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Insights for Advisors to Help their Retirement Plans Reach Peak Potential: Part 1

October 27, 2025

by Jason Levy, Sr. Counsel at Great Gray

All Americans deserve a financially secure retirement. We support this goal across Great Gray Group by arming retirement plan advisors with the latest insights and trends that may enhance their services and generate better retirement outcomes for plan participants.

I’ve been privileged to support these efforts – and recently returned from a whirlwind trip to give four presentations in three cities about retirement hot topics. With so much to talk about, I am sharing the highlights across two blog posts. Read on for the first.

Why Collective Investment Trusts (“CITs”) Are the Right Choice for Public Retirement Plans

At the National Association of Government Defined Contribution Administrators, Inc. (“NAGDCA”) Annual Conference, I presented with my industry colleagues – Holly Zaches from Bank of New York and Irica Solomon from MissionSquare – to governmental retirement plans about collective investment trust (“CIT”) fundamentals. Here’s what resonated:

  • 457(b) retirement plans can use CITs to meaningful reduce how much governmental workers pay for retirement investment options. CITs can be 50% or 60% less expensive than corresponding mutual funds – with cost savings that come with, not at the expense of, strict regulatory oversight and investor protections.
  • It is urgent for Congress to pass bipartisan legislation to provide 403(b)s with equal access to CITs. Our audience consisted of sponsors and advisors to 457(b) plans that can access CITs and to 403(b) plans that cannot. Indeed, there are 457(b) and 403(b) plans sponsored by the same governmental entity, with the same eligible participants, with the same investment lineups – yet, the 403(b) plan is required to have more expensive investment options because they cannot access CITs. It is long overdue to fix this historical anomaly and provide 403(b) plans with a level playing field.

From 3(21) to 3(38): What Changes, What Doesn’t, and Why It Matters

At the RPAG National Conference, I had the privilege to moderate a panel with top-notch retirement advisors, Sarah Keibler and Brian Hanna, about a 3(38) (aka Outsourced Chief Investment Officer (OCIO)) services.

I left this session fully persuaded that a 3(38) / OCIO service model where an expert advisor takes day-to-day responsibility for selecting and monitoring investment options in a 401(k) lineup is a model that all 401(k) plans should consider. The cost of these services is lower than ever and utilizing them can generate additional cost savings for plan participants. In addition to the rightsizing of fiduciary responsibility between the advisor and employer plan fiduciaries, these benefits create a compelling service model that can benefit advisors and retirement plans, alike.


Great Gray Trust Company, LLC Collective Investment Funds (“Great Gray Funds”) are bank collective investment funds; they are not mutual funds. Great Gray Trust Company, LLC serves as the Trustee of the Great Gray Funds and maintains ultimate fiduciary authority over the management of, and investments made in, the Great Gray Funds. Great Gray Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively.

Investments in the Great Gray Funds are not bank deposits or obligations of and are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Great Gray Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Great Gray Funds.

Participation in Collective Investment Trust Funds is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. Collective Investment Trust Funds may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges, and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a Collective Investment Trust Fund and is available at www.greatgray.com/cit-fund-info/principal-risk-definitions/ or ask for a free copy by contacting Great Gray Trust Company, LLC at (866) 427-6885.

Great Gray® and Great Gray Trust Company are service marks used in connection with various fiduciary and non-fiduciary services offered by Great Gray Trust Company, LLC.