How to Evaluate a Retirement Plan Provider's Fee Disclosures

How to Evaluate a Retirement Plan Provider's Fee Disclosures

How to Evaluate a Retirement Plan Provider's Fee Disclosures

Understanding 408(b)(2) and 404(a)(5) fee disclosures can help plan sponsors evaluate retirement plan costs, benchmark provider fees, and make more informed fiduciary decisions.

Retirement plan fees are one of the most important factors affecting both employer costs and participant outcomes, yet they are often among the least understood parts of a 401(k) plan.

Most employers receive fee disclosures every year, but many struggle to answer basic questions after reviewing them:

  • What are we actually paying?

  • What are employees paying?

  • Which fees are reasonable?

  • Are any fees hidden?

  • How do our costs compare to similar plans?

At Basic Capital, we believe fee transparency is a critical component of retirement plan governance. Employers should not need a finance degree to understand how their retirement plan is priced.

This guide explains how to evaluate retirement plan fee disclosures, understand the difference between 408(b)(2) and 404(a)(5) disclosures, and identify the questions every plan sponsor should be asking.

Why Fee Disclosures Matter

Under ERISA, plan sponsors have a fiduciary responsibility to ensure retirement plan fees remain reasonable relative to the services being provided.

That responsibility does not mean employers must always choose the lowest-cost provider.

Instead, employers should understand:

  • What services they receive

  • What those services cost

  • How fees are structured

  • Whether costs remain competitive over time

Fee disclosures provide the information needed to make those evaluations.

The Two Fee Disclosures Every Plan Sponsor Should Know

Many employers encounter two important fee disclosure documents:

408(b)(2) Disclosure

The 408(b)(2) disclosure is provided to plan fiduciaries and employers.

Its purpose is to explain:

  • Service provider compensation

  • Administrative fees

  • Investment-related fees

  • Advisory fees

  • Indirect compensation arrangements

Think of this document as the employer-facing fee disclosure.

It helps plan sponsors understand how providers are compensated and whether fees remain reasonable.

404(a)(5) Disclosure

The 404(a)(5) disclosure is participant-facing.

Its purpose is to help employees understand:

  • Investment expenses

  • Plan-level fees

  • Individual service fees

  • Investment performance information

Think of this as the employee-facing disclosure.

While employers may not review it as frequently, understanding its contents can provide insight into the participant experience.

Understanding the Three Main Fee Categories

Most retirement plan fees fall into three primary categories.

Understanding these buckets makes fee evaluation significantly easier.

Recordkeeping and Administrative Fees

These fees cover the operational side of running the retirement plan.

Common services include:

  • Participant account administration

  • Payroll integration

  • Compliance support

  • Reporting

  • Online account access

  • Participant communications

Administrative fees may be charged:

  • As a flat annual fee

  • Per participant

  • As a percentage of assets

  • Through a combination of methods

As businesses grow, these fees often evolve, making periodic reviews important.

Investment Fees

Investment fees are typically embedded within investment funds.

These costs often appear as:

  • Expense ratios

  • Fund operating expenses

  • Investment management fees

Because they are deducted directly from fund assets, participants may not always notice them.

For example:

A fund with a 0.40% expense ratio costs approximately:

  • $40 annually for every $10,000 invested

  • $400 annually for every $100,000 invested

Small differences in investment expenses can have meaningful long-term effects on retirement savings.

Advisory and Fiduciary Fees

Some retirement plans include fees for:

  • Investment consulting

  • Fiduciary services

  • Participant education

  • Plan reviews

  • Governance support

These fees may be:

  • Asset-based

  • Flat fee

  • Per-participant

Plan sponsors should understand both the cost and the services being provided.

A Sample Fee Breakdown

One of the easiest ways to evaluate a plan is to organize fees into a simple summary.

Example Plan


Fee Type

Annual Cost

Recordkeeping Fee

0.20%

Investment Expenses

0.35%

Advisory Fee

0.25%

Total All-In Cost

0.80%

For a plan with $2 million in assets:

  • Total annual fees = approximately $16,000

This type of summary often makes fee structures much easier to evaluate than reviewing multiple disclosure documents separately.

How to Calculate Your All-In Plan Cost

Many employers focus on individual fees while overlooking total plan costs.

A simple formula can help:

Recordkeeping Fees + Investment Fees + Advisory Fees = Total All-In Cost

For example:

  • Recordkeeping: 0.15%

  • Investment Expenses: 0.40%

  • Advisory Fees: 0.25%

Total Cost = 0.80%

Understanding total costs provides a more complete picture than evaluating fee categories individually.

Questions Every Plan Sponsor Should Ask

When reviewing fee disclosures, employers should ask:

Are All Fees Clearly Disclosed?

If it is difficult to determine:

  • Who receives compensation

  • How fees are calculated

  • What services are included

additional clarification may be needed.

Transparency is often one of the strongest indicators of a healthy provider relationship.

Have Fees Been Benchmarked Recently?

A fee that was competitive five years ago may not remain competitive today.

Periodic benchmarking helps determine whether pricing remains reasonable.

Are Participants Paying for Services They Don't Use?

Some plans include costs for:

  • Managed accounts

  • Advisory services

  • Specialized tools

that may have limited participant adoption.

Understanding utilization can help employers evaluate value.

Are Asset-Based Fees Growing Faster Than Services?

As plan assets increase, some fee structures become significantly more expensive even if service levels remain unchanged.

Employers should periodically review whether asset growth has altered the economics of the plan.

Common Fee Disclosure Red Flags

While every plan is different, several warning signs often warrant additional review.

Multiple Layers of Fees

Complex pricing structures can make it difficult to determine total costs.

Revenue Sharing Arrangements

Revenue sharing is not inherently problematic, but employers should understand:

  • How it works

  • Who receives compensation

  • Whether lower-cost alternatives exist

Limited Fee Transparency

If providers cannot clearly explain:

  • Costs

  • Compensation

  • Services

plan sponsors may struggle to fulfill fiduciary responsibilities.

Outdated Investment Share Classes

Employers should periodically verify that lower-cost share classes are not available for existing investments.

What Fee Transparency Looks Like Today

Modern retirement plans increasingly emphasize transparency.

Employers often expect:

  • Clear pricing structures

  • Easy-to-understand disclosures

  • Simplified fee reporting

  • Better cost visibility

  • More straightforward provider compensation models

At Basic Capital, we believe employers should be able to understand retirement plan costs without needing to decode dozens of pages of disclosures.

Companies looking for a deeper breakdown of retirement plan fee disclosures may also benefit from reading our Practical Guide to 401(k) Fee Disclosures for Employers.

Better Visibility Leads to Better Decisions

Fee disclosures are more than compliance documents.

They are tools that help employers:

  • Benchmark provider costs

  • Evaluate plan value

  • Strengthen fiduciary oversight

  • Improve participant outcomes

  • Support better governance decisions

At Basic Capital, we believe transparency supports trust, and trust supports stronger retirement plans.

Companies evaluating retirement plan modernization can also explore our For Employers resources to learn how modern retirement infrastructure supports transparency, compliance, and employee engagement.

The Bottom Line

Evaluating retirement plan fee disclosures does not require becoming a retirement industry expert.

By understanding the purpose of 408(b)(2) and 404(a)(5) disclosures, organizing fees into clear categories, and periodically benchmarking costs, employers can make more informed decisions about their retirement plan.

At Basic Capital, we believe retirement plans should make costs easier to understand, not harder to uncover.

Ready to see how a modern retirement platform approaches pricing and transparency? Get started with Basic Capital to learn how we help employers simplify retirement plan administration, improve visibility, and support better retirement outcomes.

This isn't your standard 401(k).

Meet the 401(k) that actually gets your team retirement ready.

This isn't your standard 401(k).

Meet the 401(k) that actually gets your team retirement ready.

This isn't your standard 401(k).

Meet the 401(k) that actually gets your team retirement ready.

© 2026 Basic Capital. All rights reserved.

Basic Capital Group Inc. and its affiliates and subsidiaries (collectively, "Basic Capital") provide this website and its contents for informational and educational purposes only. The information on this website is general in nature and is not intended to address the circumstances of any particular individual or entity.  Nothing on this website constitutes investment, financial, legal, tax, or accounting advice, nor should it be construed as a recommendation or endorsement of any specific investment product, strategy, or service. Basic Capital does not provide legal, tax, or accounting advice. You should consult with your own qualified financial, legal, and tax advisors before making any investment decisions. Our site uses a third party service to match browser cookies to your contact information. We then use another company to send special offers on our behalf.

Recordkeeping Services

Recordkeeping services are provided through Basic Capital Recordkeeping Services LLC, a wholly owned subsidiary of Basic Capital Group, Inc. Unless expressly agreed to in writing, Basic Capital Recordkeeping Services LLC does not act as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended, with respect to any employee benefit plan.

Investment Advisory Services

Investment advisory services are provided through Basic Capital Advisors LLC, a wholly owned subsidiary of Basic Capital Group Inc. registered with the State of New York as an investment adviser. Registration does not imply a certain level of skill or training. Investing involves risk, including the potential loss of principal. Past performance is not indicative of future results.
Investments in securities are: Not FDIC Insured • Not Bank Guaranteed • May Lose Value.
Neither Basic Capital Advisors LLC nor its affiliates are a registered broker-dealer or engage in securities brokerage activities. Furthermore, Basic Capital Advisors LLC and its affiliates do not act as a broker-dealer.

Investment Financing (“The Retirement Mortgage”)

Basic Capital’s investment financing arrangement called The Retirement Mortgage is not a security registered under the Securities Act of 1933 or an investment company registered under the Investment Company Act of 1940. This arrangement is not subject to the same regulatory requirements as the investment advisory services provided by Basic Capital Advisors LLC. The investment financing arrangement involves the use of financing or leverage, which carries additional and significant risks beyond those associated with standard investing. This arrangement may not be suitable for all investors. You should carefully consider the investment objectives, risks, terms and conditions, fees and expenses of The Retirement Mortgage before taking advantage of The Retirement Mortgage.  Please review all applicable terms, conditions, and risk disclosures specific to the investment financing arrangement before proceeding.

Basic Capital, 52 Walker Street, 5th Floor, New York, NY 10013 | 888-460-4901

© 2026 Basic Capital. All rights reserved.

Basic Capital Group Inc. and its affiliates and subsidiaries (collectively, "Basic Capital") provide this website and its contents for informational and educational purposes only. The information on this website is general in nature and is not intended to address the circumstances of any particular individual or entity.  Nothing on this website constitutes investment, financial, legal, tax, or accounting advice, nor should it be construed as a recommendation or endorsement of any specific investment product, strategy, or service. Basic Capital does not provide legal, tax, or accounting advice. You should consult with your own qualified financial, legal, and tax advisors before making any investment decisions. Our site uses a third party service to match browser cookies to your contact information. We then use another company to send special offers on our behalf.

Recordkeeping Services

Recordkeeping services are provided through Basic Capital Recordkeeping Services LLC, a wholly owned subsidiary of Basic Capital Group, Inc. Unless expressly agreed to in writing, Basic Capital Recordkeeping Services LLC does not act as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended, with respect to any employee benefit plan.

Investment Advisory Services

Investment advisory services are provided through Basic Capital Advisors LLC, a wholly owned subsidiary of Basic Capital Group Inc. registered with the State of New York as an investment adviser. Registration does not imply a certain level of skill or training. Investing involves risk, including the potential loss of principal. Past performance is not indicative of future results.
Investments in securities are: Not FDIC Insured • Not Bank Guaranteed • May Lose Value.
Neither Basic Capital Advisors LLC nor its affiliates are a registered broker-dealer or engage in securities brokerage activities. Furthermore, Basic Capital Advisors LLC and its affiliates do not act as a broker-dealer.

Investment Financing (“The Retirement Mortgage”)

Basic Capital’s investment financing arrangement called The Retirement Mortgage is not a security registered under the Securities Act of 1933 or an investment company registered under the Investment Company Act of 1940. This arrangement is not subject to the same regulatory requirements as the investment advisory services provided by Basic Capital Advisors LLC. The investment financing arrangement involves the use of financing or leverage, which carries additional and significant risks beyond those associated with standard investing. This arrangement may not be suitable for all investors. You should carefully consider the investment objectives, risks, terms and conditions, fees and expenses of The Retirement Mortgage before taking advantage of The Retirement Mortgage.  Please review all applicable terms, conditions, and risk disclosures specific to the investment financing arrangement before proceeding.

Basic Capital, 52 Walker Street, 5th Floor, New York, NY 10013 | 888-460-4901

© 2026 Basic Capital. All rights reserved.

Basic Capital Group Inc. and its affiliates and subsidiaries (collectively, "Basic Capital") provide this website and its contents for informational and educational purposes only. The information on this website is general in nature and is not intended to address the circumstances of any particular individual or entity.  Nothing on this website constitutes investment, financial, legal, tax, or accounting advice, nor should it be construed as a recommendation or endorsement of any specific investment product, strategy, or service. Basic Capital does not provide legal, tax, or accounting advice. You should consult with your own qualified financial, legal, and tax advisors before making any investment decisions. Our site uses a third party service to match browser cookies to your contact information. We then use another company to send special offers on our behalf.

Recordkeeping Services

Recordkeeping services are provided through Basic Capital Recordkeeping Services LLC, a wholly owned subsidiary of Basic Capital Group, Inc. Unless expressly agreed to in writing, Basic Capital Recordkeeping Services LLC does not act as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended, with respect to any employee benefit plan.

Investment Advisory Services

Investment advisory services are provided through Basic Capital Advisors LLC, a wholly owned subsidiary of Basic Capital Group Inc. registered with the State of New York as an investment adviser. Registration does not imply a certain level of skill or training. Investing involves risk, including the potential loss of principal. Past performance is not indicative of future results.
Investments in securities are: Not FDIC Insured • Not Bank Guaranteed • May Lose Value.
Neither Basic Capital Advisors LLC nor its affiliates are a registered broker-dealer or engage in securities brokerage activities. Furthermore, Basic Capital Advisors LLC and its affiliates do not act as a broker-dealer.

Investment Financing (“The Retirement Mortgage”)

Basic Capital’s investment financing arrangement called The Retirement Mortgage is not a security registered under the Securities Act of 1933 or an investment company registered under the Investment Company Act of 1940. This arrangement is not subject to the same regulatory requirements as the investment advisory services provided by Basic Capital Advisors LLC. The investment financing arrangement involves the use of financing or leverage, which carries additional and significant risks beyond those associated with standard investing. This arrangement may not be suitable for all investors. You should carefully consider the investment objectives, risks, terms and conditions, fees and expenses of The Retirement Mortgage before taking advantage of The Retirement Mortgage.  Please review all applicable terms, conditions, and risk disclosures specific to the investment financing arrangement before proceeding.

Basic Capital, 52 Walker Street, 5th Floor, New York, NY 10013 | 888-460-4901