Skip to content
RetireFax
Menu

Form 5500 Schedule C: How to Read Service Provider Fees

Schedule C is the part of the Form 5500 that names a plan's service providers and what each was paid. For anyone selling to retirement plans, it's the most useful page in the filing.

What It Is

Schedule C, Service Provider Information, is attached to the Form 5500 of large plans. It lists the firms and people the plan paid for services during the year: the recordkeeper, advisors and consultants, the auditor, trustees and custodians, investment managers, brokers and others. For each one it shows what services they provided, using numbered service codes, and how much they were paid.

Who Files It

  • Large plans only. Plans that file full financial statements on Schedule H, generally those with 100 or more participants. Small plans filing the 5500-SF or Schedule I don't file Schedule C.
  • Providers paid $5,000 or more. A provider appears only if its reportable compensation from the plan, direct or indirect, reached $5,000 for the year. Smaller providers don't appear.

The Three Parts

  1. Part I: Service providers and their pay. The main section. Each provider's name, EIN, service codes, relationship to the employer or other parties, direct pay from the plan, and indirect pay from other sources such as the funds the plan holds. Providers paid only certain disclosed indirect compensation may be listed more briefly.
  2. Part II: Providers that didn't give information. Providers who failed or refused to give the plan administrator what it needed to complete the schedule.
  3. Part III: Termination of the accountant or actuary. Explains why the plan's auditor or enrolled actuary was replaced.

Service Codes

Every provider in Part I is tagged with one or more two-digit codes describing what it did. These are the ones that matter most for working out who serves a plan:

CodeOfficial DescriptionUsually Means
15Recordkeeping and information managementThe recordkeeper
37Participant loan processingUsually the recordkeeper
64Recordkeeping feesUsually the recordkeeper (an indirect-pay code)
16 / 17Consulting (general / pension)Consultants
27Investment advisory (plan)The plan's advisor
26Investment advisory (participants)Advice or managed accounts for participants
28Investment managementAsset managers
10Accounting (including auditing)The plan's auditor
14Plan AdministratorThird-party administrators
19 / 21Custodial (securities) / Trustee (bank, trust company)Custodians and trustees
33Securities brokerageBrokers

Direct and Indirect Pay

Direct pay is money the plan itself paid the provider, out of plan assets. Indirect pay comes from somewhere else, most often the funds in the lineup: revenue sharing, 12b-1 fees, sub-transfer agency fees and commissions. Indirect pay is often the larger share of what a recordkeeper earns, and it's the part plan sponsors most often overlook. Codes in the 50s through 70s describe the kind of pay:

CodeOfficial Description
50Direct payment from the plan
52Investment management fees paid indirectly by plan
59Shareholder servicing fees
60Sub-transfer agency fees
63Distribution (12b-1) fees
65Account maintenance fees
70Consulting fees
71Securities brokerage commissions and fees

Reading It Correctly

  • One firm, many names. A large recordkeeper can appear under several legal entities and spellings, sometimes on the same filing. Add them up before comparing firms.
  • More than one recordkeeping code. Several providers can carry code 15 or 64. The one with the recordkeeping pay and the participant-facing codes is usually the recordkeeper.
  • Switch years. In the year a plan changes recordkeeper, both firms often appear: the outgoing one paid for part of the year, the new one for the rest.
  • Sold businesses. When one recordkeeper buys another, plans can keep listing the old name for a while. That's a sale, not a plan switching.
  • Blanks aren't zeros. A missing amount means not reported, and a provider under $5,000 isn't listed at all.

RetireFax does this work for every large plan: it merges each firm's entities and spellings, names one recordkeeper per plan each year, follows sold books to their buyer, and shows direct and indirect pay side by side. Next: how to find any plan's recordkeeper and advisor.

Skip the Manual Work

RetireFax has already read every filing. See a plan's providers, fees, lineup and rating on one page.

Request a Demo