLE IRA:
Similar to 401(k) Safe Harbor
(but with lower annual limits)
Employee and required
employer contributions
May not maintain a SIMPLE
IRA and a qualified plan
Compare and contrast IRA-based plans to 401(k) plans
SIMPLE 401(k):
Cross between SIMPLE IRA
and a 401(k) Safe Harbor
Employee and required
employer contributions
All the requirements of a 401(k)
Plan but with lower limits
Explain hybrid plan combinations
combines elements of a traditional defined benefit (DB) pension plan and a defined contribution
(DC) plan that is similar to a 401(k).
Explain plan features
Eligibility and Participation
Compensation
Contributions
Vesting
Distributions/Loans
Summarize how plan features support plan goals and objectives
Eligibility and participation:
What employees are allowed/not allowed to participate
Age/service requirements
Compensation:
Must be defined (ex. W-2), exclusions can be problematic
Maximum limit (set by IRC)
Contributions:
401(k), Roth, Match, SH, PS
Vesting:
Applies to employer contributions (match, profit-
sharing)
Usually based on years of service
Not applicable to: 401(k), safe harbor, rollovers
into plan
Distributions/Loans
Separation, death, disability, RMDs
In-service, hardship, loans
Explain which plan features are optional based on the plan design
N/A
Describe roles and responsibilities of the parties involved in creating plan documents based on
plan design
Advisors: Can be fiduciary or non-fiduciary
Third Party Administrator (TPA): Testing, Form 5500, eligibility, contributions, notices
Recordkeeper: Tracks account activity, provides account access, statements
Independent CPA: Financial reports for plans over 100 participants
Actuaries: Defined Benefit Plans
ERISA Attorneys: Plan documents, amendments, corrections
Explain the different components of an adoption agreement
• Two parts: a "checklist" of plan provisions and a
base plan document
• Pre-approved plans are IRS approved
• Prepared by TPAs and recordkeepers
• Larger plans may use an ERISA attorney and
an individually designed plan
Identify required and optional amendments
n/a
Explain importance of successful participant outcomes to Plan Sponsor and participants
n/a
List considerations for Plan Sponsor to help create successful participant outcomes
Participant Education
"Stretch" Match
Automatic Enrollment and/or Escalation
Re-Enrollment
Compare and contrast education approach and behavioral finance techniques
N/A
Explain re-enrollment process
• Default to Target Date or Managed accounts
• Results in age-appropriate asset allocation
• Opt-out option
Evaluate participant outcome by using gap analysis
N/A
Explain the roles of service providers
Advisors: Can be fiduciary or non-fiduciary
Third Party Administrator (TPA): Testing, Form 5500, eligibility, contributions, notices
Recordkeeper: Tracks account activity, provides account access, statements
Independent CPA: Financial reports for plans over 100 participants
Actuaries: Defined Benefit Plans
ERISA Attorneys: Plan documents, amendments, corrections
Identify factors used to assist in service provider selection
N/A
Describe fiduciary prudent process for selecting service providers
• Fiduciary best practice
• Advisor can help compile a list of potential providers
• Ability to review/compare different providers
• Determine if providers/contracts meet goals of plan
• Ability to determine if fees are reasonable
• Fees paid for services provided
• How paid (direct, indirect)
Explain different types of service providers, including bundled and unbundled service models
Bundled
• One provider offers ALL (or more than one)
services
• Investment, recordkeeping, TPA, education
• Cost usually expressed as a single fee
Unbundled
• Different providers for plan services
• Separate TPA, recordkeeper, and advisor
• Each provider charges a separate fee
Describe the role of Plan Sponsors regarding required participant disclosures
N/A
Explain risk/return, asset classes and diversification of investments
Risk/Return: N/A
Diversification
• Characteristics of different asset classes
• How diversification reduces risk
• Diversification allows different risk and retirement goals
for participants
Explain differences and similarities between investment options
Mutual Funds
Brokerage accounts
Separate accounts
Asset allocation funds (Target Date/ Risk)
ETFs
Alternative investments (Real estate, precious
metals, collectibles)
GICs and Stable value funds
Collect Investment Funds (CIFs)
Employer Stock
Compare to/through target date funds
• Single investment holding
• Well-diversified
• Professionally managed
• Designed to be age (TDFs) or risk (TRFs) appropriate
• TDFs (Target Date Funds) have a glide path (gets more conservative)
• "To funds" (age 65) - "through funds" ( age 65)
• TRFs (Target Risk Funds) retain their asset allocation
• TDFs require oversight to ensure glide path and cost are Reasonable
Explain Qualified Default Investment Alternative (QDIA) rules
• Used when EE does not provide investment instructions
• Provides fiduciary safe harbor relief (prudence)
• TDFs, TRFs, Balanced funds, managed portfolio
• QDIA notices are required
• QDIAs are NOT required (best practice)
Compare asset allocation fund models, including impact on participant outcomes
N/A
Compare active and passive management
N/A
Explain the impact of revenue sharing on fiduciary prudent process
• Plan asset subject to ERISA rules of prudence
• May be used to pay plan expenses
• May be credited back to participants
• Be aware of the amount of revenue sharing being generated
Summarize the process of prudent investment selection
• Diversification
• Asset classes across a risk/return spectrum
• Active/Passive management style
• Use of Target Date/Risk funds
• Are fees reasonable?
• Revenue sharing
• Do investments support plan goals?
Explain fiduciary prudent process to create a broad-based IPS
• Purpose of the IPS
• Investment selection
• Review and update IPS
• Responsibilities of plan fiduciaries
(committee, advisor)
•Investment/Manager monitoring
• Asset class guidelines
• Investment expenses/fees
• Proxy voting
• Diversification
• Asset classes across a risk/return spectrum
• Active/Passive management style
• Use of Target Date/Risk funds
• Are fees reasonable?
• Revenue sharing
• Do investments support plan goals?
Identify basic criteria and procedures to follow when selecting and replacing investment options
• Outline process for selection/monitoring/replacement of investments
• Selection criteria, monitoring software
Identify parties responsible for maintaining the IPS
n/a
Describe fiduciary prudent process to change IPS according to best practices
N/A
Identify components of investment reviews
n/a
Recommend the frequency for performing investment reviews and/or plan committee meetings
n/a
Describe the importance of investment performance evaluation for a fiduciary prudent process
n/a
Determine when investment replacements are appropriate
n/a
Identify best practice documentation needed for documenting prudent process when monitoring
plan investments
n/a
Explain daily activities required by plan sponsor staff while interacting with service providers
n/a
Identify most important actions to prevent most common errors
1) Know which errors are most common
2) Work with service providers to create a process
3) Create and use checklists
4) Read and review plan documents
5) Maintain a fiduciary file for all plan-related
documents
Identify the role of adviser related to the Retirement Plan Committee
n/a
Identify attributes of an effective Retirement Plan Committee
n/a
Explain the importance of meetings for fiduciary due diligence
n/a
Identify best practices for fiduciary training
• Identify the plan's fiduciaries and non-fiduciary
providers
• How to document fiduciary decisions
• Why read/follow plan documents
• How to diversify investments/ minimize risk
• Explain ERISA exclusive purpose/ standard of
care rules
• How to select/ monitor investments/ fees prudently
Why adopt an IPS
Describe the process for appointing and replacing fiduciaries
N/A
Identify conversion documentation as a plan management best practice
N/A
Identify conversion documents that are part of a plan management prudent process
Decision to replace old provider
Including reasons for inadequacy or
complaints
RFP (prudent process documents)
Participant notices (Blackout, QDIA)
New provider fee schedule - 408(b)(2)
New provider service agreements
New plan documents (adoption agreements)
Common when there is a change in TPA or RK
Content preview
NAPA CPFA Certification Exam 2026/2027 |
Certified Plan Fiduciary Advisor | Verified
Questions & Answers | Grade A
Q: Explain ERISA exclusive purpose and ERISA prudence rule
Answer
The Exclusive Purpose Rule: A fiduciary must act solely in the
best interest of plan participants.
The Fiduciary Standard of Care: Prudence, Loyalty, Diversification, Follow the Plan Document
Q: Identify actions that might establish a fiduciary relationship
Answer
assuming significant control over another person's property or finances, having a high degree of
trust and confidence placed in you by another party, making decisions on behalf of someone else
with their best interests in mind, providing professional advice in a field where expertise is
required, managing assets on behalf of another person, and entering into a legal agreement where
one party is explicitly designated as a fiduciary, such as a trust or will.
Q: Identify named fiduciaries
Answer
Persons or entities specifically
named in the plan document
,Q: Explain roles and responsibilities of named fiduciaries
Answer
Discretionary authority over
management or the
administration of the plan
Q: Identify actions covered by the Best Interest Contract Exemption
Acknowledge fiduciary status for itself and its financial advisers;
Answer
Adhere to basic standards of impartial conduct, including: Giving prudent advice that is in the
customer's best interest (i.e., based on the investment objectives, risk tolerance, financial
circumstances, and needs of the retirement investors, without regard to financial or other
interests of the financial institution or financial adviser); Avoiding making misleading
statements; and Charging no more than reasonable compensation
Commit to the impartial conduct standards in an enforceable contract when providing advice to
an IRA owner
Implement policies and procedures reasonably and prudently designed to prevent violations of
the impartial conduct standards
Refrain from giving or using incentives for financial advisers to act contrary to the customer's
best interest
Fairly disclose the fees, compensation, and material conflicts of interest associated with their
recommendations.
Q: Differentiate investment advice and investment education
Answer
Education = guidance to help others makes their OWN decisions
, Advice: significant detail about an employee's personal finances, goals and risk tolerance are
gathered in order to make projections.
Q: Describe the "best interest contract exemption" under the DOL fiduciary regulation
Answer
The Best Interest Contract Exemption permits financial advisers (i.e., an individual who is a
representative of an investment adviser, broker-dealer, insurance company, or bank or similar
financial institution) and the financial institutions that employ them to continue to rely on many
current compensation and fee practices, as long as they meet specific conditions intended to
ensure that financial institutions mitigate conflicts of interest and that they, and their financial
advisers, provide investment advice that is in the best interests of their customers.
Q: Differentiate between 3(16), 3(21) and 3(38) fiduciaries
3(16): • Ensure plan operates in accordance with ERISA
Answer
• Ensure plan follows its terms
• Provide participant notices/disclosures
• Sign and file Form 5500 (Annual return)
• Authorize distribution/loans
• Select and monitor service providers
• Ensure plan expenses are reasonable
Q: 3(21)
3(21): - Represents or acknowledges fiduciary status
Answer
Renders the advice pursuant to a written or verbal