This is the 2026 revised and updated edition of Ropes & Gray’s ERISA Compliance Handbook for Asset Managers. Like the original Handbook, this new edition is intended to support managers of U.S. private pension assets with a helpful resource that explains the basic rules and requirements of ERISA as they relate to the investment of pension funds and other asset pools subject to ERISA, in contexts relevant to fiduciary activity.
Although every effort has been made to reflect current guidance on key issues, this area of the law is continuously evolving, and new guidance appears on a regular basis. While the last Section aims to provide a summary of the most significant recent developments affecting ERISA plan fiduciaries, we advise the readers of this Handbook to continue to regularly watch for new developments and always consult qualified legal counsel for further explanation or substantive application of the rules to any given situation.
Sections

I. Basics
Discusses the methodology for determining whether you are managing ERISA plan assets, and reviews basic rules governing fiduciary conduct.

II. Documentation
Addresses standard requirements for a manager that undertakes to manage ERISA plan assets, including customary documentation a manager should have in place before accepting ERISA plan assets for management.

III. Important Policies & Procedures
Describes reporting and disclosure requirements in connection with the relationship between a manager and its ERISA clients, rules that apply to gifts and entertainment received or provided by an ERISA manager, and proxy voting.

IV. Qualifications

V. Specific Transactions
Explains rules that apply to enumerated specific transactions involving ERISA assets.

VI. Evolving Legal Landscape for Plan Fiduciaries
Summarizes the current status of recent legislative and regulatory initiatives that impact ERISA plan fiduciary behavior, for example, “ESG” investing and cryptocurrency.
Addresses certain items appurtenant to the management of governmental plan assets as well as participant-directed assets held under a 401(k) or other individual account plan.
If you have particular questions regarding the content in this Handbook, please email ERISAFiduciaryPractice@ropesgray.com or contact one of the following members of our ERISA Fiduciary practice.
Special thanks to Peter Rosenberg, a former partner in Ropes & Gray’s ERISA Fiduciary Practice, for his invaluable assistance with revising and updating the latest edition of the Handbook.




