Crypto 401(k) Fiduciary Risk Checklist

Plan sponsors face real fiduciary exposure adding crypto to retirement plans.

As more retirement plan sponsors consider or add cryptocurrency investment options following shifts in regulatory posture, the fiduciary duty questions involved are materially different from adding a traditional fund: custodian security and insurance need genuine due diligence, fees need specific benchmarking given crypto options can carry meaningfully higher costs, and disclosure needs to address volatility and total-loss risk in concrete rather than boilerplate terms. This checklist scores 10 concrete, weighted fiduciary practices a plan sponsor's process should specifically cover before and after launching a crypto option.

• →Scores documented fiduciary decision process and custodian security due diligence separately
• →Checks fee transparency and benchmarking given crypto options' typically higher cost structure
• →Includes allocation caps and opt-in-only design as concrete risk-reduction practices
• →Covers ongoing monitoring and evolving regulatory tracking, not just a one-time launch decision
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