Recent headlines about private investments—especially private credit—have raised understandable questions from nonprofit investors. Cases of isolated defaults, investors hitting redemption limits, and emerging pressure in certain sectors have created uncertainty and, in some instances, discomfort among nonprofit boards and leadership teams.

Even if these headlines fail to capture the full context, they draw attention to key risks and operational considerations that nonprofits should evaluate carefully to ensure private investment exposure advances, rather than constrains, their mission.

For nonprofit leaders, the priority is aligning investments with the organization’s mission, liquidity needs, and governance capacity. This article explains how to evaluate private investments with clarity, discipline, and long-term perspective.

What Are Private Investments?

Private investments are assets that are not traded on public exchanges like stock markets. Instead of buying publicly listed stocks or bonds, private investors commit capital to private funds that invest directly in companies or assets. These may include one or more of the following.

Unlike publicly traded securities, private investments are typically held for several years at a minimum. They are not easily bought or sold (in other words, they’re less liquid), and they carry a unique set of opportunities and risks compared to other investments.

Why Nonprofits Use Private Investments

Some nonprofits may already be well-positioned to use private investments effectively. In particular, these strategies tend to fit organizations that:

As public markets have grown less predictable, these advantages have grown more interesting to nonprofit investment committees.

Financial markets are now contending, simultaneously, with geopolitical pressures, economic uncertainty, and rapid technological change. This means institutional investors are no longer focused on predicting a single most-likely outcome. They’re preparing for a range of possibilities. Amid this environment, private investments have garnered more attention as a potential tool to build portfolio resilience across various potential outcomes.

But those potential benefits must be weighed carefully against the illiquidity, manager-selection risk, and operational demands that private investments can introduce, particularly for nonprofits with limited internal capacity.

The Trade-Offs: What to Watch

Private investments can offer meaningful benefits, but they are not appropriate for every organization or every dollar. Nonprofit leaders should be aware of several key trade-offs.

For nonprofits, this burden is not just conceptual—it is operational. Private funds often require organizations to manage capital calls on tight timelines, review and execute subscription documents, coordinate with legal and tax advisors, and absorb delayed tax reporting due to K-1s. These demands can place additional strain on lean finance teams, especially when an organization is utilizing multiple managers or strategies at once.

In practice, the question is not only whether a private investment is attractive on paper, but whether the nonprofit has the staff capacity, systems, and outside support to administer it effectively.

A Closer Look at Private Credit

Recently, private credit (and specifically, lending directly to companies) has received particular attention, with headlines questioning the asset class’s overall stability. But it’s important to separate broad trends from specific areas of concern.

Not all aspects of the private credit market are experiencing the same dynamics, says Kevin Van Buskirk, CAPTRUST senior manager of investment research. “The headlines are getting a lot of attention, but the data doesn’t point to widespread problems.”

Much of the recent volatility in private credit has been concentrated in semi-liquid funds designed for retail investors, says Van Buskirk. These vehicles allow periodic redemptions, which can create stress when many investors try to withdraw money at once, as has happened in the past few months.

In other words, the problems caused by recent withdrawals were more about the structure of the investment vehicles and their unique redemption characteristics than about the underlying credit quality of the asset class. The core institutional private credit market—where most nonprofits invest—has remained relatively stable and has not experienced the same level of outflows as the semi-liquid, retail-oriented funds that are making headlines.

At the same time, private credit is not without risk. Several areas warrant attention.

  1. Increased payment-in-kind (PIK) interest, where borrowers defer cash payments
  2. A rise in loans being placed on manager watchlists
  3. Greater scrutiny of specific sectors, particularly software

On that last point, Van Buskirk cautions against broad generalizations. “There’s a clear distinction between higher-quality and lower-quality software names,” he says, noting that artificial intelligence may affect some business models more than others.

In other words, the risks are real, even if they are not uniform. “There are a few areas of concern that people need to do their due diligence on,” says Van Buskirk.

Why Manager Selection Matters

One defining feature of private investments is the wide dispersion of returns. Outcomes can vary significantly depending on the manager, strategy, and timing.

This makes manager selection especially important. In private credit, for example, understanding underwriting standards, sector exposure, and portfolio construction is critical in distinguishing between more and less resilient investments.

Here, experience and due diligence acumen matter most. Two funds that look similar on paper can produce very different outcomes, which makes it essential to work with managers who demonstrate consistent underwriting, discipline, and a repeatable process.

Governance: The Deciding Factor

Across all aspects of private investing, governance plays a central role. In this context, governance extends beyond broad oversight from a board or investment committee. It includes a clear investment policy statement, defined decision-making authority, disciplined due diligence, liquidity planning, operational processes for handling capital calls and documentation, and coordination across finance, tax, audit, and legal functions.

For nonprofit investors, governance also includes execution. A sound policy framework is key, as is the team’s ability to respond to capital calls, monitor cash needs, keep documentation current, and manage tax and audit timelines that may be affected by private fund reporting. Without those processes in place, even a well-designed allocation can become difficult to implement.

Of course, strong governance won’t eliminate uncertainty, but it can help an organization stay disciplined during periods of stress.

“The goal is to create a framework to evaluate what we do know, rather than letting uncertainty overwhelm the decision-making process,” says James Stenstrom, CAPTRUST senior director of institutional portfolios.

In practice, strong governance around private investments usually includes:

“In uncertain markets, governance does some heavy lifting,” says Stenstrom. “The clearer the framework, the steadier the decisions will be.” For many nonprofits, that framework may include an experienced advisor or an outsourced chief investment officer (OCIO) to help guide decisions and support ongoing oversight.

The Bottom Line

Perhaps the most important takeaway for nonprofit leaders is balance. It’s easy for headlines to shape perceptions, whether those headlines are currently focused on market stress, market upswings, or emerging risks. But the underlying reality is often more nuanced. For nonprofits, this reinforces a familiar principle: investment decisions should be grounded in long-term objectives, not short-term noise.

Private investments can be a valuable tool—but they require patience, discipline, and thoughtful oversight. For some nonprofits, the benefits may justify those demands. For others, especially organizations with tighter liquidity needs or lean internal resources, a smaller allocation—or no allocation at all—may be the more prudent choice. The right answer depends not only on return objectives, but also on governance readiness and the organization’s ability to manage the practical realities that come with private funds.

*Based on how the rule was written, it appears to apply only to those with FICA earnings above the threshold and would not affect self-employed individuals.

Those who were previously maxing out their plan using pre-tax contributions are the most impacted. Because the $8,000 catch-up contribution for 2026 can no longer be made pre-tax, taxable income will increase. For someone in the 24 percent marginal tax bracket, this could result in approximately $1,920 in additional federal taxes, assuming no other changes. Overall, this shift is expected to increase the tax liability of many high earners, regardless of how they adjust their contribution strategy.

Roth vs. Taxable

Now that the rule is in force, the most common question is what high earners should do. Should they continue making catch-up contributions as Roth, or stop making catch-up contributions altogether and instead direct those dollars to a taxable brokerage account? 

First, consider the options from a current-year tax perspective. In both scenarios, contributions are made with after-tax dollars or otherwise included in taxable income. This means neither approach would change the individual’s current tax liability.  

Next, compare the potential long-term benefits, starting with Roth catch up contributions. Assuming the contribution limit remains the same, contributing $8,000 per year for five years results in $40,000 of total Roth contributions. If this grows at 5 percent over 10 years, the balance will be approximately $81,178. Because the funds are held in a Roth account, the entire balance could be withdrawn tax-free through a qualified distribution.

If the same $8,000 annual contributions were instead directed to a taxable brokerage account over the same time frame, the account would have a $40,000 cost basis. Assuming the same 5 percent growth rate, and ignoring taxes for simplicity, the account would also grow to approximately $81,178. However, the $41,178 of investment growth would be subject to capital gains taxes when the investments are sold. At a long-term capital gains rate of 15 percent, taxes on that growth would be roughly $6,176. If taxes were paid from this account, the usable account balance would be $75,000.

Planning Considerations

Overall, the initial income tax impact occurs regardless of which option the high earner chooses. There are certainly other factors besides current and future income tax impact that should be considered as well, but there is no reason to not utilize the Roth catch-up based upon the income tax impact.

As a final consideration, if the individual has not already maximized other available pre-tax accounts, such as a health savings account (HSA), those options should be evaluated first. Pre-tax contributions reduce current taxable income in a similar way catch-up contributions previously did. Assuming no additional pre-tax vehicles are available leveraging the Roth catch-up contribution generally provides the most favorable long-term outcome.

Resource by the CAPTRUST wealth planning team.

Source:

https://www.irs.gov

Click here to take the survey.

Survey Details

By participating, you contribute to a peer-based benchmark that helps nonprofits understand how their practices compare with organizations facing similar challenges. The aggregated findings are shared in a complimentary report designed to inform board discissions, policy decisions, and long-term planning.

Who Should Take the Survey?

The survey is intended for CEOs, executive directors, and senior leaders (investment or board committee members or chairs) who have deep knowledge of its mission, operations, and emerging trends in the nonprofit industry.

For more information on CAPTRUST privacy policy, please visit here.

The initiative is designed to help millions of uncovered workers take advantage of the upcoming federal Saver’s Match program, which will provide government matching contributions beginning in 2027. There are no new requirements for employers under this executive order.

What Was Announced?

The executive order directs the U.S. Department of Treasury to develop a new online marketplace that will allow individuals to search for and enroll in private-sector IRAs.

Details:

What Does This Mean for Plan Sponsors?

Background: The Saver’s Match 

The Saver’s Match is an optional provision of the SECURE 2.0 Act that replaces the existing Saver’s Credit with a direct federal contribution to a participant’s retirement account, including IRAs and employer-sponsored retirement plans.

Primary Features:

The executive order may prompt questions from employees about whether they can receive the same federal match through their employer-sponsored retirement plan or whether participation in the IRA marketplace is required to qualify. It may also create additional engagement opportunities for plan sponsors to highlight their existing employer match structure.

Source:

www.whitehouse.gov/presidential-actions/2026/04/promoting-retirement-savings-access-for-american-workers-by-establishing-trumpira-gov/

The 1975 five‑part test framework reinforces that not every party interacting with plan participants is acting as an ERISA fiduciary. In this environment, plan fiduciaries should focus on understanding who is providing advice, in what capacity, and how potential conflicts are identified and managed.

Overview

With the 2024 Retirement Security Rule removed from the Code of Federal Regulations, determinations of fiduciary responsibility for participant investment advice, such as rollover recommendations, have reverted to the DOL’s original five‑part test.

Under the five-part test framework, a person is considered an ERISA investment advice fiduciary only if all five elements are satisfied, or if fiduciary responsibility is explicitly established by contract:

  1. The advice relates to investments.
  2. The advice is provided on a regular basis.
  3. The advice is given pursuant to a mutual agreement or understanding.
  4. The advice is intended to serve as a primary basis for investment decisions.
  5. The advice is individualized to the plan or investor.

This means fiduciary status is not automatic and may vary depending on the nature, frequency, and context of the interaction.

Regulatory Uncertainty Has Increased, Not Decreased

Although vacating the rule restores the original five‑part test, it does not provide long‑term certainty around standards of care or the management of conflicts in retirement advice. Over the past decade, fiduciary definitions and expectations have shifted repeatedly through a series of court decisions and regulatory initiatives, reinforcing that reverting to an older standard does not eliminate the potential for future change.

While the DOL has indicated that it has no immediate plans to pursue replacement regulations, future changes remain possible under a new administration. As a result, plan fiduciaries should expect continued discussion of participant‑level advice, particularly as it relates to rollovers and distributions.

Practical Considerations for Plan Fiduciaries:

  1. Understand who is interacting with plan participants—and in what capacity.
  2. Identify which service providers engage directly with participants.
  3. Clarify when those interactions fall within the ERISA fiduciary standards of care and when they do not.
  4. Review agreements and disclosures.
  5. Confirm that fiduciary roles and responsibilities are clearly documented.
  6. Review how compensation arrangements and potential conflicts related to recommendations are disclosed.
  7. Review rollover activity.
  8. Understand how rollover options are presented to participants.
  9. Confirm whether service providers are acting as fiduciaries or as educators when discussing rollovers.
  10. Monitor patterns or trends over time that may warrant further review.

Source:

www.dol.gov/

Please consult ERISA counsel regarding the application of the five‑part test and fiduciary obligations to your specific facts and service relationships.

Proposes Broad Framework for Plan Investment Selection–Including Alternatives

Implementing Executive Order 14330, the U.S. Department of Labor (DOL) has issued a proposed regulation creating a framework for retirement plan fiduciaries to meet ERISA’s prudence requirements when selecting investments. The executive order was limited to making alternative investments, such as private market debt and equity and digital assets, available in retirement plans. Even so, the DOL’s guidance broadly addresses the selection of all investments for 401(k), 403(b), and other individual account plans.

Importantly, the proposed regulation does not endorse the use of any particular types of investments. It also leaves undisturbed the fundamental rule that plan fiduciaries are responsible for curating an investment menu appropriate for their plans and for monitoring plan investments over time. The proposed regulation identifies six factors that should be included in the consideration of plan investments:

  1. Investment performance      
  2. Fees and expenses
  3. Benchmarking
  4. Liquidity
  5. Valuation
  6. Complexity

The first three factors will be familiar to fiduciaries whose plans offer investments commonly used in 401(k), 403(b), and other individual account plans. The other three are more relevant to consideration of alternative investments and are rarely an issue with more traditional investments.

The proposed regulation sets out real-life examples, demonstrating how these factors should be used, and characterizes following the examples as creating a safe harbor for plan fiduciaries. The proposed regulation says that if plan fiduciaries demonstrate they have dutifully considered these factors, courts should defer to their decisions. However, the DOL cannot mandate how courts interpret ERISA. Therefore, while courts may consider the DOL’s guidance, they are not bound by it. For plan fiduciaries considering whether alternative investments are appropriate for their plans, and their plan participants, some practical considerations include the following.

Lawsuits Challenging 401(k) Plan Fiduciaries: New Developments

Cases continue to be filed against the fiduciaries of 401(k) and other individual account plans. Many lawsuits make what are now garden-variety claims of overpayment for investments or services or for retaining underperforming investments. However, there were also some less common claims and outcomes this quarter.

Is Reasonableness Required? Cases Challenging Pension Actuarial Assumptions Reach Opposite Results

Since 2018, a number of lawsuits have been filed alleging that certain pension plans paid improperly low benefits to some pensioners and their survivors by using incorrect actuarial assumptions.

When an alternate benefit is elected (which frequently means an early or joint and survivor benefit) rather than a standard lifetime benefit, participants and their beneficiaries are entitled to benefits with a value that is actuarily equivalent to the plan’s standard benefits. Actuarily equivalent benefits are calculated using mortality tables and interest-rate assumptions. The lawsuits in this area allege that either outdated mortality tables or incorrect interest-rate assumptions were used to calculate the alternate benefits, resulting in benefits that are not actuarily equivalent to the standard benefit.

Two district court decisions in the Seventh Circuit were decided in favor of their respective plan sponsors, holding that ERISA does not require the use of reasonable assumptions in the calculation of actuarily equivalent benefits. Rather, those courts decided that the assumptions built into the respective plan documents should be followed, regardless of their reasonableness. The U.S. Court of Appeals for the Seventh Circuit recently reversed those decisions, finding that the phrase “actuarily equivalent” implies reasonable assumptions must be used. This was a 2-to-1 decision. The dissenting judge noted ERISA does not specifically require the use of a reasonable assumption in this area, although it does in others. Reichert v. Kellogg (6th Cir. 3.16.2026).

Underscoring the uncertainty in this area, four days after Reichert v. Kellogg was decided, a district court in Missouri (in the Eighth Circuit) came to the opposite decision: that reasonable assumptions are not required in the calculation of actuarily equivalent benefits. Landel v. Olin Corp. (E.D. Mo., 3.20.2026).

Plan sponsors with questions about actuarial equivalence should contact their attorneys and actuaries.

DOL Announces Enforcement Priorities

In an unusual move, the DOL has issued Field Assistance Bulletin No. 2026-01, directed to internal DOL personnel and DOL field offices, updating its enforcement priorities. Consistent with other recent initiatives, this bulletin appears to favor fiduciaries who employ a thorough and diligent governance process. The stated priorities are as follows:

  1. Focusing on the most egregious conduct and most significant harm. The DOL intends to focus primarily on fiduciary loyalty breaches, targeting individuals and organizations that act in bad faith by enriching themselves or others at the expense of plan participants. Suspected breaches of prudence will take a back seat to suspected breaches of loyalty.
  2. The DOL will not regulate through enforcement actions. Instead, it will give clear advance notice of its interpretations of ERISA and of fiduciary responsibilities. Novel legal theories or ERISA interpretations of ERISA should not be first articulated through enforcement actions.
  3. A centralized review of all significant enforcement activities. This will help ensure coordinated nationwide positions that are consistent with DOL leadership’s views. This will be implemented through advance reporting to DOL leadership of significant enforcement activities, including settlements and corrective actions.
  4. Responsive and timely enforcement. This will be implemented through the imposition of an 18-month timeline to conduct enforcement activities, unless complexity warrants a longer (30-month) timeline. Investigations taking longer than the target timelines will be reviewed quarterly by the Director of Enforcement.

Beneficiary Changes Must Follow the Plan’s Procedures—No, Really

A plan participant was divorced and sent a fax to his employer’s human resources department directing that his former wife should be removed as the beneficiary of his 401(k) plan account. In the fax, the participant asked that the human resources department send him any paperwork he would need to complete in order to make the change. No additional action was taken by the participant.

Following the participant’s death, a dispute arose over whether his former wife or the participant’s estate should receive the plan benefits. The district court awarded the benefits to the participant’s estate, finding that the fax directing the beneficiary change was in substantial compliance with the plan’s beneficiary-election procedure. On appeal, the district court decision was reversed.

Although the appellate court agreed that the substantial compliance doctrine exists under ERISA, it found that sending a fax, rather than completing the plan’s change of beneficiary form, did not substantially comply with the plan’s required procedure. In its decision, the court cited several other cases where the correct form had been used but improperly or incompletely completed, and substantial compliance was found. Packaging Corporation of America Thrift Plan for Hourly Employees v. Langdon (7th Cir. 2026).

Investment advisory services offered by CapFinancial Partners, LLC (“CAPTRUST” or “CAPTRUST Financial Advisors”), an investment advisor registered under The Investment Advisers Act of 1940.

Federal income tax changes tied to 2025’s One Big Beautiful Bill Act have reshaped the charitable deductions landscape—not by removing incentives, but by rewarding donors who plan ahead.

For endowment, foundation, and nonprofit leaders, this creates a timely opportunity to help donors understand what’s changing before the next giving year unfolds, and to position your organization as a steady, trusted partner in that process.

Read on for important information to share with donors to help them maximize their giving in 2026.

1. Every Donor Gets a Deduction, but Itemizers Face a New Hurdle.

What changed:

Previously, only donors who itemized could claim a charitable deduction. The new rules extend a limited deduction to standard filers and introduce a minimum giving threshold for itemizers.

Why it matters:

For many small and mid‑level donors, this is the first time in years that charitable giving carries a direct tax benefit that impacts their AGI as an above-the-line deduction. At the same time, for higher‑income donors, tax benefits now activate only after the 0.5 percent threshold is cleared.

What to know:

Under the new rules, giving may need to be more intentional. Donors who understand the new thresholds will be better positioned to give confidently and avoid surprises at tax time.

2. Bunching Now Has New Relevance.

What changed:

While bunching (the practice of combining multiple years of charitable giving into one year) was always a planning option, the new rules make it more important because donors must exceed a minimum giving level before itemized deductions apply.

Why it matters:

For donors hovering near the AGI threshold, bunching gifts into a single year may be the most effective way to preserve tax efficiency without increasing total giving.

What to know:

3. QCDs Are Still One of the Most Effective Tools Around.

What changed:

Nothing—and that’s exactly why they matter. Qualified charitable distributions (QCDs) were not subject to itemized deduction limits before.

For donors between age 70 1/2 and their required begin date, QCDs from individual retirement accounts (IRAs) can reduce future required minimum distributions (RMDs) and, therefore, could reduce income taxes over their lifetimes.

For donors at or above RMD age, QCDs from IRAs can satisfy current RMDs while supporting charitable causes.

Why it matters:

Because QCDs are paid directly from an IRA to a qualified charity, they are considered an above-the-line deduction, and, therefore, continue to be one of the most tax efficient ways to give for eligible donors.

What to know:

For many older donors, QCDs now stand out even more clearly against an otherwise more complex giving environment.

4. The New Rules Reward Planning Over Autopilot Giving

What changed:

Previously, donors could rely on habitual or evenly paced giving and still receive tax benefits. However, the new framework favors donors who intentionally plan the timing and structure of their gifts.

Why it matters:

This shift is both behavioral and technical. Donors who pause, plan, and coordinate their giving with broader financial goals are now more likely to see tax benefits.

What to know:

This creates an opening for earlier conversations, fewer last-minute decisions, and more durable donor relationships built around shared goals rather than transactions.

For nonprofits, it’s a chance to move upstream, from year-end appeals to year-round partnership.

What to Say When Donors Ask About 2026 Taxes

When donors ask about taxes, they’re not always looking for technical answers. Often, they want reassurance—and guidance on how to give thoughtfully under new rules.

These conversations don’t require tax advice. They benefit most from clarity, framing, and an invitation to plan.

Nonprofits can be planning partners without giving financial or tax advice. Donors like to know what works best for the organizations they support so they can have a bigger impact.

Often, the most helpful thing you can offer isn’t an answer but an invitation to plan early and move forward intentionally. By focusing on timing, intention, and partnership, nonprofits can help donors transition from reactive, spontaneous giving to thoughtful longer-term planning.

Sources:

www.irs.gov

If you’ve spent any time with a retirement plan committee, you already know this truth: most good fiduciary decisions aren’t flashy. They’re incremental, detail‑oriented, and occasionally unglamorous. Collective investment trusts (CITs) fit squarely into that category.

CITs aren’t new. They’ve been around for decades. Yet for many plan sponsors, they still feel mysterious, or at least more complicated than they need to be. That’s unfortunate, because when used appropriately, CITs can be a powerful tool for improving participant outcomes without increasing fiduciary risk.

Let’s start with the basics.

What is a CIT, Really?

A CIT is a pooled investment vehicle maintained by a bank or trust company. Unlike mutual funds, CITs are not registered with the SEC under the Investment Company Act of 1940. Instead, they’re regulated by banking authorities and available only to qualified retirement plans (those that meet IRS and ERISA requirements). 403(b) plans currently do not allow them, although there is legislation in the works that could change that. Also, regulations prohibit CITs in private, tax-exempt 457(b) plans. And, even if legally permitted, CIT providers can elect not to offer CITs to certain retirement plans.

From a participant’s perspective, a CIT often looks and behaves like a mutual fund. It has a stated objective, a professional investment manager, daily valuation, and performance reporting. The key differences happen behind the scenes.

Why Plan Sponsors Use CITs

The most common reason sponsors consider CITs is cost. Because CITs don’t carry the same regulatory, marketing, and distribution expenses as mutual funds, they can often be offered at lower expense ratios. In a world where every basis point still matters, that’s not nothing.

But cost alone shouldn’t drive the decision. Well-structured CITs can also offer:

Importantly, none of these benefits are automatic. A poorly structured CIT is no better than a poorly chosen mutual fund. Fiduciary process still matters, and cheaper isn’t always better when looking at performance.

The Trade-Offs

CITs are not perfect, and pretending otherwise is a fiduciary mistake. Because CITs are not SEC‑registered, they don’t produce a prospectus. Instead, sponsors and participants rely on a declaration of trust and fact sheets. This places more responsibility on committees to ensure disclosures are clear, accurate, and participant‑friendly.

Liquidity can also differ. Most CITs are daily‑valued and daily‑liquid, but not all. The distinction matters, particularly as some strategies push into less traditional asset classes.

Performance between a CIT and its mutual-fund equivalent can differ due to a difference in portfolio holdings and cash flows. Plan sponsors should make sure to evaluate performance and portfolio differences before pursuing a CIT alternative.

Finally, CITs are generally not portable outside of qualified plans. That’s rarely an issue for core menu options, but it’s something sponsors should understand before defaulting participants into a structure they can’t take with them.

What’s Different About CITs in 2026?

If the last few years have taught us anything, it’s that retirement plans don’t stand still. In 2026, several trends are shaping how sponsors should think about CITs:

First, customization is becoming mainstream. Custom target‑date CITs, once limited to mega‑plans, are increasingly accessible to mid‑sized sponsors. That raises the fiduciary bar. Custom solutions require custom oversight.

Second, regulatory scrutiny hasn’t gone away. It’s just shifted. While CITs remain a permitted and well‑established vehicle, committees should expect continued focus on fee reasonableness, benchmarking, and documentation. A lower cost only helps if it’s demonstrably prudent.

Third, participant communication matters more than ever. As plan menus incorporate more white‑label and collective options, sponsors must ensure participants understand what they own. Confusion can erode trust.

Finally, innovation is creeping in. Some CIT structures are being used to explore new asset classes or lifetime income components. That doesn’t make them outright inappropriate, but it does mean committees need to slow down, ask better questions, and resist the urge to adopt complexity for its own sake.

The Bottom Line

CITs are not a silver bullet. They are a tool that can be used well or poorly.

For plan sponsors willing to do due diligence, they can reduce costs, improve flexibility, and support better long‑term outcomes for participants. For sponsors looking for shortcuts, they can introduce risk and confusion just as easily as any other investment vehicle.

As always, the fiduciary standard doesn’t ask whether something is popular or innovative. It asks whether it’s prudent, well‑documented, and in the best interest of participants. CITs can meet that standard in 2026, but only if sponsors remember that structure never replaces judgment.

Important Disclosure
This content is provided for informational purposes only, and does not constitute an offer, solicitation, or recommendation to sell or an offer to buy securities, investment products, or investment advisory services. Data contained herein from third-party providers is obtained from what are considered reliable sources. However, its accuracy, completeness, or reliability cannot be guaranteed. Nothing contained herein constitutes financial, legal, tax, or other advice. Consult your tax and legal professional for details on your situation. Investment advisory services offered by CapFinancial Partners, LLC (“CAPTRUST” or “CAPTRUST Financial Advisors”), an investment advisor registered under The Investment Advisers Act of 1940.

On March 30, 2026 the Department of Labor (DOL) released proposed regulations titled “Fiduciary Duties in Selecting Designated Investment Alternatives.”  

It is important to note that this proposal extends beyond alternative assets. Any investment offered within a retirement plan is considered a Designated Investment Alternative (DIA).  

What is it? 

The proposed rule introduces a process-based safe harbor by detailing an objective, thorough, analytical approach that plan fiduciaries can use to demonstrate prudence when selecting plan investments. Building on the DOL’s 1979 Investment Duties regulation, the proposal identifies six core factors for fiduciaries to consider:  

  1. Performance 
  2. Fees 
  3. Liquidity 
  4. Valuation 
  5. Benchmarking 
  6. Complexity 

The proposed regulation discusses alternative assets, including those related to private equity, private debt, private real estate, digital assets, commodities, infrastructure, and lifetime income investment strategies. It outlines examples of how a plan fiduciary could evaluate these investments using the factors above as part of a prudent selection process. The proposal does not require plan fiduciaries to include or consider alternative assets. Traditional investment menus remain acceptable. 

Why the Ruling Matters 

The proposed rule reinforces an established principle: serving as a fiduciary does not mean predicting market movements or making flawless decisions. 

ERISA does not expect perfection. It expects a disciplined decision-making process grounded in thoughtful analysis, informed judgment, and the exclusive best interest of participants and their beneficiaries. 

The rule’s investment-neutral approach reinforces the importance of fiduciary discretion and the value of: 

What’s Next?  

The proposed rule now enters a 60-day comment period. 

CAPTRUST will continue to monitor this proposal and share updates as the rulemaking process advances and the regulation is finalized. 

For more information, contact your CAPTRUST financial advisor. 

This content is provided for educational purposes only.  

Source: US Department of Labor proposes landmark rule to democratize access to alternative investments in 401(k) plans | U.S. Department of Labor 

To better understand how donors are navigating the intersection of values, strategy, and uncertainty, CAPTRUST surveyed 154 of our wealth advisors who work closely with clients making charitable decisions every year. CAPTRUST’s core wealth clients are typically individuals and families with complex financial lives and multiple millions of dollars in investable assets.

Their advisors’ responses offer important signals for nonprofit, foundation, and endowment leaders seeking to engage donors more effectively. Here are four key takeaways and what they mean for organizations that rely on philanthropy.

1. Impact Clarity is a Major Barrier to Giving

More than one‑fifth of advisors (21.8 percent) said the biggest barrier preventing clients from giving or giving more is when they feel disconnected from organizations, while 17.7 percent reported that donors hesitate when they don’t see clear impact.

For nonprofit leaders, this highlights a critical gap: Even motivated donors may pause their giving if they can’t easily understand how their gift will translate into outcomes. When impact feels abstract or buried in complexity, donor confidence erodes.

Advisors also cited economic or personal financial uncertainty as a factor preventing clients from giving or giving more (42.2 percent). These findings suggest donors want ample reassurance on two fronts: reassurance from their financial advisor about what they can afford to give and reassurance from nonprofits that their gifts are being used effectively. Transparent communication and credible impact reporting can help.

2. Donors Want Better Communication, But Not More of It

When advisors were asked what type of nonprofit engagement their clients value most, 44.5 percent selected “clear, concise impact updates.” This was, by far, the top response. Preferences for low‑touch engagement (16.1 percent) and family involvement opportunities (16.1 percent) followed, while invitations to events ranked lower (10.6 percent).

At the same time, 8.2 percent of advisors cited “too many solicitations” as a barrier to giving.

Taken together, these data points indicate donors want to understand outcomes but not be overwhelmed by outreach.

For nonprofit leaders, this means prioritizing fewer, clearer touchpoints that focus on results, not process. Impact updates should answer simple questions donors care about. What changed? Who benefited? And why did this gift matter? When organizations lead with clarity and restraint, they make it easier for donors to stay engaged and give with confidence.

3. Operational Readiness Is More Important Than Ever

Advisors report that qualified charitable distributions (QCDs) are the most frequently used giving method (37.7 percent), followed closely by donor‑advised funds (DAFs) at 33.1 percent. QCDs are direct transfers from an individual retirement account to a qualified charity, available for individuals age 70 1/2 and older. DAFs, on the other hand, allow donors to contribute assets to a designated charitable account and recommend grants over time.

Traditional cash gifts, including checks and online donations, still play a role (14.2 percent), as do gifts of appreciated securities (13.2 percent), such as stocks or mutual funds donated directly to charitable organizations.

Planned gifts, including bequests, charitable trusts, and beneficiary designations, along with complex assets, such as real estate or privately held business interests, represent a smaller share.

The takeaway for nonprofit leaders is that operational readiness can be a key differentiator.

Organizations that can smoothly accept non‑cash gifts, understand how QCDs and DAFs function, and coordinate effectively with financial advisors can remove friction at critical moments, making generosity easier for donors to act on.

4. Purpose Remains the Primary Motivator

When asked what most strongly motivates their clients’ charitable giving, 60.8 percent of advisors pointed to “supporting causes their clients care deeply about,” while another 19.6 percent cited community or faith‑based connection. By contrast, just 15 percent identified tax efficiency as the primary driver.

In practice, this suggests that tax planning rarely initiates generosity. Instead, giving begins with purpose; tax strategies tend to serve as a secondary benefit once intent is already established.

Mission clarity and emotional resonance are still the foundations for fundraising success. Organizations that can articulate why their work matters, and who it helps, are better positioned to inspire generosity, regardless of the tax environment. The bottom line is that donors today are thoughtful and increasingly strategic. Nonprofits, endowments, and foundations that can combine emotional resonance with operational excellence—and communicate their impact clearly and concisely—can earn trust, deepen relationships, and inspire sustained generosity.