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Fiduciary Standards Start With Transparency

The loudest voices demanding “fiduciary purity” in America’s retirement debate are often the least willing to submit themselves to basic public scrutiny.

That contradiction is now impossible to ignore.

This week, the Pinpoint Policy Institute filed a formal complaint with the Internal Revenue Service alleging that the Institute for the Fiduciary Standard (IFS) has failed to make required IRS Form 990 filings publicly available, despite repeated requests. If accurate, the allegation raises serious questions about whether an organization that brands itself as a champion of transparency and accountability is complying with the most basic transparency rules that govern tax-exempt nonprofits.

This matters because IFS is not a passive observer in retirement policy. It is an active and aggressive participant.
IFS has positioned itself as a leading opponent of efforts to modernize 401(k) plans and expand access to alternative investments such as private equity, private credit, real assets, and digital assets. Most recently, it has attacked President Donald Trump’s executive initiative to allow plan fiduciaries greater flexibility in offering diversified investment options when appropriate for participants.

IFS frames this debate as a moral crusade. Its leadership argues that protecting workers requires rigid constraints, standardized portfolios, and an ever-narrower definition of “prudence.” Any deviation from the litigation-safe status quo is portrayed as reckless, dangerous, or predatory.

Yet prudence, like fiduciary duty itself, cuts both ways.

If an organization claims authority to shape national retirement policy—while warning employers, regulators, and courts about the supposed dangers of expanded choice—it has an obligation to operate with full transparency. That obligation is not ideological. It is statutory.

Federal law requires most tax-exempt organizations to file annual Form 990 disclosures and to provide those filings upon request. These documents exist for a reason: they allow the public to understand who funds an organization, how it is governed, and whose interests it ultimately serves. Failure to comply is not a technicality. It is a breach of public trust.

The irony here is difficult to miss.

IFS has spent years insisting that ordinary Americans cannot be trusted with broader investment choice inside their own retirement accounts. It argues that workers must be protected from complexity, illiquidity, and risk—even as public pension funds and university endowments routinely allocate substantial portions of their portfolios to those very same assets. This worldview has helped entrench a two-tier retirement system: one for elites with access to real markets, and another for workers confined to a legally sanitized imitation.

Now, Pinpoint’s complaint suggests that the same organization demanding maximum disclosure from others may be failing to disclose its own financial and operational realities.

This is not about politics. It is about consistency.
If IFS believes transparency is essential to protecting retirement savers, it should welcome scrutiny—not resist it. If it believes fiduciary standards require accountability, it should model that accountability itself. And if it wants to shape the rules governing trillions of dollars in worker savings, it should be willing to follow the rules governing nonprofits.

Excessive ERISA litigation, judicial paternalism, and regulatory fear have produced uniformity, suppressed innovation, and foregone returns for millions of Americans.
Transparency is the starting point for reform—not a talking point to be selectively deployed.

The IRS will determine whether the allegations against IFS are valid. But the broader lesson is already clear: those who seek to control retirement policy through moral authority must first earn it through compliance, openness, and accountability.

Fiduciary standards should begin at home.

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