How should a plan sponsor select and monitor a recordkeeper or TPA?

Last updated October 2, 2026

Selection demands a documented comparison — services, fees, technology, references — typically via RFP for recordkeepers. Monitoring means annual performance and fee reviews, error tracking, cybersecurity checks, and a fresh market test every three to five years, all recorded in committee minutes.

Recordkeepers and TPAs run the plan's daily machinery, and hiring them is a fiduciary decision judged on process:

  • Selection: define required services; solicit comparable proposals (an RFP for recordkeeping); evaluate fees against services, technology, and references; document the decision and rationale.
  • Monitoring: annual service reviews (accuracy, timeliness, participant experience), fee confirmation against the 408(b)(2) disclosures, cybersecurity posture per DOL guidance, and prompt escalation of errors.
  • Market testing: a periodic RFP/RFI — every 3–5 years is the commonly cited benchmark — proves ongoing reasonableness with live data.

The recurring litigation lesson: long-tenured vendors aren't the problem; never-retested vendors are.

Thanks for your feedback!

Related questions

Put these answers to work

Fiduciary In A Box walks your team through every one of these requirements step by step — documenting decisions, organizing files, and keeping your plan compliant year-round.

See how FIAB works