CIT 101: 5 Questions About CIT Onboarding

Collective Investment Trusts (CITs) are being adopted by retirement plans at an unprecedented rate.

These investment vehicles, known for their cost efficiency and retirement investor-focused protections, are now the most prominent investment vehicle in defined contribution plans like 401(k) plans – used by 82% of plans, according to Callan’s 2024 Defined Contribution Report. This surge in adoption has been fueled by the removal or reduction of minimum asset thresholds, making CITs more accessible than ever.

As CIT adoption spreads, more retirement plan advisors, employer plan fiduciaries, and other decisionmakers are encountering CITs for the first time. With this shift, questions naturally arise, especially around the onboarding process.

Below, we answer the top five questions about CIT onboarding.

1. How is Great Gray’s modern-day CIT onboarding different from the old approach?

While the legal requirements remain unchanged, the way plans complete onboarding has transformed. CIT onboarding has historically been perceived as time-consuming and paperwork heavy. However, the reality is quite different. Great Gray Trust Company has revolutionized CIT onboarding by replacing outdated, manual processes with a seamless digital experience: BoardingPass™.

With BoardingPass, the process is streamlined:

• Data is automatically saved and stored, eliminating the need to re-enter previously provided information.
• Documents are kept in a single, centralized repository, allowing plans to onboard additional CITs in minutes instead of days or weeks.
• Fund requests can be electronically submitted, often allowing the fund to be ready for trading in as little as one day.
• BoardingPass allows decisionmakers to focus on selecting the right investment, not worry about paperwork.

2. Why is onboarding necessary for CITs but not mutual funds?

CIT onboarding is needed for two key reasons:

• Legal Eligibility – CITs can only be offered to specific types of tax-qualified retirement plans. To maintain a CIT’s tax-exempt status, the Participation Agreement—a central component of onboarding—collects information to confirm a plan’s eligibility. This verification protects all participating plans.
• ERISA Oversight – Unlike mutual funds, CITs must be managed under ERISA (Employee Retirement Income Security Act), which imposes strict fiduciary responsibilities on the CIT trustee and investment managers. U.S. courts have described ERISA’s fiduciary duties as the “highest known to the law.” CIT trustees must manage assets prudently, with undivided loyalty to plan participants while adhering to rigorous compliance standards. The onboarding process ensures these obligations are properly documented.

3. Who is qualified to complete onboarding documents?

Any authorized investment decision-maker for a plan can complete the Participation Agreement. In the past, gathering the necessary information involved multiple stakeholders, often leading to repetitive back-and-forth communication.

4. Do I need to input every fund request and data entry field manually?

No. BoardingPass eliminates redundant data entry by acting as a centralized hub that automatically pulls plan data from sources like the IRS Form 5500 database and prior plan CIT investments. This means:

• Pre-filled Participation Agreements – Plan details are auto-populated, saving time and reducing errors.
• Click-to-select fund requests – The platform’s intuitive interface guides decisionmakers through fund selection without excessive manual input.

The result? Faster, more accurate onboarding with minimal effort.

5. Who benefits from a digital onboarding approach like BoardingPass?

Everyone involved in the CIT selection process benefits from a digital-first approach, including:

• Plan Sponsors & Fiduciaries – Enjoy real-time access to updates, instant alerts for missing signatures, and streamlined document storage.
• Advisors & Consultants – Quickly sort and filter fund selections by name, family, or CUSIP, ensuring a more efficient and transparent investment selection process.
• Recordkeepers – Gain instant visibility into fund requests, eliminating delays caused by paper-based document transfers.

By digitizing the process, BoardingPass enhances accuracy, reduces risk, and accelerates fund approvals. Documents are automatically generated, signed, and stored as PDFs for retrieval, eliminating the need for physical paperwork.

Onboarding should not be a barrier to CIT adoption.

CITs are becoming a fundamental part of modern retirement plan investment lineups.

With BoardingPass, CIT onboarding is no longer a burden. Plans can move forward confidently and efficiently, ensuring they access the best investment solutions without unnecessary delays.