It’s Time to Retire the False Notion that CITs Lack Transparency

The rapid growth of Collective Investment Trusts (CITs) over the past decade has fundamentally transformed the landscape of retirement plan investing, steadily positioning CITs to drive continued innovation in the retirement investment landscape. Today, CITs hold over $6.3 trillion in assets across all retirement plans as of year-end 2024,¹ as DC plans reached $14.2 trillion in total assets as of year-end 2025.² CITs are now the most prevalent investment vehicle in defined contribution plans, holding approximately 4% more assets than mutual funds,³ with 77% of DC plans using them.⁴ This shift is reflected in the numbers: CITs have nearly doubled their DC market share from 23% to 42% of assets, with total DC CIT assets reaching $3.8 trillion — nearly four times their level a decade ago — while mutual fund market share declined from 48% to 38%.³ CIT expansion is most evident in target-date funds, where CITs overtook mutual funds in mid-2024 and now represent 54% of total target-date assets — up from 52% the prior year — as total target-date assets reached $4.8 trillion in 2025, with all 21 new target-date series launched that year structured as CITs.²

CITs’ appeal lies in lower fees, rigorous institutional oversight under strict and overlapping legal regimes, and significant investor protections — positioning them as a cost-effective alternative to mutual funds and the investment vehicle of choice for innovative retirement investment products.¹ Industry analysts note that CITs’ lower costs, coupled with plan sponsors’ and other employer plan fiduciaries’ continued focus on cost-effective solutions that meet rigorous fiduciary standards, position them for ongoing growth in the retirement ecosystem, with assets projected to reach $9.2 trillion by 2029.¹

Also contributing to this growth are declining or eliminated investment minimums, which have brought CITs to a broader market. However, some in the retirement ecosystem may still be unfamiliar with these vehicles, resulting in antiquated misperceptions often around transparency.⁵ Misperceptions of a rapidly declining segment of the retirement marketplace hinder their recognition of the enhanced disclosure standards that have governed these vehicles since 2012.⁶, ¹³ CITs operate under robust transparency frameworks specifically designed for institutional retirement investors, including DOL Regulation 404a-5, which establishes vehicle agnostic disclosure requirements that apply equally to CITs, mutual funds, and all other retirement plan investment vehicles. When a CIT holds ERISA plan assets, the entire CIT becomes subject to ERISA’s fiduciary and prohibited transaction provisions, creating the highest standard of investor protection for retirement plan participants.⁷ Importantly, ERISA’s look-through rules mean that as long as one investor in a CIT is an ERISA-covered plan, all assets in that CIT are managed to the ERISA standard — effectively extending these protections to non-ERISA plans invested alongside ERISA plans in the same vehicle. Technological advancements have further enhanced how easily plan fiduciaries and participants can access and compare CIT information, closing the gap between the transparency frameworks that have always existed and the market’s awareness of them. These frameworks are explored in detail in Sections 3 and 5.

This paper explores the transparency frameworks under which CITs operate. It underscores how transparency serves plan fiduciaries in meeting their responsibilities and supports participant decision-making. By highlighting the regulatory standards, technological advancements, industry best practices, and market adoption trends, this paper aims to close the recognition gap and position CITs accurately as the transparent, well-governed, and increasingly accessible investment options they have long been — and to ensure all stakeholders in the retirement planning process have the understanding they need to act on that reality