Origin Story
I began my career in public accounting after graduating from the University of Illinois at Urbana-Champaign in 2000. I knew immediately upon starting my first assignment that I was in the wrong profession. It just sucked the life out of me. I eventually transitioned into a financial advisory role, where I found the work much more interesting. I had always enjoyed investigative work, and I was interested in finding a way to combine that with my financial knowledge.
In 2005, a couple of years into my career as a financial advisor, a colleague told me that retirement-plan Form 5500 filings were publicly available. I couldn't believe it and thought there could be a unique opportunity to investigate. But I didn't know what to do with that information initially.
Then, in 2009, I decided to start looking at the filings and calling business owners to tell them what I was finding. I thought I'd be a hero for pointing out that their retirement plan participants—including themselves—were getting ripped off.
Instead, I repeatedly heard some version of:
“We're not paying anything. My friend handles the plan and looks over everything.”
Yet the publicly available filing would show compensation being paid to that same person—often in amounts the employer had never understood they were paying.
After enough of those conversations, I started to feel like I was fighting retirement plan crime.
That criticism wasn't always welcomed. On several occasions, administrators, advisors, and recordkeepers whose clients' plans I had criticized responded with threatening phone calls and emails. In one instance, two people from the same organization contacted me, and one told me he was going to “run me out of the business.” On other occasions, organizations whose clients' plans I had scrutinized asked that I be placed on do-not-call or do-not-solicit lists. Even my own firm eventually told me I could no longer criticize an approved vendor or use Form 5500 filings as a prospecting tool.
Those experiences revealed a deeper problem than employers simply lacking information. The information was often available, but employers weren't necessarily experiencing their retirement plan as a purchasing decision. I also began to see how deeply embedded relationships among advisors, recordkeepers, administrators, and other providers could create conflicts that made it difficult for an advisor to challenge an existing arrangement objectively.
My own firm's instruction that I could no longer criticize an approved vendor or use Form 5500 filings as a prospecting tool made that conflict particularly clear to me. The firm wasn't simply providing resources I couldn't access on my own; it was also charging me for the affiliation while restricting the very investigative work that had become central to what I wanted to do.
The threats I received from multiple parties also showed me how difficult it could be for an independent advisor to challenge an established arrangement. Larger and more established firms had much more power to push back. In some cases, multiple parties connected to the same plan responded to the same scrutiny, which made me question whether they were protecting their relationships with one another rather than engaging with the issues I had raised.
That ultimately led me to become an independent registered investment advisor. I wanted the freedom to investigate retirement plans, criticize providers when warranted, use publicly available information, and structure my services in a way that I believed was appropriate for retirement plans, without someone else pulling my strings.
Since then, I have helped employers evaluate retirement plans with the same scrutiny they apply to other professional service relationships. Over the years, I have reviewed thousands of Form 5500 filings and documented thousands of conversations with employers. I have tracked provider compensation, services, plan characteristics, and purchasing decisions to better understand how these relationships work in practice and how they change over time.
Those observations have been organized into a proprietary database, giving me a longitudinal perspective on retirement-plan provider compensation and the way employers purchase, evaluate, and monitor these services. That perspective matters because a single year's fee tells only part of the story.
What was the plan paying three years ago? What is it paying today? When did compensation change? What changed in the services or circumstances of the plan? Did the amount of work change? What level of expertise was required? And did the additional compensation correspond to something the plan actually needed?
I'm not suggesting that every professional should always charge by the hour. A professional can appropriately charge a fixed fee for a defined scope of work. But understanding the time, expertise, and services involved provides a useful reference point for evaluating whether the economics of a professional-services relationship make sense.
The same principle applies to the retirement plan as a whole. Financial advisors, recordkeepers, third-party administrators, investment platforms, and other providers each play a role. Understanding who is being paid, how much they are being paid, what they provide, and how those relationships have changed over time gives an employer a much clearer picture of what the plan is actually buying.
My work therefore extends beyond identifying a fee that appears high or recommending that a provider be replaced. Sometimes the existing arrangement is appropriate. Sometimes compensation can be negotiated. Sometimes services or expenses can be restructured. Sometimes a provider should be replaced. And sometimes the best decision is to do nothing. The objective is to understand the arrangement well enough for the employer to make an informed decision.
That focus is the foundation of my practice today. The retirement plan is my client. I provide independent, fixed-fee retirement-plan consulting and one-time evaluations designed to help employers understand what they are paying, what they are receiving in return, and whether the arrangement continues to make sense for the plan.
Outside of my work as a retirement plan crime fighter, I curate small gatherings that bring interesting people together around thoughtfully sourced food, good conversation, and relationships that continue to develop over time.
My Philosophy as a Forensic Consultant
In the retirement plan industry, financial advisors typically charge asset-based fees and argue that they need to charge this way because they are “managing” the account. But in most participant-directed plans, they aren't actually making the investment decisions in participants' accounts. Instead, they typically choose a cookie-cutter fund lineup, rarely if ever make changes, and wait for participants to contact them.
They attempt to justify their fee structure and management services by misleadingly touting the value of selecting the investment options, acting as a fiduciary, and providing vendor search and benchmarking services. In reality, technology has commoditized their services, resulting in advisors often being significantly overcompensated at the participants’ expense which is rarely evident to either the participants or employers.
The real value lies in advisors taking the time to meet with participants and help them figure out how to determine an optimal retirement plan contribution level, create and monitor a budget, determine an investment risk level that makes sense, effectively allocate contributions between a Roth or traditional 401(k), and implement a debt repayment plan if applicable.
With regard to fiduciary services, simply having a fiduciary on the plan doesn’t mean much. The fiduciary needs to actually add value by taking actions such as constructing an investment policy statement, documenting plan sponsor and participant phone calls and meetings, and establishing an investment committee.
Just like any other service professional, the advisory fee should be based on time and value rather than a fee based on the value of the assets, which has no bearing on the value or level of services provided. Ideally, the employer should consider paying reasonable advisory fees directly. This can make the cost more visible to the party responsible for purchasing the service, potentially provide a business tax deduction subject to applicable tax rules, allow more participant assets to remain invested, and put the employer in a better position to evaluate and compare the true cost of the services.
My own advisory model follows the same purchasing discipline I believe retirement plans should apply: compensation is stated in dollars, services are defined, work is documented, and the relationship can be evaluated based on what is actually being provided.
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