Revenue for “bundled” recordkeepers have been facing downward pressure for years--both on recordkeeping fees and asset management fees. Over the past decade recordkeeping fees have dropped 50 percent and investment fees paid by 401(k) plans have dropped by 38 percent over a similar period. These bundled recordkeepers are looking to fund managers, plans, and individual participants to compensate for this decline. The recordkeepers’ search for new revenue sources can create challenges for plan fiduciaries and sponsors and should be monitored closely.

There is ongoing pressure on plan providers to continue to lower fees. And, it is reasonable to expect providers to seek alternative sources of revenue that may not be part of plans’ direct costs. In monitoring providers, fiduciaries should take note of rules under ERISA that require fiduciaries to obtain information from providers about both direct and indirect compensation that will be received by providers “in connection with” the plan services. This requirement goes beyond simply negotiating plan fees and beyond the general “prudence” requirements.

As recordkeeping fees continue to decline, recordkeepers are becoming more resourceful. As a result, representatives servicing your retirement plan may be paid based on their ability to sell financial products to your employees. Employer beware.