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Question 1

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Most ERISA excessive-fee class actions filed against 401(k) plan fiduciaries primarily allege which type of breach?

Failure to provide hardship distributions on demand

Failure to prudently monitor recordkeeping and investment fees by leaving higher-cost share classes or revenue-sharing arrangements in place when lower-cost alternatives were available

Failure to enroll all employees automatically into the maximum deferral percentage

Failure to permit daily liquidity in stable value funds

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2026 Statistics

Key Facts: QPFC Exam

Multiple-Choice Questions

NAPA CPFA/QPFC Candidate Handbook

2.5 hrs

Closed-Book Exam Time

NAPA exam policy

70%

Passing Score

NAPA CPFA/QPFC requirements

$967

NAPA Member Exam Fee

NAPA 2026 fee schedule

50-100

Recommended Study Hours

NAPA candidate guidance

$24,500

2026 §402(g) Deferral Limit

IRS Notice 2025-67

Vacated

2024 Retirement Security Rule

N.D. Tex. final judgment, Mar 17, 2026

QPFC is a closed-book, 70-question multiple-choice exam with a 2.5-hour time limit and a 70% passing score. The exam fee is $967 for NAPA members and roughly $1,400 for non-members (which includes the four required study modules). The exam shares the same coursework as the CPFA credential. Coverage focuses on the ERISA 404(a) prudent-expert standard, 3(21) vs 3(38) advisor roles, 404(c) safe harbor, QDIA selection, 408(b)(2) service-provider disclosure, 404a-5 participant fee disclosure, target-date fund glide paths, recordkeeper evaluation, and SECURE 2.0 provisions relevant to plan advisors.

Sample QPFC Practice Questions

Try these sample questions to test your QPFC exam readiness. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1Under ERISA §404(a)(1)(B), an investment advisor servicing a 401(k) plan must act with the care, skill, prudence, and diligence of a person who is familiar with such matters. This is commonly referred to as which standard?

A.The prudent expert standard

B.The reasonable layperson standard

C.The good-faith effort standard

D.The arm's-length transaction standard

Explanation: ERISA §404(a)(1)(B) imposes the so-called prudent expert (or prudent professional) standard, which is stricter than the common-law prudent person rule. A fiduciary advising a plan is judged against what an experienced retirement-plan professional would do under like circumstances, not what a reasonable layperson would do.

2ERISA §404(a)(1)(A) requires a fiduciary to discharge duties solely in the interest of participants and beneficiaries and for the exclusive purpose of providing benefits and defraying reasonable expenses. This obligation is best described as the duty of:

A.Loyalty

B.Diversification

C.Following plan documents

D.Care

Explanation: §404(a)(1)(A) is the duty of loyalty. It bars a fiduciary from serving any interest other than the participants' and limits expense payments to those reasonably necessary to operate the plan. Diversification, document compliance, and care are separately codified at §404(a)(1)(C), (D), and (B).

3Which of the following functions performed for a 401(k) plan would NOT, by itself, make a person an ERISA fiduciary under §3(21)(A)?

A.Processing payroll deferrals according to participant instructions with no discretion

B.Exercising discretionary authority over plan administration

C.Rendering investment advice for a fee with respect to plan assets

D.Selecting the investment lineup made available to participants

Explanation: ERISA §3(21)(A) triggers fiduciary status only when a person exercises discretionary authority or control over plan management, renders investment advice for a fee, or has discretion over administration. Purely ministerial functions performed under specific instructions, such as payroll processing, are not fiduciary acts.

4An advisor signs an agreement assuming ERISA §3(38) status for the investment menu of a participant-directed 401(k) plan. What is the resulting allocation of investment-selection fiduciary responsibility?

A.The §3(38) manager has full discretionary authority and bears fiduciary liability for the lineup it constructs, while the named fiduciary retains a duty to prudently select and monitor that manager

B.The plan sponsor remains fully liable for individual fund selections; the §3(38) appointment is purely advisory

C.Liability is shared 50/50 between the §3(38) manager and the plan sponsor

D.The §3(38) appointment shifts all fiduciary liability, including the duty to monitor, to the manager

Explanation: An ERISA §3(38) investment manager is a discretionary fiduciary that selects, monitors, and replaces plan investments. Appointing one shifts fund-by-fund liability away from the plan sponsor, but the sponsor still has a residual fiduciary duty to prudently select and periodically monitor the §3(38) manager itself.

5An advisor agrees to provide ERISA §3(21) co-fiduciary investment advice to a 401(k) plan committee. How does this engagement differ from an ERISA §3(38) engagement?

A.A §3(21) advisor recommends investments but the plan fiduciary retains discretion and decision-making authority; a §3(38) manager has discretion to make the decisions

B.A §3(21) advisor must be a registered investment adviser; a §3(38) manager may be any service provider

C.A §3(21) advisor takes on all investment liability; a §3(38) manager only provides recommendations

D.A §3(21) advisor cannot be paid for advice; a §3(38) manager may be

Explanation: Under a §3(21) co-fiduciary engagement, the advisor recommends investments but the plan committee retains the discretion to accept or reject those recommendations and remains the decision-making fiduciary. Under a §3(38) engagement, the advisor takes on discretion and is solely responsible for the investment decisions made within the scope of the appointment.

6ERISA §404(c) is best characterized as:

A.A safe harbor that relieves fiduciaries of liability for losses resulting from a participant's own investment direction, provided certain disclosure and broad-range-of-investments conditions are met

B.A mandatory requirement that all 401(k) plans offer participant-directed investments

C.A prohibition on plan fiduciaries selecting investment options on behalf of participants

D.A rule that converts every participant into an ERISA co-fiduciary

Explanation: ERISA §404(c) is an optional safe harbor. When the plan satisfies the regulation (broad range of investments, ability to change selections at least quarterly, required disclosures including those under §404a-5), the fiduciary is not liable for losses that result from a participant's own investment decisions.

7To meet the §404(c) broad range of investment alternatives requirement, the plan must offer at least how many investment alternatives with materially different risk and return characteristics?

A.Three

B.Two

C.Five

D.Ten

Explanation: 29 CFR §2550.404c-1(b)(3)(i)(B) requires at least three investment alternatives, each diversified, with materially different risk and return characteristics that, taken together, allow the participant to construct a portfolio with risk and return characteristics normally appropriate for that participant.

8Which of the following losses is NOT covered by the §404(c) fiduciary safe harbor even when all regulatory conditions are met?

A.Losses arising from the imprudent selection or retention of an investment option on the plan menu

B.Losses from a participant's poor asset allocation among the available options

C.Losses from a participant's failure to rebalance after a market downturn

D.Losses from a participant choosing the most aggressive fund despite a short time horizon

Explanation: §404(c) protects only against losses that are the direct result of participant decisions; it never protects fiduciaries from their own imprudence in selecting or monitoring the menu. The duty to prudently choose each investment option remains with the responsible fiduciary, regardless of §404(c).

9ERISA §405(a) describes co-fiduciary liability. Under which condition is a fiduciary liable for another fiduciary's breach of duty?

A.Knowingly participating in or concealing the breach, enabling the breach through one's own breach of duty, or failing to make reasonable efforts to remedy a known breach

B.Being on the same plan committee at any time during the breach period

C.Receiving any compensation, even reasonable, from the plan during the breach

D.Holding a license required to provide services to the plan

Explanation: ERISA §405(a) imposes co-fiduciary liability when a fiduciary knowingly participates in or conceals another fiduciary's breach, enables a breach through its own failure of duty, or has knowledge of a breach and fails to make reasonable efforts under the circumstances to remedy it. Mere committee membership alone is not the test.

10An advisor recommends that the plan sponsor hire a relative's firm as recordkeeper. Even though the proposed fees are reasonable, this raises a fiduciary concern primarily because:

A.The duty of loyalty under §404(a)(1)(A) requires acting solely in the interest of participants, and a conflicted recommendation cannot meet that standard without process safeguards

B.Recordkeepers must be unrelated to all plan advisors by federal statute

C.All related-party transactions are per se prohibited under §406 regardless of pricing

D.The duty of diversification prohibits hiring small firms

Explanation: The duty of loyalty in §404(a)(1)(A) requires undivided loyalty to participants. A conflicted recommendation taints the prudent process and cannot survive scrutiny unless the conflicted fiduciary steps aside and an independent fiduciary handles the analysis and decision, with the arrangement still meeting the §408(b)(2) reasonable-services and reasonable-compensation tests.

About the QPFC Exam

The Qualified Plan Financial Consultant (QPFC) is NAPA's retirement-plan advisor credential. It shares the same coursework, exam, and application requirements as the Certified Plan Fiduciary Advisor (CPFA); QPFC is offered for advisors whose broker-dealer requires that designation on marketing material. The exam is a closed-book, 70-question multiple-choice test with a 2.5-hour time limit and a 70% passing score, focused on ERISA fiduciary duties, plan investment design, fee disclosure, recordkeeper evaluation, and SECURE 2.0 implications for plan advisors.

Questions

70 scored questions

Time Limit

2 hours 30 minutes

Passing Score

70%

Exam Fee

$967 (NAPA member); ~$1,400 (non-member, includes modules) (National Association of Plan Advisors (NAPA) / American Retirement Association)

QPFC Exam Content Outline

30%

Fiduciary Duty & ERISA Roles

ERISA 404(a)(1) duties of loyalty, prudent-expert care, diversification, and following plan documents; 3(21) co-fiduciary vs 3(38) discretionary investment manager; 3(16) plan administrator; 405 co-fiduciary liability; 406 prohibited transactions and 408 statutory exemptions; 408(g) eligible investment advice arrangements; 409 personal liability and 502 enforcement; DOL Voluntary Fiduciary Correction Program

15%

Participant-Directed Plan Rules

ERISA 404(c) safe-harbor conditions, broad-range-of-investments (three diversified alternatives with materially different risk/return), at-least-quarterly election frequency, education vs advice under DOL FAB 2002-3, self-directed brokerage windows, and Fifth Third v. Dudenhoeffer prudence framework for employer stock

15%

QDIA & Target-Date Funds

29 CFR 2550.404c-5 QDIA types (TDF, balanced, managed account, short-term cash for 120 days), 30-day QDIA notice and annual re-notice, DOL 2013 TDF Tips, to-vs-through glide-path analysis, passive vs active TDF construction, custom TDFs as fiduciary acts, and managed-account QDIAs

15%

Service-Provider & Participant Fee Disclosure

408(b)(2) covered-service-provider written disclosure (services, direct and indirect compensation, fiduciary/RIA status), 90-day missing-disclosure remedy with DOL notification, 404a-5 participant disclosures (initial, annual comparative chart with 1/5/10-year returns and benchmarks, quarterly fee statements), 101(i) blackout notice, and Schedule C of Form 5500

15%

Investment Policy & Recordkeeper Evaluation

IPS components and avoidance of mechanical removal triggers, watch lists and qualitative review, fund-replacement process, recordkeeper service categories (bundled vs unbundled vs open architecture), R-series share classes (R1 through R6 institutional), revenue sharing and 12b-1 fees, ERISA budget account uses, 3-5 year RFP cadence, and DOL 2021 cybersecurity best practices

10%

SECURE 2.0 & Advisor Implications

SECURE 2.0 101 auto-enrollment for new plans (3-10% initial deferral, 1% auto-escalation to 10-15%), 110 student-loan match, 115 emergency personal expense distribution, 125 LTPT eligibility (two consecutive 500-hour years), 127 PLESAs ($2,500 cap), 304 cash-out limit ($7,000), 305 EPCRS self-correction expansion, 314 domestic-abuse distribution, 603 Roth catch-up for high earners (full enforcement 2026), 604 Roth employer contributions, 107 RMD age 73/75; vacated 2024 Retirement Security Rule status as of May 2026

How to Pass the QPFC Exam

What You Need to Know

Passing score: 70%
Exam length: 70 questions
Time limit: 2 hours 30 minutes
Exam fee: $967 (NAPA member); ~$1,400 (non-member, includes modules)

Keys to Passing

Complete 500+ practice questions
Score 80%+ consistently before scheduling
Focus on highest-weighted sections
Use our AI tutor for tough concepts

QPFC Study Tips from Top Performers

1Memorize the ERISA 404(a)(1) four duties (loyalty, prudent expert, diversification, following plan documents) and recite which one each fact pattern triggers before answering

2Build a chart distinguishing 3(21) co-fiduciary, 3(38) investment manager, and 3(16) plan administrator roles, including who retains residual liability after each appointment

3Drill the 408(b)(2) covered-service-provider disclosure list and the 90-day missing-disclosure remedy until both are automatic

4Lock down 404a-5: initial timing, annual comparative chart contents (1/5/10-year returns, benchmark, expense ratio per $1,000, shareholder fees), and quarterly fee statements

5For target-date funds, practice classifying to-vs-through glide paths and applying the DOL 2013 TDF Tips selection process to demographic fact patterns

6Track 2026 IRS limits cold: 402(g) $24,500, 415(c) $72,000, age-50 catch-up $8,000, and the SECURE 2.0 ages 60-63 super catch-up structure

Frequently Asked Questions

What is the format of the NAPA QPFC exam?

The QPFC credentialing exam is closed-book, 70 multiple-choice questions, with a 2.5-hour time limit and a 70% passing score. It is administered by Pearson VUE at test centers or via online proctoring. Because QPFC and CPFA share the same coursework, exam, and requirements, NAPA allows credentialed advisors to use either designation.

What topics are tested on QPFC?

QPFC focuses on the advisor side of retirement plans: ERISA 404(a) fiduciary duties; 3(21) and 3(38) advisor roles; 404(c) participant-directed safe harbor; QDIA selection under 29 CFR 2550.404c-5; 408(b)(2) service-provider disclosure; 404a-5 participant fee disclosure; investment policy statements; target-date fund glide-path analysis; recordkeeper evaluation; share-class economics; and SECURE 2.0 provisions relevant to plan advisors.

How much does the QPFC exam cost in 2026?

The total exam package is $967 for NAPA members. Non-members typically pay close to $1,400, which includes the four required study modules. NAPA Firm Partner-affiliated candidates pay $81 annually for credential maintenance; without Firm Partner affiliation, the maintenance fee is $690. Always verify the current fee on napa-net.org before registering.

How long should I study for the QPFC exam?

NAPA recommends 50 to 100 hours of dedicated study, typically spread across 8 to 16 weeks for advisors who already have two to three years of retirement-plan experience. The biggest time blocks should go to ERISA fiduciary duties (about 30% of the exam) and to the technical disclosure regimes (408(b)(2) and 404a-5). Advisors new to plan work should plan toward the higher end of the range.

What prerequisites should I have before sitting for the QPFC exam?

NAPA recommends two to three years of retirement-plan-advisor experience. There is no formal degree or licensing prerequisite, but candidates should be comfortable with ERISA terminology, defined contribution plan mechanics, and the technical disclosure rules (408(b)(2), 404a-5, and QDIA notices). Without that base, the closed-book exam is significantly harder.

How does QPFC differ from the CPFA designation?

QPFC and CPFA share identical coursework, exam, and application requirements. NAPA offers QPFC primarily for advisors whose broker-dealer or RIA compliance department prefers the QPFC designation on marketing material; otherwise the two are interchangeable. Candidates earn one credential and may elect which letters to use professionally.

Is the 2024 DOL Retirement Security Rule on the QPFC exam in 2026?

As of May 2026 the 2024 Retirement Security Rule has been vacated by the Northern District of Texas, and the DOL has withdrawn its appeal. NAPA exam content reflects the rule's status; candidates should understand the vacatur, the implications for advice and rollover recommendations, and that the DOL has signaled it may propose a narrower replacement rule. Practice questions should be framed around current ERISA fiduciary analysis and 2022 ESG rule (which was upheld on remand in 2025).