Pre-election uncertainty was clearly experienced among the country's roughly 60 million participants in 401(k) plans. Trading in plans administered by Aon Hewitt hit all-time highs the day after Donald Trump's surprise victory.

Related: Day-after-election 401(k) trading hits all-time high

Overwhelmingly, participants who chose to reallocate—some would say trade—on the election sought safety, as 81 percent of assets were moved from equity holdings to fixed income.

At Empower Retirement, measures were taken in anticipation of overwhelming participant call volume.

Empower's roughly 600 call center reps were fortified with 200 extra employees from management and other areas of the company to help field participants' inquiries—what an Empower representative described as an all-hands-on-deck approach.

By midday November 8^th—just hours after Hilary Clinton conceded the election–reps at Empower were outfitted with a two-page primer explaining what a retirement investor should do in light of President-elect Trump's unexpected victory.

The messaging offered conventional stay-the-course wisdom for 401(k) investors: "Resist the knee-jerk reaction to sell investments or time this market"; "The largest upward movements in stock prices often occur at the bottom of market declines"; "Avoid behavior that is hazardous to your wealth. Selling investments after they have experienced significant declines can be the worst mistake most investors make next to not contributing enough to their retirement plan."

Related: Retirement plan providers consider DOL fiduciary rule's asset retention effects

The paper made a soft recommendation for professional management in the form of target-date funds and risk-based asset allocation funds as a way to assure discipline in the face of market volatility.

Education or advice under the fiduciary rule?

Empower's outreach last November raises questions as to what type of advice will be offered through call centers under the fiduciary rule.

Related: What is fiduciary investment advice under the DOL fiduciary rule?

"As part of our service to participants the team at Empower is always trying to anticipate the next market event that might result in the need for clear and concise communication from our experts," said Edmund Murphy, president of Empower Retirement.

"It's an uncertain world — and always has been– but we believe that we can mitigate participant anxiety by providing a reassuring voice. We always counsel participants to speak to their advisor if market events cause them to want to rethink their retirement plan," he added in a statement to BenefitsPro.

Across the industry, recordkeepers are preparing to implement new procedures to comply with the rule, in spite of speculation that it will either be delayed or rolled back under the Trump administration.

Any advice to buy, sell, or hold a security is considered a fiduciary act under the rule. So is a recommendation to roll assets into an IRA. Trillions of dollars in 401(k) plans stand to be affected in the coming years.

"Different service providers are taking different approaches to comply," said David Levine, a principal at the Groom Law Group. "Some are preparing to be fiduciaries on everything, including rollover and distribution advice. Others will only offer general education to participants to avoid liability."

And others are balancing their approach between those extremes, says Levine. Some service providers are willing to accept fiduciary responsibility for advising participants on how to allocate accounts, but straying from offering advice on rollovers.

"There are no hard and fast rules as to how service providers will choose to comply. Each one will be different," said Levine.

The final rule's education carve-out differentiates generic, ongoing education to participants from direct fiduciary advice.

"There are clear ways to provide information that won't rise to the level of fiduciary advice," said Pat DiCarlo, a partner at Alston & Bird.

Explaining the dangers of timing markets to participants is one example, noted DiCarlo.

"If you are providing information to more than one person then it generally won't met the standard of fiduciary advice," he said.

DiCarlo and other attorneys consulting with service providers have advised clients to equip call center reps with scripts for specific scenarios with participants.

Related: 5 providers on the DOL fiduciary rule's effects

But in many potential contexts, it will be difficult to draw the distinction between education and advice, thinks DiCarlo.

"You are never going to get past the problem that you can't control every conversation," explained DiCarlo.

While he sees the rule's Best Interest Contract Exemption's requirements on rollover advice as favorable for retirement investors, DiCarlo thinks those providers that limit their call centers to a strict education role risk reducing the quality of service participants can receive.

Related: 4 versions of the Best Interest Contract Exemption

"For the low information participant that just wants help allocating their portfolio, there are restrictions," said DiCarlo. "Translating education into action is going to be difficult for a lot of participants."

New monitoring responsibilities for sponsors

Raleigh, NC-based CAPTRUST, a fiduciary specialist defined contribution advisory, works with more than 90 recordkeepers within its portfolio of plan sponsors.

John Curry, senior director of marketing at CAPTRUST, says providers are "all over the map" in how they intend to manage fiduciary risk under the rule.

Related: DOL chart comparing early fiduciary rule to final fiduciary rule

"There's a game of musical chairs going on in the industry," said Curry. "For providers that are planning to limit themselves to education, we feel that creates an opening for firms like ours."

For the other end of the spectrum, where service providers will provide personalized fiduciary advice on distributions, rollovers, and asset allocation, plan sponsors will have to step up their monitoring responsibilities, says Curry.

"We're hearing questions from sponsors as to what work will be required to monitor service providers that are offering full services," he said. "When you have more fiduciaries touching plans, it places more burdens on sponsors. To some degree, sponsors are shooting in the dark—the fiduciary rule is not really descriptive of sponsors' new monitoring requirements."

In some cases, sponsors will be challenged. Curry provided the example of a 403(b) plan that uses multiple service providers that assume different fiduciary roles.

"Sponsors will have to understand the role of each provider, who the master administrator is, and prove they are delivering consistent services to all of their participants," said Curry. "That's a lot of complexity for the non-profit sponsor of a $30 million plan to take on."

In other cases, sponsors' monitoring responsibilities will be relatively easy to manage. Participant advice on how to allocate assets in a 401(k) account, for instance, "is not particularly scary," said Curry.

But on rollovers and distributions, monitoring responsibilities will be more challenging. "Is the rollover advice subjective, is it quantitative, what data is the provider using to measure differences in fees? Those are difficult assessments, and may be a pretty far bridge for the typical call center rep to cross."

Potential for price disparity

As providers offer different levels of fiduciary service through their call centers, questions remain as to what price disparity will emerge in the market.

"Any time a provider says they are offering a full array of services, they are trying to expand how they are compensated," says James Brewer, founder of Chicago-based Envision 401(k) Advisors.

"That increases the potential for misunderstanding with sponsors," said Brewer. "They are going to have to examine how well they understand their monitoring responsibilities, which will increase with providers that say they will do everything through their call centers."

Presumably, providers that offer fiduciary advice, and assume that risk, will be able to charge more for record-keeping services.

"There may be new price disparity for record-keeping, but we simply don't know that yet," said Curry. "Sponsors are going to have to really drill home on what they are paying for the services they are getting from providers."

Steve Gordon, executive director at The Bogdahn Group, a fiduciary advisory to more than 650 retirement plans, says it is always best to engage service providers that offer the most thorough fiduciary services.

But ultimately, sponsors will have to determine the potential for conflicted advice when service providers put themselves out as fiduciaries.

"If a sponsor hires a service provider that is going to offer direct advice to participants the sponsor needs to ensure that provider has the most thorough fiduciary controls in place," said Gordon.

Using a service provider that limits its fiduciary role could make sponsors' monitoring responsibilities easier to manage.

But it's too early to measure the value of that approach to sponsors and participants, said Gordon.

"We don't know the full effect of these changes yet. For example, will record-keeping costs go down from scaling back the professionals in a call center and adding automation, or go up for providers who can't improve their margins by cross selling products?" said Gordon.

"Unfortunately, this remains to be seen," added Gordon.

Related: See our Fiduciary Rule page for all of our coverage