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How to Find a 401(k) Plan's Recordkeeper and Advisor

Every large 401(k) names its recordkeeper and advisor in a public filing. Here's how to find them, and how to avoid the mistakes that make the answer look wrong.

1. Find the Filing

Start with the plan's latest Form 5500. The Department of Labor's EFAST2 filing search lets you look up filings by the sponsor's name or its employer identification number (EIN). Many companies sponsor more than one plan, so check the plan name and three-digit plan number (001, 002 and so on) to be sure you have the right one, and pick the most recent plan year.

2. Check the Plan's Size

Look at which version was filed. A Form 5500 with Schedule H means a large plan, generally 100 or more participants, and it will include Schedule C. A Form 5500-SF means a small plan, which doesn't list its providers (see small plans below).

3. Read Schedule C

Schedule C lists every provider paid $5,000 or more, each tagged with service codes:

  • Recordkeeper: code 15 (recordkeeping and information management), often with 37 (participant loan processing) or 64 (recordkeeping fees).
  • Advisor: code 27 (investment advisory, plan), or 16 and 17 (consulting). Code 26 means advice or managed accounts offered to participants, which is often a different firm.
  • Auditor: code 10 (accounting, including auditing).

Our Schedule C guide explains every part of the schedule and how direct and indirect pay are reported.

Small Plans

Small plans don't file Schedule C, so their recordkeeper isn't named directly. Two places can still help:

  • Schedule A, filed by plans that hold insurance contracts, names the insurance company. For plans run through a group annuity, the insurer is often the recordkeeper too.
  • The plan's own documents. Participant statements, the summary plan description and the annual fee disclosure all name the recordkeeper. A plan's employees and HR team have these.

Common Traps

  • The filing is a year or more old. Plans file up to seven months after the plan year ends, or later with an extension. A switch in the last year won't show yet.
  • Two recordkeepers in one year. In a switch year, the outgoing and incoming firms can both appear. Compare the next year's filing to see who stayed.
  • Legal names don't look like brand names. Recordkeepers often file under an operating company or trust company name that doesn't match the brand you know.
  • Acquired firms. After one recordkeeper buys another, filings can keep the old name for a year or two.
  • The wrong plan. A company's pension plan, 401(k) and acquired-company plans each file separately, often with different providers.

RetireFax shows the recordkeeper, advisor, auditor and every other provider on each plan's page, already matched to the firm's brand name, with how long it has served the plan and the plan's chance of switching. See how advisors use it.

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