Every year, the 401(k) Averages Book comes out and tells us something we already know—but somehow still manage to ignore.
Fees are going down.
That’s the headline everyone wants to celebrate. Investment costs continue to drop, recordkeeping is more competitive than ever, and overall plan expenses keep trending downward. On paper, it looks like progress. It looks like the system is working.
And to a certain extent, it is.
But then you get past the headline, and that’s where things get uncomfortable.
Because while fees are falling overall, the disparities between what plans actually pay are still staggering. You can line up two plans of similar size, similar demographics, even similar providers—and still see meaningful differences in cost. Not a few basis points here or there, but gaps that actually matter over time.
So the real question isn’t whether fees are improving.
It’s why the gap still exists at all.
This isn’t 2005. We’re not operating in the dark anymore. Fee disclosures exist. Benchmarking tools are everywhere. Advisors talk about fiduciary duty like it’s second nature. Litigation has made it painfully clear that excessive fees are not just a theoretical issue.
And yet, here we are.
The problem isn’t a lack of information. It’s a lack of urgency.
Plans stay where they are because things feel “fine.” Providers don’t push hard enough because stability is easier than change. Advisors sometimes accept the status quo because proving something better requires effort, and effort creates friction.
Meanwhile, participants quietly pay the price.
Because here’s the part that gets lost: averages don’t apply to individuals. Just because the industry average is going down doesn’t mean your plan is benefiting from it. Someone is still paying more than they should—and often they don’t even realize it.
That’s what the Averages Book really exposes.
Not just progress, but inconsistency. Not just improvement, but complacency.
And if you’re not actively questioning what you’re paying and why, there’s a very real chance you’re on the wrong side of that gap.
