Step 3 · market structure & peer fee bands
Benchmarks
Who serves whom (recordkeeper, custodian, advisor, and auditor market share) and what good fees look like for plans of your size. Every figure is computed from DOL Form 5500 filings, plan years 2022–2024 — no panel data, no estimates.
Corpus coverage
Full multi-year DOL Form 5500 dataset currently indexed. Most competitors only expose the latest plan year.Plan year
2024
Filings
992,293
Total assets
$26.5T
Active participants
218,915,622
Plan year
2023
Filings
993,180
Total assets
$25.9T
Active participants
227,643,665
Plan year
2022
Filings
957,834
Total assets
$22.6T
Active participants
222,501,779
Fee benchmarks by plan-asset band
401(k) & 403(b) plans only · fees expressed in basis points of plan assetsCompare your plan to peers
Fee mode
Your fee (bps)
25.0
Peer band
$50M – $100M
15,778 of 16,931 plans disclosed Sched C
Peer median (bps)
15.6
Peer median ($)
$78K
60% above peer median
Materially above the peer median. Likely a fee-benchmarking opportunity.
| Plan-asset band | Plans | Plans w/ Sched C | Median assets | Median participants | Median total Sched C comp | Median fee (bps) |
|---|---|---|---|---|---|---|
| < $1M | 1,186,931 | 4,404 | $193K | 8 | $5K | 100.9 |
| $1M – $10M | 711,611 | 60,991 | $2.4M | 21 | $24K | 50.1 |
| $10M – $50M | 111,660 | 75,794 | $17.2M | 160 | $58K | 28.4 |
| $50M – $100M | 16,931 | 15,778 | $67.5M | 531 | $107K | 15.6 |
| $100M – $500M | 16,545 | 15,575 | $176.9M | 1,335 | $186K | 9.8 |
| $500M – $1B | 3,022 | 2,814 | $676.2M | 4,151 | $443K | 6.4 |
| $1B+ | 3,434 | 3,189 | $2.0B | 11,492 | $1.0M | 4.8 |
Schedule C disclosure is required only for plans with 100+ participants, so the fee medians are computed from the “Plans w/ Sched C” subset of each band — not all plans in the band. Schedule C also has a $5K de minimis threshold, so providers paid less than $5K aren’t captured. Plans with under $10K in assets are excluded from the bps calculation entirely (fee-to-asset ratio is dominated by fixed admin floors and isn’t comparable). Smaller bands have thinner disclosed samples and should be read accordingly.
Top custodians by plan assets
Trust banks and brokerage custodians with 20+ plans reported in Schedule C.| Provider | Plans | Total assets | Median plan assets | Avg direct comp | |
|---|---|---|---|---|---|
| BANK OF NEW YORK MELLON Custodian | 193 | $272.5B | $299.8M | $220K | Open → |
| NORTHERN TRUST Custodian | 212 | $241.7B | $371.4M | $228K | Open → |
| STATE STREET BANK AND TRUST Custodian | 39 | $193.6B | $609.9M | $401K | Open → |
| BNY MELLON Custodian | 22 | $46.8B | $273.6M | $179K | Open → |
| JPMORGAN CHASE BANK N A Custodian | 23 | $22.5B | $164.7M | $65K | Open → |
| STATE STREET BANK & TRUST Custodian | 22 | $12.5B | $145.1M | $88K | Open → |
| CHARLES SCHWAB TRUST BANK Custodian | 438 | $12.0B | $16.9M | $7K | Open → |
| CHARLES SCHWAB & CO Custodian | 228 | $6.6B | $17.8M | $3K | Open → |
| MATRIX TRUST Custodian | 122 | $6.6B | $24.9M | $11K | Open → |
| NATIONWIDE Custodian | 400 | $5.6B | $8.5M | $37K | Open → |
| VANGUARD GROUP Custodian | 74 | $4.7B | $15.8M | $43K | Open → |
| US BANK Custodian | 41 | $4.0B | $64.1M | $28K | Open → |
| AMALGAMATED BANK Custodian | 20 | $4.0B | $153.5M | $27K | Open → |
| CHARLES SCHWAB Custodian | 45 | $3.7B | $22.8M | $10K | Open → |
| COMERICA BANK Custodian | 37 | $3.2B | $29.1M | $33K | Open → |
Top recordkeepers by plan assets
DC-plan recordkeepers and administrators with 20+ plans reported in Schedule C.| Provider | Plans | Total assets | Median plan assets | Avg direct comp | |
|---|---|---|---|---|---|
| FIDELITY INVESTMENTS INSTITUTIONAL Recordkeeper | 31,967 | $6.1T | $29.3M | $90K | Open → |
| ALIGHT SOLUTIONS Recordkeeper | 208 | $647.4B | $1.3B | $1.3M | Open → |
| FID INV INST OPS CO Recordkeeper | 362 | $507.2B | $248.8M | $309K | Open → |
| EMPOWER ANNUITY INSURANCE O Recordkeeper | 10,834 | $404.4B | $14.4M | $43K | Open → |
| TRANSAMERICA RETIREMENT SOLUTIONS Recordkeeper | 4,687 | $386.7B | $24.6M | $94K | Open → |
| EMPOWER ANNUITY INSURANCE Recordkeeper | 7,968 | $384.7B | $13.6M | $44K | Open → |
| MERRILL LYNCH PIERCE FENNER AND S Recordkeeper | 1,592 | $310.5B | $44.3M | $113K | Open → |
| VOYA INSTITUTIONAL PLAN SERVICES Recordkeeper | 171 | $209.0B | $505.9M | $712K | Open → |
| FIDELITY INVESTMENTS Recordkeeper | 334 | $186.0B | $42.5M | $126K | Open → |
| TIAA Recordkeeper | 1,139 | $181.7B | $32.2M | $29K | Open → |
| ADP Recordkeeper | 12,774 | $179.0B | $7.4M | $23K | Open → |
| FIDELITY INV INST OPS CO Recordkeeper | 95 | $177.6B | $810.4M | $488K | Open → |
| GREAT WEST LIFE & ANNUITY INS CO Recordkeeper | 31 | $156.0B | $6.3M | $1.7M | Open → |
| FIDELITY INV INST L OP CO Recordkeeper | 30 | $143.3B | $970.8M | $817K | Open → |
| ADP BROKER-DEALER Recordkeeper | 7,321 | $112.8B | $8.4M | $30 | Open → |
Top advisors / consultants by plan assets
Investment advisory firms with 20+ plans reported in Schedule C.| Provider | Plans | Total assets | Median plan assets | Avg direct comp | |
|---|---|---|---|---|---|
| STRATEGIC ADVISORS Advisor / Consultant | 9,429 | $3.1T | $73.3M | $71K | Open → |
| FINANCIAL ENGINES Advisor / Consultant | 229 | $564.8B | $777.8M | $734K | Open → |
| BLACKROCK INSTITUTIONAL TRUST CO Advisor / Consultant | 109 | $444.4B | $753.3M | $363K | Open → |
| CAPFINANCIAL PARTNERS Advisor / Consultant | 1,330 | $440.3B | $59.7M | $49K | Open → |
| NISA INVESTMENT ADVISORS Advisor / Consultant | 90 | $396.2B | $1.1B | $1.8M | Open → |
| STATE STREET GLOBAL ADVISORS TRUST Advisor / Consultant | 62 | $386.7B | $2.3B | $211K | Open → |
| PIMCO Advisor / Consultant | 67 | $331.0B | $459.7M | $631K | Open → |
| T ROWE PRICE ASSOCIATES Advisor / Consultant | 40 | $330.6B | $1.5B | $827K | Open → |
| JP MORGAN INVESTMENT MANAGEMENT Advisor / Consultant | 42 | $308.5B | $868.5M | $646K | Open → |
| MERCER Advisor / Consultant | 259 | $304.7B | $477.3M | $134K | Open → |
| DODGE & COX Advisor / Consultant | 42 | $294.4B | $1.8B | $756K | Open → |
| CALLAN ASSOCIATES Advisor / Consultant | 51 | $273.2B | $631.9M | $97K | Open → |
| NEPC Advisor / Consultant | 165 | $270.2B | $374.0M | $100K | Open → |
| MERCER INVESTMENTS Advisor / Consultant | 415 | $249.4B | $116.2M | $116K | Open → |
| STATE STREET GLOBAL ADVISORS Advisor / Consultant | 97 | $247.2B | $374.3M | $1.2M | Open → |
Top plan-audit firms
Schedule H auditors ranked by number of plans audited (2024).| Auditor | Plans | Total plan assets |
|---|---|---|
| CLIFTONLARSONALLEN LLP | 7,647 | $866.1B |
| BAKER TILLY US, LLP | 6,289 | $1.2T |
| FORVIS MAZARS, LLP | 4,010 | $634.6B |
| RSM US LLP | 3,214 | $352.1B |
| CROWE LLP | 2,628 | $1.1T |
| BDO USA, P.C. | 2,574 | $908.3B |
| MOSS ADAMS LLP | 2,359 | $885.7B |
| PLANTE & MORAN, PLLC | 2,301 | $265.2B |
| CARON & BLETZER, PLLC | 2,255 | $155.4B |
| EIDE BAILLY LLP | 2,227 | $165.7B |
| PENSION ASSURANCE LLP | 2,199 | $70.0B |
| CBIZ CPAS P.C. | 2,118 | $341.2B |
| FORVIS, LLP | 2,105 | $247.1B |
| WIPFLI LLP | 1,896 | $149.8B |
| GRANT THORNTON LLP | 1,754 | $842.8B |
Benchmark your own plan against peers in seconds.
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