Most retirement-plan reviews start with a benchmark. I start with questions. Who is being paid? How much? For what? Who is actually paying? Why is the compensation structured this way? What work is being performed? What has changed over time? And would the employer make the same decision if the services were purchased like any other professional service? Here are the forensic questions I ask when I investigate a retirement plan.

After more than 7,000 conversations with people responsible for retirement plans, I’ve learned that the way sponsors think about their advisors may be just as important as the fees they pay. I’ve heard a great deal about trust, loyalty and how much an advisor does for a company, but much less about how sponsors determine whether that compensation is reasonable or whether participants are getting good value.

Most retirement plan participants can't tell you what they pay in fees not only because the disclosures are too complicated, but also because they're written in a language nobody uses to think about money instead of the two languages people actually use, salary and monthly bills. This post traces why fees stay invisible, from General Accounting Office data on participant confusion to the psychology of loss aversion, and rebuilds fee disclosure around two numbers instead: what a fee costs as a pay cut against salary, and what it costs as a bill each month. Real plan data from Chicago area companies shows the two numbers moving independently of each other, and two case studies show where even that framing needs correcting before it tells the truth about who's actually paying.

Retirement plan benchmarking has become more sophisticated than ever, but it still leaves important questions unanswered. Drawing on seventeen years of Form 5500 research, this article explores how the history of provider compensation, participant counts, and purchasing decisions can reveal insights that a single benchmarking report cannot.

Many retirement plan advisors ultimately build their most profitable relationships by managing participants' personal assets. I chose a different path. This post explains why I invoice my work, reject asset-based pricing, refuse rollover business, and believe every advisory practice begins by answering one question: Who is the client?

SECURE 2.0 contained more than 90 provisions and did not address the compensation architecture that determines whether plan sponsors can function as buyers of retirement plan services.

SECURE 3.0 is now in the early drafting stage. Here is a proposed one paragraph amendment to ERISA 408(b)(2), written as actual statutory text, requiring quarterly invoicing of all service provider compensation in dollar terms.

One paragraph added. Multiple provisions simplified or rendered redundant. Better information. Lower compliance burden.

PBM reform and retirement plan fee reform are usually treated as separate policy questions. Structurally, they are the same problem. Both markets have tried disclosure based reform. Neither has produced market discipline. The fix in both is to replace automatic collection with invoicing.