How often should plan investments and fees be reviewed?
Last updated October 2, 2026
Review investment performance against the IPS quarterly (at minimum annually), and benchmark plan fees — investments, recordkeeping, and advice — at least annually, with periodic market tests such as RFPs every three to five years. Documented reviews are the backbone of fee-litigation defense.
The review rhythm that has become the de facto standard of care:
- Quarterly: investment performance versus IPS benchmarks; watch-list updates; notable manager or market events.
- Annually: total plan cost review — expense ratios and share classes, recordkeeping fees (especially revenue-sharing arrangements), adviser compensation — benchmarked against comparable plans.
- Every 3–5 years: a live market test (RFP or RFI) for recordkeeping and major services, proving fees against actual alternatives.
Excessive-fee cases rarely fault plans for their prices in isolation — they fault the absence of evidence anyone checked. Each review, its inputs, and its conclusions recorded in minutes converts routine oversight into the defense file.
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