Over six years, participants in this plan paid administrative and recordkeeping fees averaging about $112 per person per year. Comparable plans — same industry, same bundled services, similar size — paid about $53. The difference, accumulated across the plan's participants and the review period, comes to roughly $1.6 million in excess fees. Had those dollars stayed invested alongside the rest of the plan — assuming a 6% annual return, stated here because every such assumption should be — the total cost including the growth that money never had the chance to earn is roughly $1.9 million. Both numbers appear in the workpapers; the second is how the industry itself presents fee differentials, because compounding is where fees do most of their damage.
That number is high enough to warrant a hard look. It is not, by itself, proof that anyone did anything wrong — and the second half of this review explains both sides of that sentence.
We reconstructed the plan's fees year by year from its public government filings, tying the plan's own financial statements to the compensation its service providers reported receiving — to the dollar, wherever the filing formats allow. One early year required an estimate (the filings from that year disclose revenue-sharing unevenly); that estimate is labeled in the workpapers, with the exact document named that would replace it with a known figure.
A fee is only "high" compared to something. We used two yardsticks: a published industry survey, and — more telling — a live peer: a real plan in the same industry, of similar size, buying the same bundle of services, whose costs are on the public record. We adjust for what each plan actually buys; a plan purchasing extra services should cost more, and pretending otherwise is how careless reviews manufacture outrage. Against the better yardstick, this plan still paid roughly double.
The overpayment was not uniform. In the most recent three years of the period the case is strong and the records are solid; in the earliest years the disclosure is thinner and the numbers rest partly on the labeled estimate. A careful reader — or an opposing expert — would attack the weakest year first, so the report says plainly which years carry the conclusion and which merely echo it.
Every review we produce includes this section, because high-looking fees sometimes have legitimate explanations. We checked three here: whether the plan bought a broader bundle of services than its peers (it did not, materially); whether the timing of industry-wide repricing explains the gap (it explains a fraction, in the later years); and whether fees were quietly rebated back to participants through the plan's expense account — a mechanism that makes gross fees overstate what participants really bore. The public filings cannot fully rule that last one out; the specific document that would settle it is listed below.
The plan's investment menu itself — the funds chosen and the share classes used — was reasonable. Participants were in appropriate share classes for the plan's size. We state this with the same confidence as the findings above, because a review that only ever finds problems would deserve no one's trust.
Public filings take this analysis a long way and no further. Four documents would close the remaining gaps: the provider's formal fee disclosure to the plan; the service agreement; the committee's meeting minutes; and the plan expense-account activity. Each gap above names which of these would cure it. This is exactly the list a professional — or an attorney — would request first.
If everything had checked out, this report would say so, in numbers, and that would be the end of it. Where the numbers raise questions — as they do here — the next step is review by an independent licensed professional, who is paid the same whether they confirm a problem or clear it. If something is seriously wrong, this report and its workpapers are built to hand directly to your own attorney. We do not choose the attorney, and we take nothing from anyone you hire.