If I walked into your office tomorrow and you handed me responsibility for your 401(k), I wouldn’t start by changing investments, firing vendors, or chasing the latest industry trend.
I’d start with the basics — because that’s where most plans quietly fail.
First, I’d look at who actually makes decisions. Not who’s listed on paper, but who really has authority. Too many plans operate with informal power structures: one dominant personality, a “committee of one,” or a group that meets only when something goes wrong. Fiduciary responsibility doesn’t work well in the shadows.
Second, I’d review your process. Do you have an investment policy statement that’s followed, not just filed away? Are fees benchmarked on a regular schedule? Do you review vendors proactively or only after complaints arise? A plan without a process is a lawsuit waiting for a bad year.
Third, I’d read the meeting minutes — slowly. Minutes tell the real story. They show whether decisions were reasoned, whether alternatives were considered, and whether questions were asked. Sparse or generic minutes don’t protect anyone. They usually do the opposite.
Fourth, I’d assess vendor oversight. Recordkeepers, advisors, and TPAs are important, but none of them are fiduciaries just because they say they are. Delegation requires monitoring. Trust without verification is not a fiduciary strategy.
Finally, I’d look at participant impact. Not through glossy reports, but through outcomes. Are employees actually participating? Are they deferring enough? Are communications understood, or just delivered?
Here’s the truth plan sponsors don’t always want to hear: most 401(k) problems aren’t dramatic. They’re quiet. They build slowly through neglect, assumptions, and unchecked routines.
Fixing a plan doesn’t start with bold moves. It starts with discipline.
And discipline, done consistently, is what keeps good plans out of trouble.
