An accounting firm with just 10 participants in 2015 and 20 in 2024 paid steadily rising 401(k) fees for years in a way that forfeited a basic tax deduction, revealing a much bigger problem in the system.

Every professional service relationship has an invoice. The invoice describes the work, states the cost, and creates the moment where a buyer decides whether the price is justified. Retirement plan service providers almost never send one — and that single structural fact explains why plan fees have never been subject to real market discipline.

A retirement plan can receive a clean audit opinion even if it embeds hidden compensation, shifts costs onto participants, and includes conflicted provider relationships.

Here’s why.

When a firm with an employee compensation and benefits practice runs a plan where fees grew as participants disappeared, it reveals something important about how the 401(k) system actually works.