Review retirement-plan participation, fees and payroll controls alongside returns. Understand deposit timing and turn findings into assigned actions.
June 8, 2026 · Financial Forte Staff
Historical article: prepared retrospectively using information available as of June 8, 2026.
A strong year in the market can make a retirement plan meeting feel easy. Account balances rose, employees seem pleased and the investment report looks reassuring. Yet investment performance does not show whether an eligible employee missed enrollment, a payroll contribution arrived late or a service fee changed without anyone noticing.
A useful retirement plan review examines the experience employees receive and the process the employer operates. Returns belong in that discussion alongside eligibility, participation, fees, administration and documented follow-through. For an ERISA plan, a prudent fiduciary process includes monitoring the investments and providers entrusted with plan responsibilities; a good market year does not substitute for that work.[1]
Use measures that answer a decision
Begin by defining each measure. Participation might mean employees making salary deferrals, all employees with an account balance or everyone receiving any contribution. Those are different groups. A rate is useful only when the numerator and denominator are consistent and the committee understands who is missing from the calculation.
Also distinguish an outcome from its possible explanation. A lower participation percentage might reflect newly eligible hires, enrollment delays, affordability concerns or a reporting error. The employer should investigate before concluding that employees have lost interest. Comparing departments or locations can help identify a process issue, but individual financial circumstances should not become unnecessary committee discussion material.
Track a few measures that lead to action: timely eligibility processing, completion of required communications, payroll reconciliation, participation using a defined population and unresolved service requests. Set a review frequency that fits the process. A once-a-year meeting is too infrequent to discover a recurring payroll transmission problem promptly.
Investigate the denominator
Consider a hypothetical company whose plan had 100 eligible employees and 80 people making salary deferrals. Its participation rate was 80%. After hiring, the eligible population grows to 120, while the number deferring remains 80. The reported rate falls to about 66.7% (80 divided by 120), even though no existing saver has stopped contributing.
That does not mean there is no problem. It changes the next question. Were the 20 newly eligible employees given timely information and a functioning way to enroll? Did payroll and the recordkeeper use the same eligibility date? Were any employees entitled to automatic enrollment under the actual plan terms?
After the employer corrects a communication problem, eight of those employees begin deferring. The rate becomes 88 out of 120, or about 73.3%. It remains below the earlier 80%, but the plan has eight more active savers. That is a more informative account of progress than saying the plan still failed to recover its old percentage.
The committee should not presume that every nonparticipant needs the same message. Some may need enrollment help; others may have pressing cash needs or may have made an informed choice. Offer clear information about plan features and available education without presenting participation as a measure of an employee's worth or financial discipline.
Connect fees with services and controls
Request a complete account of what the plan, employer and participants pay. Identify investment expenses, recordkeeping charges, advisory compensation and other service fees, including indirect compensation when applicable. Compare arrangements with reasonably similar services and plan characteristics. The lowest quoted price does not establish that an arrangement is the most suitable.[2]
Suppose this company's hypothetical plan has $5 million in assets and $30,000 in annual fees within a clearly defined review scope. That equals 0.6% of assets ($30,000 divided by $5 million). The calculation makes the cost easier to compare, but it does not prove the fee is reasonable. A quote excluding investment expenses cannot fairly be compared with one including them. Nor does a fee ratio explain whether service failures are being resolved.
For each provider, identify who handles eligibility, notices, payroll files, distributions and error correction. Then compare the service agreement with actual delivery. If the employer believes the provider is reviewing payroll accuracy but the contract only promises to process files received, a responsibility may be left unattended.
Salary deferrals require particular attention. A plan with fewer than 100 participants at the beginning of the plan year can use the DOL safe harbor: qualifying participant contributions and loan repayments deposited by the seventh business day after receipt or the day withheld amounts would otherwise have been paid in cash are deemed timely under this rule. An ability to deposit sooner does not invalidate that safe harbor. Outside it, the general rule requires deposit as soon as the money can reasonably be separated from employer assets; the following month’s fifteenth business day is an outer limit for pension plans, not a routine deadline.[3]
The company in this example began with 100 eligible employees, so it should not assume it qualifies. Eligibility, enrollment and the regulatory participant count are different measures. Have the administrator establish the beginning-of-year participant count and applicable rule, then reconcile every payroll against the actual deposit date.
Leave the meeting with an operating record
A useful committee record identifies the issue, information considered, decision and follow-up responsibility. It should show why a change was made or why an existing arrangement was retained. A thick presentation without recorded decisions creates less practical value than a short, accurate record tied to completed tasks.
Give each open item an owner and completion date, then put unresolved items on the next review agenda. For the hypothetical participation issue, that might include reconciling the eligibility census, confirming corrected communications and checking the next payroll file. For a fee concern, it might involve obtaining missing compensation information before deciding whether a competitive review is needed.
Monitor completion evidence, not just a provider's assurance that an issue is being handled. A corrected file, a reconciled contribution report or a reviewed communication can establish what actually happened. Escalate repeated failures and document the response. Delegating a function does not mean the employer can ignore its responsibility to select and monitor the service arrangement.[1]
Before the next review, choose one question the investment report cannot answer: who was missed, what was paid, which task was delayed or whether a prior correction worked. Answering that question can reduce administrative risk and improve employees' experience while making the committee's time more productive.
Related reading
Have more questions about retirement plan reviews and fiduciary administration? Email Dave at dave@financialforte.com to discuss your questions and next steps.
The contact invitation is current; it does not imply this contact path existed on the historical reference date.
Educational information, not personalized investment, tax, legal or benefits advice. Examples use hypothetical assumptions. Verify current rules and your circumstances before acting.
