How to review your 401(k) provider
When problems keep coming back, it's time to ask who is helping, who is responsible and what needs to change.
Start with what is not working.
You keep chasing an answer. Payroll and your plan provider point fingers. An employee cannot get help. Start there: what happened, who is affected and what still needs to be fixed?
Write down the open issues. If employee money, benefits or required paperwork could be affected, get help from your plan administrator and advisers right away. Do not wait for a provider review to address the problem.
Do you have the right help?
Some plans get several services from one provider. That is often called “bundled.” Others use separate providers, including a third-party administrator, or TPA, for help running the plan. Either setup can work.
Ask who handles plan rules, testing, paperwork, payroll questions and employee requests. A separate TPA may help when your plan needs more specialized support. But adding a provider only helps if everyone knows who does what. Check that the agreements match what you expect.
Know what you pay and what you get.
When did you last compare your plan with other options? Look at provider fees, investment costs and the help included. Check for extra charges and make sure each proposal covers the same work.
Main to Mill uses provider quotes, market data and Graham's experience to compare costs and services. Our fee benchmarking gives you a side-by-side cost and service comparison with recommendations. It may also turn up ways to improve plan rules or investments. We agree on that work separately from the initial review.
Sources: 1
Who is responsible for what?
Fiduciary roles, in plain English.
A fiduciary has a legal duty to put the people in the plan first and make careful decisions. These numbers come from retirement-plan law. Here is what they mean for an employer.
3(16)
Running the plan
This is the plan administrator’s role. An outside provider can take responsibility for agreed tasks, such as notices and filings. Check which jobs they own and which are still yours.
A TPA that helps with paperwork does not automatically take on this responsibility. Check who your plan names as administrator.
What do you handle, and what do we still need to do?
3(21)
Helping you choose investments
When advisers use this label, they usually mean they recommend investments and you make the final decision.
The law uses 3(21) more broadly to define who is a fiduciary. It also includes a 3(38) manager. The work someone does matters more than the label.
Do you make recommendations, or make the decisions?
Sources: 2
3(38)
Making investment decisions
You put a qualified investment manager in charge of the investments covered by your agreement. That can include choosing, reviewing and replacing the plan’s funds. The manager accepts fiduciary responsibility in writing.
This does not automatically include plan paperwork or choosing investments for each employee. You still need to choose the manager carefully and review their work.
Which decisions will you make, and how will you keep us informed?
Where Main to Mill fits.
Graham leads your plan review and stays your point of contact. Navigate 401K, LLC can serve as a 3(38) investment manager when engaged to do so. Your agreement names who takes on that role and which investment decisions they handle.
Your plan still needs people to handle paperwork, payroll and employee questions. We look at how those pieces fit together and where you may need more help.
What to gather before we talk
Gather your provider agreements, fee information, list of investments and notes from your last review. Add your open questions and any changes to your business. Missing something? We can help you work out what to ask for.
We start by talking through what needs attention. You receive a written report to help you decide what comes next. If you need a side-by-side fee comparison, a provider search or ongoing help, we agree on that work separately.
Sources behind this guide.
- Department of Labor: Selecting and monitoring service providers
- ERISA §3: Administrator, fiduciary and investment-manager definitions (29 U.S.C. §1002)
- Department of Labor interpretive bulletin: Ministerial tasks and plan administrators (29 CFR §2509.75-8, D-2 and D-3)
- Department of Labor: Delegation, monitoring and fiduciary liability
- ERISA §404: Fiduciary duties (29 U.S.C. §1104)