NAPA Net The Magazine, 2026 Summer

NAPA Net

Insight for the Retirement Plan Advisor

DIVIDE BEYOND the

NAPA’s 2026 Advisor Allies!

NAPA’s 2026 DC Advisor Teams and Multi-Office Firms

The Labor Department Redirects EBSA Investigation Priorities PLUS

Congratulations to our 2026 NAPA Top 100 Advisor Allies

Strong partnerships help drive better retirement outcomes. That’s why MFS is committed to helping you provide your clients with the insights, resources, and expertise needed to help their participants navigate their retirement journeys with confidence.

Beyond

By Kelsey Mayo

Best in the Business: NAPA’s 2026 Advisor Allies!

Thank you once again to all who participated and voted, and congratulations to the top retirement plan wholesalers. By

John Sullivan

50

Bigger Fish: The Labor Department Redirects EBSA Investigations

Here’s a closer look at the Labor Department’s new enforcement priorities.

By Judy Ward

56

Top of the Class! NAPA’s 2026 DC Advisor Teams and Multi-Office Firms Revealed

We appreciate the commitment and hard work of the teams acknowledged.

By John Sullivan

2026 Top 100 DC Wholesaler Winners

Eric Milano, QPFC

Alan Valenca, CFP®, CIMA®, RMA®

Tim White, CFP ® Great Lakes Region Cell: 330.603.5629 Tim.White@troweprice.com

Bailey Domer

Alex Eaton

Midwest Region (IL, IN)

Travis Gavinski Top 10 Wholesaler Wisconsin

Kara Knott

Heidi Lapham

Michael Moschetta

Corey Pride

North Central (KS, MO, NE)

Texas Gulf Coast

W. Pennsylvania and N.E. Ohio

North Texas and Oklahoma

Tony Robke, CIMA® Great Lakes and Southeast

Frank Tighe, CPFA® South Central

Cell: 248.500.5322 Bailey.Domer@troweprice.com

Cell: 410.458.3247 Alex.Eaton@troweprice.com

Cell: 608.512.8695

Travis.Gavinski@troweprice.com

Cell: 410.577.3754

Kara.Knott@troweprice.com

Cell: 443.257.4443

Heidi.Lapham@troweprice.com

Cell: 614.769.3656

in the financial services industry

years in the financial services industry

years in the financial services industry

Michael.Moschetta@troweprice.com 25 years in the financial services industry

Cell: 214.334.7645

Corey.Pride@troweprice.com

Cell: 859.412.0426

years in the financial services industry

Tony.Robke@troweprice.com 21 years in the financial services industry

Cell: 713.805.7270

Frank.Tighe@troweprice.com

26 years in the financial services industry Visit troweprice.com/dccapabilities

Nevin

Former Chief Content Officer American Retirement Association

Former Chief Content Officer of the American Retirement Association, Nevin now claims to be “retired.” One of the industry’s most prolific writers, during his more than four decades in the retirement industry, he’s served as the Employee Benefits Research Institute’s (EBRI) Director of Education and External Relations, spent a dozen years as Global Editor-in-Chief of PLANSPONSOR/PLANADVISER, and after two decades working with retirement plans, entered journalism as the originator, creator, writer and publisher of PLANSPONSOR.com’s NewsDash.

N. Levine

Principal Groom Law Group, Chartered

David is an attorney who advises plan sponsors, advisors and service providers on retirement and other benefit plans, and is a popular speaker on plan design, fiduciary governance, regulatory and legislative issues. He writes the magazine’s “Inside the Law” column.

Founder AmpliPhi Social Media Strategies

Spencer is the founder of AmpliPhi Social Media Strategies. A former 401(k) wholesaler, he now teaches financial services professionals how to use social media for business development, and is a popular speaker on social media and the author of ROTOMA: The ROI of Social Media Top of Mind He writes the magazine’s “Inside Social Media” column.

Founder and Chief Marketing Officer 401(k) Marketing, Inc.

Rebecca founded 401(k) Marketing in 2014 to assist qualified experts operate a professional business with professional marketing materials and ongoing awareness campaigns. Previously she held a variety of positions at LPL Financial, Guardian Life, Northwestern Mutual and Fidelity Investments. Rebecca writes the magazine’s “Inside Marketing” column.

Partner Faegre Drinker Law Firm

Fred Reish is a partner in the Faegre Drinker law firm. His practice focuses on fiduciary standards of care, prohibited transactions, conflicts of interest, and retirement plans. He has been recognized as one of the “Legends” of the retirement industry by PLANADVISER and PLANSPONSOR magazines. Fred also serves as a Research Fellow for the Retirement Income Institute. He has received the following awards: Institutional Investor Lifetime Achievement Awards, ASPPA/Morningstar 401(k) Leadership Award, and IRS District Director’s Award for contributions to the retirement community.

Chief Solutions Officer Endeavor Retirement

Bonnie Treichel, the Founder of Endeavor Retirement and Endeavor Law, is an ERISA attorney that works with advisors, plan sponsors and others in the retirement plan ecosystem. She is a regular contributor to NAPA’s publications and enjoys working with advisors as a subject matter expert to NAPA and ARA training programs such as the ESG(k) program, 401(k) Rollover Specialist (k)RS™ program, and others to come.

Editor-in-Chief John Sullivan jsullivan@usaretirement.org

Senior Writers Ted Godbout tgodbout@usaretirement.org

John Iekel jiekel@usaretirement.org

Paul Mulholland pmulholland@usaretirement.org

Ad Sales

Tashawna Rodwell trodwell@usaretirement.org

Senior Director of Digital Marketing Joey Santos-Jones jsantos-jones@usaretirement.org

Production Assistant Derin Oduye doduye@usaretirement.org

NAPA OFFICERS

President

Lisa M. Drake (Garcia)

President-Elect Alicia Malcolm

Vice President Doug Bermudez

Secretary Lee Bethel

Immediate Past President Keith Gredys

Executive Director

Brian H. Graff, Esq., APM

NAPA Net the Magazine is published quarterly by the National Association of Plan Advisors, 4401 N. Fairfax Dr., Suite 600, Arlington, VA 22203. For subscription information, advertising and customer service, please contact NAPA at the above address or call 800-308-6714, or customercare@napa-net.org. Copyright 2026, National Association of Plan Advisors. All rights reserved. This magazine may not be reproduced in whole or in part without written permission of the publisher. Opinions expressed in bylined articles are those of the authors and do not necessarily reflect the official policy of NAPA.

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Help (Desperately) Wanted

We all see what’s in front of us, so what do we plan to do about it?

It’s an age-old issue (pun intended) — where will we get the next crop of 401(k) advisors?

The current generation is heading out, and, as Brian Graff frequently notes, children rarely dream of one day fulfilling their lifelong goal of becoming a defined contribution plan consultant. Hence, recruiting is an ongoing concern.

I had a great conversation with Kevin Gaston on the topic recently at an American Retirement Association-hosted event.

Gaston, Vestwell’s Head of Strategic Retirement Consulting, had plenty to say about the future of the retirement plan industry and the challenges and opportunities it faces.

“Everyone in there works for a recordkeeper, TPA, etc., but what’s interesting is that we all grapple with the same issues,” he said. “In that room, there is a 200-person company and a 10,000-person company, and they’re both dealing with the exact same questions of talent, training, recruitment, and retaining.”

One of the most daunting challenges and opportunities is the expected “massive influx of new plans.”

“We all see what’s in front of us,” Gaston said. “There are not enough people in the industry today, so we have to find a way to bolster those numbers.”

Referring to college graduates and their (lack of) awareness of what a career in retirement plans can offer, he mentioned WinstonSalem State’s Dr. Terence Martin, a speaker at this year’s

NAPA 401(k) Summit, and noted this awareness will occur at the level of the professor.

“It’s a tough nut to crack in getting to the right person,” he added. “But there’s no reason that there’s not at least a course of study and understanding of what we do for a living at say, the University of Virginia, or the University of Georgia. What are the closest colleges here, Georgetown? George Washington University? I don’t think there’s any reason they should not be doing it. But it will take a big firm to come at them with [an endowment].”

He claimed most of the working public doesn’t understand the breadth of the support system behind the private retirement plan system.

“You go to work, there’s a 401(k), right? And you don’t know how that 401(k) actually works. We need to be able to get that part clearer downstream.”

Part of the answer, Gaston said, is appealing to the next generation’s sense of altruism.

“This is the quickest way to make an impact,” he argued. “But it has to be a dynamic, 24-yearold who could go out and speak to other people their age. One day, I was part of them, and now I’m not. I tell them the benefits of [saving in a work-based plan], and I see the looks of disconnection. If you play the pieces out, suppose we can get into 10 colleges and get 20 people in the industry. I think that they will do things and reach people in a way that you and I would never dream of.”

Mentioning the oft-repeated statistic that a worker who starts saving even a nominal amount at

age 25, rather than age 35, will have accumulated (on average) a million more dollars at retirement age, Gaston concluded, “That’s how we can get people to start saving at that 25-year mark. It doesn’t have to be a lot. But some kind of influencer, somebody who’s age 25, can really sell this thing.” NNTM

John Sullivan Editor-in-Chief

Congratulations to our 2026 NAPA Advisor Allies

All three of our honorees have been named NAPA Advisor Allies for each of the last three years—an amazing accomplishment and the perfect reflection of our unwavering commitment to DC advisors. It’s just one more reason why we’re your trusted partner for workplace retirement.

Andrew Brosco Central Region

Dan Florina Midwest Region

Click here to learn how we help DC advisors retire the status quo.

Nancy Gerstner, CRPS® Mid Atlantic Region

No fee was paid for this recognition. Honorees are selected through a voting process led by NAPA’s plan advisor community. © 2026 Franklin Templeton

Stepping Into Leadership: My Vision for the Year Ahead

If there’s one thing that’s clear, it’s this: The pace of change in the retirement plan industry isn’t slowing.

By Alicia Malcolm

I’m incredibly honored to step into the role of 2026 –2027 NAPA President.

As a brief background, I joined the Financial Services industry in 2012, right after graduating from college. I started my career at UBS Financial Services, working with my mom, who ran a private wealth management practice.

Soon after joining, she introduced me to one of her strategic partners, Paul D’Aiutolo, who only consulted on retirement plans. While at first, I had no idea what any of this meant, I quickly began to learn both sides of the business, wealth management and retirement plan consulting. After about one year, I transitioned into a new financial advisor position, and my mom’s former strategic partner became my formal business partner in 2016.

Shortly after joining the financial services industry, I became involved with NAPA. I attended my first NAPA conference in 2014, and after that, I was all in. After meeting so many wonderful people and hearing about all the good work they were doing for so many participants, I knew this business was meant for me. I thank you all for having such influence and inspiration in such a short period of time.

Since then, I have volunteered with NAPA in various capacities, and I was asked to join the Leadership Council in 2021. My beautiful friend and former NAPA President, Jania Stout, called to nominate me.

Since my time on the Leadership Council, I have

also been involved with the Government Affairs Committee, the Political Action Committee (PAC), and now the American Retirement Association, the parent association of NAPA.

I share my background with you all for a few reasons. First and foremost, like many of you, I am extremely passionate about what I do for a living. While I am thankful for all client relationships that we have, being able to service the retirement plan business, yes, at the consulting level, but also at the participant level, is such an honor.

Having the opportunity to serve on NAPA’s Leadership Council and now the privilege to represent the association as president, I am extremely excited to channel my passion to represent all of NAPA’s advisors, plan sponsors, and their participants, whom we all care so deeply about.

A good friend once heard me describe how busy and stressed I was and said, “You need to take a deep breath and relax. It is not like we are doctors. We are not saving people’s lives.”

While I agree we are not doctors and do not physically save lives every day, the work we do to help everyday Americans by providing them with the tools, resources, and education they need to be able to retire financially one day is incredible. The work we all do will help no fewer than 23 million participants be in a better financial position over their lifetimes.

Despite that, and despite successes like SECURE Act 1.0 and 2.0 that will forever change the retirement plan landscape,

Alicia Malcolm, CRPC®, CRPS® is a Financial Advisor and Senior Vice President- Wealth Management with UBS Financial Services, Inc. This is her inaugural column as NAPA’s 2026/2027 president.

there is still so much more to do. The retirement plan business has always been and will continue to be a target. In the late 1970’s, the retirement plan industry witnessed the quiet birth of the 401(k) Plan. The Revenue Act of 1978 created section 401(k) of the Internal Revenue Code. In other words, the 401(k)-tax code. Being established by the tax code will always pose a threat to our industry.

Whenever Congress seeks additional revenue, retirement plans are immediately brought into focus, as they represent taxdeferred dollars. This ongoing scrutiny makes it imperative for industry professionals like you to remain vigilant and proactive in protecting the retirement plan landscape.

Over the next 12 months, I am committed to doing everything in my power to advocate on your behalf. I will also continue to encourage each of you to get involved not only this year, but well beyond.

On a personal note, I would like to thank and honor my mom, whom we unexpectedly lost in June 2025. She introduced me to the financial services industry and has always been my greatest cheerleader and mentor. With that, I’m excited for what’s ahead for this community and the role we continue to play in shaping the future of the retirement system.

Because if there’s one thing that’s clear, it’s this: The pace of change isn’t slowing, which makes understanding what’s happening in Washington — and what it means for your clients and your practice — more important than ever. NNTM

to our 14 NAPA top 100 Advisor Allies for 2026!

More Advisor Allies than any other firm for the eighth year in a row, thanks to the votes of America’s advisors.1

Learn how our combined strength put us at the top of the Advisor Allies list. Find your local Manulife John Hancock representative today.

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Valhalla, NY. Product features and availability may differ by state. Securities are offered through John Hancock Distributors LLC, member FINRA, SIPC. John Hancock Investment Management Distributors LLC is the principal underwriter and wholesale distribution broker-dealer for the John Hancock mutual funds, member FINRA, SIPC. NOT FDIC INSURED. MAY LOSE VALUE. NOT BANK GUARANTEED. © 2026 Manulife John Hancock. All rights reserved. FOR INTERMEDIARY USE ONLY. NOT FOR DISTRIBUTION WITH PLAN SPONSORS OR THE PUBLIC. MGTS-I 37592-GE 6/26-1341203 MGR0529265527799 | MF5527799 Congratulations

Why ARA Supports the Proposed ‘Investment Selection Rule’

Process, not politics, should guide 401(k) investments. By providing vital asset-neutral, process-driven clarity to 401(k) investment selection, the proposed rule will help America’s retirement plan system remain strong and durable.

By Brian H. Graff

There is no shortage of attention surrounding the Department of Labor’s new rule on Fiduciary Duties in Selecting Designated Investment Alternatives.

Much of the early coverage has focused on whether the rule will open 401(k) plans to “risky” private-market investments. But that is not what this rule does; I believe it’s important to clarify what it actually does, and why the American Retirement Association (ARA) supports it on behalf of its members and the investing public. ERISA — the federal law governing workplace retirement plans — already permits private market investments.

Defined benefit pension plans, many of them maintained by unions for their members, have successfully used private market investments for decades. Even some larger 401(k) plans already use private-market investments as part of a managed portfolio that serves as a target-date fund for participants.

What the rule actually does is reinforce the strict ERISA fiduciary process — a framework that has long governed how retirement plan investment decisions are made and, importantly, one designed to protect participants. It does this by giving plan sponsors and their independent fiduciary advisors valuable clarity

about the decision-making process. The rule offers longneeded practical guidance on how these fiduciaries should approach investment selection, benchmarking, and ongoing monitoring.

And, importantly, it does this in an entirely asset-neutral manner, applying to all 401(k) investments equally. It does not require, favor, or suggest any particular asset class, including private markets. In fact, DOL’s proposed rule could just as easily apply to so-called “ESG investments” that were the subject of a regulation issued during the Biden Administration.

Put simply: this rule is not about expanding access to any particular investment. Rather, it reinforces the protective standards that govern how plan fiduciaries make decisions by providing a roadmap for investment selection, not a mandate.

Plan fiduciaries still must act solely in the interests of participants and beneficiaries, follow a prudent, welldocumented process, and continually monitor investment decisions over time.

Further, nothing in this rule shields private market investments from potential liability. If a retirement plan sponsor and their independent fiduciary advisors fail to satisfy ERISA’s strict fiduciary standard, they could still be subject to a participant class-

action lawsuit.  This is why no retirement plan fiduciaries are going to be haphazardly adding any new investment options into their plans.

So why is this rule so important?

Because it provides plan sponsors and their independent fiduciary advisors with the guidance they have been seeking to assist them in fulfilling their fiduciary responsibilities.

For those responsible for building and overseeing 401(k) investment lineups — plan sponsors and their fiduciary advisors — this clarity is not academic. It has real-world implications. Many younger 401(k) participants today will have retirement dates in 2050 or later.

Relying exclusively on an increasingly shrinking public market with performance heavily reliant on the “Magnificent 8” is likely not a sensibly prudent investment strategy over a 30year time horizon. In such cases, some exposure to properly vetted private market investments may make perfect sense.

Today and in the future, plan fiduciaries will need to navigate an ever-expanding array of investment products and strategies. The rule offers a durable roadmap, guiding decision-makers through these choices with clearer expectations.

The ERISA framework allows fiduciaries to exercise judgment, but it also requires that judgment to be grounded in a prudent process that puts participants first.

In doing so, it provides greater confidence in decisionmaking and reinforces participant protections by making the fiduciary process more explicit. It allows fiduciaries to evaluate investments thoughtfully, without guessing regulatory intent or overcorrecting out of caution. And it supports innovation without compromising participants’ financial interests.

The ERISA framework allows fiduciaries to exercise judgment,

but it also requires that judgment to be grounded in a prudent process that puts participants first.

By providing vital assetneutral, process-driven clarity to 401(k) investment selection, the proposed rule will help America’s retirement plan system remain strong and durable.

As the debate over this proposed rule unfolds, we hope sensible policy, not politics, drives the evaluation process. All should agree that keeping politics out of

401(k) investment decisions would clearly be in participants’ best interests.

We encourage members to review the proposal and consider how the guidance may impact their current fiduciary processes and investment practices.

ARA will continue to provide updates, analysis, and opportunities for member engagement as the rulemaking process moves forward. NNTM

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Trends ‘Setting’

Rising Social Security COLA predictions come as solvency concerns continue to grow. Can Private market assets make a difference? All this and more in this issue of ‘Trends Setting.’

On the Rise

Rising inflation points to a significantly higher Social Security COLA in 2027.

Based on the newly released inflation data for May, the Social Security cost-of-living adjustment (COLA) for 2027 could be a full percentage point higher than this year’s.

According to estimates by The Senior Citizens League (TSCL), the 2027 COLA could be 3.8% or 1.0 percentage point higher than this year’s COLA of 2.8%, based on the May Consumer Price Index (CPI) data from the Bureau of Labor Statistics.

This is also consistent with the organization’s projection from last month, which showed that the 2027 COLA could climb to 3.9% based on the data through April.

The Bureau of Labor Statistics (BLS) announced recently that the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is the index used to calculate the annual Social Security COLA, increased 0.7% in May, resulting in a 4.4% increase over the last 12 months.

The organization noted that, if a 3.8% COLA went into effect, the average benefit for retirees would rise by $77. Social Security currently pays the average retiree $2,026.41 per month. With the predicted COLA, payments would increase to $2,103.41.

In a separate estimate, Mary Johnson, a retired Social Security and Medicare policy analyst, predicts the Social Security COLA could be 4.7% or higher next year.

Johnson notes that inflation, as measured by the index used

to calculate the COLA, is growing at the fastest pace in four years, since 2022.

“This is hard to quantify as it hits consumers now, but it clearly is causing enormous cost pressures, especially difficult for low-income and older Americans living on fixed incomes,” says Johnson. Consumers are spending more at the supermarket but bringing home less every trip, she added.

“Social Security recipients received a 2.8% COLA this year, raising average monthly benefits of $2,000 about $56, but would need $94 per month to keep up with May inflation,” Johnson estimates.

Meanwhile, according to TSCL’s 2026 Senior Survey, also released today, 44% of retirees — or 24.8 million older Americans — depend

on Social Security for all their income, up from 39% in 2025.

“A 3.8 percent COLA might sound like a lot compared to last year’s 2.8 percent, but it won’t be enough to make up the difference between what seniors bring in and what they need to live with dignity. And that’s the point of the program: It’s to grant ‘some measure of perfection against the loss of a job and against poverty-ridden old age,’ as Franklin D. Roosevelt said when he signed Social Security into law 91 years ago,” TSCL Executive Director Shannon Benton said in a statement.

By law, the annual inflation adjustment is based on the average inflation during July, August, and September as measured by the CPI-W. The BLS averages the CPI-W for these three months and then compares it with the same time period from the previous year. The percentage difference between the two is the annual COLA, payable for checks received in January 2027.

The BLS also reported that the Consumer Price Index for All Urban Consumers (CPI-U) increased 0.5% on a seasonally adjusted basis in May, after rising 0.6% in April. Over the last 12 months, the all-items index increased 4.2% before seasonal adjustment.

The energy index rose 3.9% in May, after rising 3.8% in April and 10.9% in March. Perhaps not surprisingly, the energy index accounted for over 60% of the monthly all-items increase. The shelter index also increased in May, rising 0.3%, while the food index rose 0.2% over the month.

Johnson further observes that longer-term data trends indicate that the country hasn’t reached a peak yet. With four more months of data to come in, she noted that her estimate is likely to change before the COLA is announced in October.

It’s also worth noting again that the annual COLA adjustment is a precursor to how much the annual retirement plan contribution limits may increase next year.

- Ted Godbout

Contemplating the Cut

Social Security faces funding shortfall within 6 years without reform.

ACOLA increase won’t mean much if Congress doesn’t do something, and soon, about Social Security solvency.

If federal lawmakers fail to act in the very near future, the date on which Social Security will no longer be able to pay full benefits is only six years away, according

to the newly released Social Security trustees report.

The Old-Age and Survivors Insurance (OASI) Trust Fund reserves are currently projected to become depleted in the fourth quarter of 2032, which is one quarter earlier than projected last year. If Congress does not take any action before then, the Social Security Administration will be able to pay only 78% of benefits, according to the projections.

The Disability (DI) Trust Fund is projected to be able to pay 100%

of benefits through at least 2100, which runs to the end of the 75-year projection period. This is similar to last year’s report, which showed that the DI Trust Fund would be able to pay scheduled benefits through at least 2099, the last year of that report’s projection period.

If the OASI Trust Fund and the DI Trust Fund projections were combined, the resulting projected fund (designated OASDI) would be able to pay 100% of total scheduled benefits until the third quarter of 2034, unchanged from last year’s report. At that time, the projected fund’s reserves would become depleted and continuing combined fund income would be sufficient to pay 83% of scheduled benefits.

One thing to keep in mind, however, is that the trustees commonly refer to the combined OASI and DI trust funds, but those projections are hypothetical (and some could argue meaningless), as the two funds are for separate programs and are not combined. In fact, they could not actually be combined unless there was a change in the law; the report contends, however, that the combined projection is used to indicate the overall status of the Social Security program.

Meanwhile, the Hospital Insurance (HI) Trust Fund — or Medicare Part A, which helps pay for services such as inpatient hospital care — will only be able to pay full benefits until the second quarter of 2033, one quarter earlier than projected last year. At that point, that fund’s reserves will become depleted and continuing program income will be sufficient to pay 89% of total scheduled benefits.

The Supplementary Medical Insurance (SMI) Trust Fund is adequately financed into the indefinite future because, unlike the other trust funds, its main financing sources — enrolled beneficiary premiums and the associated federal contributions from the Treasury — are automatically adjusted each year to cover costs for the upcoming year. Although the financing is

assured, the report noted that rapidly rising SMI expenditures have been placing increasing demands on beneficiaries and general taxpayers.

“These insolvency dates may feel abstract and far away, but the reality is that the senators elected in 2026 will be in office when Social Security reaches insolvency. The question is no longer whether these challenges demand attention. It is whether Washington will find the will to act,” noted Margaret Spellings, president and CEO of the Bipartisan Policy Center, in a statement.

Notably, the report further explained that the projected long-term finances of the combined OASDI fund worsened this year primarily due to three factors. First, the assumed ultimate total fertility rate was lowered from 1.90 children per woman to 1.75 children per woman.

Second, estimated historical and assumed near-term and ultimate net total immigration are lower this year. These two demographic changes lowered the projected number of workers, projected taxable payroll, and projected GDP over the long range, the report noted.

And third, the One Big Beautiful Bill Act (OBBBA), enacted on July 4, 2025, made permanent the lower ordinary income tax rates and adjusted tax brackets originally passed under the 2017 Tax Cuts and Jobs Act. The legislation also increased and made permanent the larger standard deduction of the 2017 Act. The OBBBA also added a temporary additional standard deduction for taxpayers over age 65.

As a result of these provisions, the OASI and DI Trust Funds will receive lower levels of revenue in the future from income taxation of Social Security benefits, the report emphasized.

Other key statistics show that Social Security paid benefits of $1.6 trillion in calendar year 2025, and there were 70 million beneficiaries at the end of the calendar year. In addition, an estimated 185 million people had earnings covered by Social

Security and paid payroll taxes during 2025.

More specifically, total OASDI program income was $1.45 trillion, mostly from payroll taxes, including $1.3 trillion from payroll taxes; $58 billion from income taxation of Social Security benefits, and $69 billion from interest earnings.

Total OASDI program cost was $1.6 trillion, mostly for benefit payments, while $7 billion was for administrative expenses and $6 billion was used for the financial interchange with the Railroad Retirement program.

Total OASDI income for 2025 was $160 billion less than total cost. Trust fund reserves covered this shortfall, allowing for payment of all scheduled benefits. The reserves of the OASDI program (which are held in special issue U.S. Treasuries) declined from $2.7 trillion at the beginning of 2025 to $2.56 trillion at the end of 2025. Social Security’s cost has exceeded its non-interest income since 2010.

The projected actuarial deficit over the 75-year long-range period is 4.42% of taxable payroll — up from the 3.82% projected in last year’s report.

And once again, the Board of Trustees warned that policymakers need to act.

“Lawmakers have many options for changes that would reduce or eliminate the long-term financing shortfalls. Taking action sooner rather than later will allow consideration of a broader range of solutions and provide more time to phase in changes so that the public has adequate time to prepare,” the trustees noted.

The Board of Trustees is usually comprised of six members with four serving by virtue of their positions with the federal government: Scott Bessent, Secretary of the Treasury and Managing Trustee; Frank Bisignano, Commissioner of Social Security; Robert F. Kennedy, Jr., Secretary of Health and Human Services; and Keith Sonderling, Acting Secretary of Labor. The two public trustee positions have been vacant since 2015.

- Ted Godbout

Private Poise

Are private markets investments poised for broader adoption in DC plans?

New research finds a sharp rise in acceptance for the inclusion of private asset classes such as private credit and private real estate in defined contribution (DC) plan portfolios, especially within default funds.

According to PIMCO’s 20th annual DC Consulting Study, every aggregator firm surveyed now expects at least some plan sponsors to adopt private market exposure in their target date funds (TDFs) or managed accounts within the next 12 months. By comparison, last year’s study

found that only 37% of aggregator firms agreed with this sentiment. Additionally, nearly 6 out of 10 (57%) institutional consultants reported similar expectations.

The 2026 study captures data, trends and opinions from 36 consulting and advisory firms that serve over 53,000 clients with aggregate DC assets of more than $10.2 trillion.

PIMCO noted that these findings suggest that what was once a forward-looking idea has become a near-term reality for many DC stakeholders. Private credit was singled out as one of the top assets for inclusion, ranking as the first or second most likely private strategy to be added to multi-asset portfolios by

91% of aggregators and 52% of institutional consultants; this was ahead of other alternatives like private equity and real estate, the findings show.

And with adoption apparently poised to expand, DC intermediaries emphasize balancing return potential with asset quality, cost, and liquidity.

To that end, the study explained that both groups are evaluating private markets on factors such as risk-adjusted performance potential, manager quality, cost, and liquidity to ensure these additions align with the constraints of daily-valued, participant directed plans.

For example, aggregators place high importance on

Nearly 80% of DC intermediaries said their plan clients are willing to shift from all-active TDFs to blended TDFs, whereas only 27% see a willingness to move from all-passive to blends.

ensuring private allocations can meet DC liquidity standards, ranking it among their top five criteria alongside performance and quality; in contrast, institutional consultants put slightly less emphasis on plan-level liquidity features, the study noted.

Both groups also acknowledge that wider adoption will depend on external factors beyond plan sponsor demand. In this case, roughly 9 in 10 (89%) consultants cite the need for regulatory clarity and a well-defined fiduciary framework around privates as a major factor for increasing usage, and roughly three-quarters highlight the need for enhanced liquidity mechanisms, such as more frequent valuations or improved structures for daily flows.

Target Dates and QDIAs

The study further revealed that plan sponsors and their DC intermediaries continue to evolve the qualified default investment alternative (QDIA), with a focus on combining the best of active and passive management, tailoring solutions to plan needs, and expanding into new asset classes.

Both institutional consultants and aggregators overwhelmingly agreed that blended TDFs will be the most widely adopted QDIA option by plan sponsors in the coming three years.

PIMCO observed that this marks the second year in a row that blended TDFs topped DC intermediaries list of expected

QDIA trends, affirming a broad convergence toward QDIAs that leverage active management — particularly in asset classes like fixed income — while maintaining cost efficiency.

In fact, nearly 80% of DC intermediaries said their plan clients are willing to shift from all-active TDFs to blended TDFs, whereas only 27% see a willingness to move from allpassive to blends.

At the same time, demand for more tailored solutions continues to grow, according to the findings. Nearly half (46%) of aggregator firms anticipate increased adoption of fully customized TDFs, while 85% expect rising interest in participant-personalized TDFs as next-generation defaults.

Retirement Income

Plan sponsors are also broadening their adoption of inplan retirement income solutions and consultants expect this momentum to continue in 2026.

More than half (52%) of plans working with consultants already offer in-plan retirement income solutions, compared with 17% of plans advised by aggregators. PIMCO noted, however, that this appears to be on the verge of a significant change. Nearly all aggregators (93%) say it’s likely their clients will add nonguaranteed retirement income focused strategies, such as fixed income or multi asset strategies, in the next 12 months.

The study further observed that target date series with embedded lifetime income guarantees — essentially default TDFs that include an annuity component — are seen as the “next likely wave” in sponsor adoption of retirement income features. Both institutional consultants and aggregators picked TDFs with embedded annuities as a top candidate for new retirement-focused plan additions over the next year, “signaling an inflection point” where plan defaults might soon deliver guaranteed retirement income to participants.

“The motivation is clear, as participants approach retirement these guaranteed strategies can help manage longevity risk and generate steadier payouts,” the study noted.

Fixed-Income Options

Additional findings show that consultants and plan sponsors are seeking broader access to fixed income markets, suggesting that traditional core bond offerings alone are not fully representative of today’s opportunity set.

More than half of institutional consultants anticipate that most of their plan sponsor clients will add active non-core fixed income options, while 45% expect increased adoption of multi-asset inflation hedging strategies to investment menus.

“Fixed income markets have changed significantly over the last decade, but most DC plan menus still reflect a narrower, legacy opportunity set,” noted Rene Martel, Managing Director and PIMCO’s Head of Retirement. “What we’re seeing in this study is a clear shift: consultants and plan sponsors recognize that participants need access to a broader range of fixed income solutions in order to better navigate today’s market environment and improve longterm retirement outcomes.”

- Ted Godbout

September 27-29, 2026

Chicago, IL

NAPA

Spotlight Topic

PERCEPTION VS. REALITY IN THE DC SPACE

BY JOHN SULLIVAN

Through the Looking Glass— Perception vs. Reality in the Defined Contribution Space

What retirement plan providers want, and what plan participants need, often clash in the quest for greater personalization. What does the data actually say about recent innovation in the 401(k) space, and how can it help advisors achieve successful retirement outcomes for the clients with whom they work?

BY JOHN SULLIVAN

CONVENTIONAL

WISDOM IN THE RETIREMENT PLAN

INDUSTRY isn’t so conventional when observing actual data.

It often contradicts general agreement among product manufacturers and plan providers about the need—and demand— for certain products and services, compared with plan sponsor and participant attitudes.

While the development and messaging surrounding innovation in key areas continues to increase, adoption and utilization in those areas, at least for now, remain low.

There are several reasons why, including a lack of awareness and education from the investing public

about the products and strategies in question, advisor roadblocks for what they see as possible competitive threats, and plan sponsor reluctance over suitability issues that could lead to an increased risk of litigation, to name a few.1

It’s combined with the argument that 401(k) s and similarly styled defined contribution (DC) plans were developed as accumulation vehicles, and straying from this original mission by adding competing priorities could potentially cause plan sponsors and participants to lose focus.

“The primary goal of the first 401(k) savings plan I designed was to help middle-income employees save for retirement,”

retirement plan pioneer Ted Benna recently said.2

Yet, demand for retirement plan personalization is undoubtedly growing, fueled by the increasing use of artificial intelligence and a younger employee population accustomed to hyper-customization in the products and services they purchase, retirement benefits included.3

So, how is retirement plan personalization achieved in a manner that adheres to individual requirements, circumstances, and suitability without distracting from its original purpose—accumulation?

The following article will examine three industry “hot topics” (Retirement Income, Private Market Investments, and Accumulation/

Decumulation), and include MFS proprietary plan advisor, sponsor, and participant research.

The goal is to produce a more informed and complete picture of what participants actually want and need in the quest for greater personalization and, as a result, better retirement outcomes.

RETIREMENT INCOME

It’s a complex topic with a simple argument; provide an income stream that cannot be outlived, thereby reducing (or eliminating) longevity risk. Acting as a “paycheck in retirement,” retirement income—or lifetime income—products distribute consistent payments in a

manner similar to what an individual would receive in their working years.

These annuitized payments have several benefits, including lower stress and anxiety just before and during retirement, and the capacity for greater spending by the individual.4 They’re shielded from market volatility, often grow tax-free, and certain products offer cost-of-living adjustments (COLA) and other inflation protection options over time.

The demise of defined benefit (DB) pension plans and the rise of DC plans have federal regulators encouraging their availability in workplacebased retirement plans, and in September 2025, the Department of Labor (DOL) provided guidance for plan sponsors and fiduciaries that clarified their use as a qualified default investment alternative (QDIA).5

Product manufacturers and asset managers have long asserted that interest in these products (and their use within 401(k) plans) is high, yet their actual adoption is low.

According to the 68th Annual 401(k) Survey from the Plan Sponsor Council of America, only 8.9% of respondents had an inplan annuity in 2024, the latest year for which data is available.

Advisors are reluctant to recommend them, as well, and only 6% of advisors’ plans currently feature an in-plan income solution, and just 3% have an income component within their qualified default investment alternative (QDIA).6

REALITY CHECK:

MFS found that only 22% of advisors put “figuring out retirement income solutions” as a top concern.

– 2026 MFS DC Plan Sponsor Survey

So why aren’t they more popular, and why aren’t plan participants demanding them from sponsors?

Kelsey Mayo, Chief of Retirement Policy & Regulatory Affairs with the American Retirement Association (ARA), said that litigation risk is a key obstacle for fiduciaries.

“Litigation risk deters sponsors from using innovative products and plan enhancements and makes sponsors fearful of

doing anything outside the norm,” she explained.

Since using a retirement income option like an annuity isn’t required and (as the data show) isn’t common, fiduciaries, whether it’s the advisor, plan sponsor, or someone else, are apprehensive about taking on a product that could be construed as imprudent, Mayo added.

Aside from low awareness and education about the product, its potential, and availability in 401(k)s, part of the reason for low demand among participants might be the name—annuity. Traditional objections, such as high fees and the perception that they favor the manufacturer at the expense of the annuitant, make the branding problematic. Research and consulting firm Greenwald & Associates routinely

finds a disconnect in perception between an unnamed product that lists the benefits that annuities provide and an annuity itself.

“Stigma around the name ‘annuity’ remains,” Founder and Managing Director Mathew Greenwald wrote. “The gap between the appeal of an unnamed product and a guaranteed lifetime income annuity remains, with a third of consumers decreasing their level of interest when the word ‘annuity’ is used. Finding ways to rehab the ‘annuity’ name should be a priority, starting with framing it as part of a broader retirement income strategy.”7

Indeed, the “rehab” is already underway, and the reason terms like retirement income and lifetime income are in wider use.

“The gap between the appeal of an unnamed product and a guaranteed lifetime income annuity remains, with a third of consumers decreasing their level of interest when the word ‘annuity’ is used. Finding ways to rehab the ‘annuity’ name should be a priority, starting with framing it as part of a broader retirement income strategy.”

PRIVATE MARKET INVESTMENTS

Whether to include private market investments (alternative investments) as an investment option in 401(k)s has generated a considerable amount of discussion among industry stakeholders, regulators, and the financial press. Private market investments are equity or debt in privately-owned companies that do not trade on public stock exchanges. They include private equity, private credit, infrastructure, and real estate, among other asset classes.

In August 2025, President Trump issued an executive order (EO14330) to encourage their inclusion within defined contribution plans. It resulted in a proposed rule from the DOL “that clarifies, and provides a safe harbor for, a fiduciary’s duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA) in connection with selecting designated investment alternatives for a participant-directed individual account plan, including asset allocation funds that include alternative assets.”8

Typically reserved for high-net-worth individuals with significant investable assets, proponents argue that a “democratization” of private market investments is needed and should be structured in a professionally managed account and made available

“Typically reserved for high-net-worth individuals with significant investable assets, proponents argue that a “democratization” of private market investments is needed and should be structured in a professionally managed account and made available to retail investors within 401(k) plans.”

to retail investors within 401(k) plans.

They add that DB plans have successfully incorporated private market investments for decades, which have delivered higher risk-adjusted returns and diversification benefits.

They further note that investment opportunities in public companies have shrunk while those in private companies have grown. There are half as many U.S. publicly traded companies as there were in the 1990s, more companies are going public later, choosing to stay private

during their highest growth phase, and nearly 87% of firms with more than $100 million in revenue a year remain private.9

REALITY CHECK:

Just 6% of sponsors told MFS that inclusion of private assets is “extremely/very important” for outcomes; 73% say “not very” or “not at all.”

– 2026 MFS DC Plan Sponsor Survey

Critics counter that private market investments have higher fees, are complex and difficult for the average retail investor to understand and include unsuitable illiquidity requirements. Low awareness and demand from the general investing public have critics further arguing that the asset classes are “sold rather than bought,” meaning marketed by investment managers hungry for the potential sales opportunities they offer.

“Who’s pushing for private market investments in 401(k) plans?” highprofile tort lawyer Jerry Schlichter, founder and managing partner of Schlichter Bogard LLC, recently (and rhetorically) asked. “Not AARP, not the Pension Rights Center, or unions. It’s private equity managers who want to tap into $6 trillion in 401(k)plans. There are no advocates for ordinary investors who want it.”10

ACCUMULATION/ DECUMULATION

Few retirement plan innovations have done more to help people save than the so-called “autorevolution”—automatic enrollment, deferral, and escalation.

Introduced as part of the Pension Protection Act (PPA) of 2006, they revolutionized workplace retirement savings plans by encouraging employers to require employees to “opt

out” rather than “opt in” to 401(k) plans.

Auto-enrollment, specifically, is shown to increase savings rates by roughly 2% per year in the first 5 years of plan investment.11

Yet financial professionals (and their clients) are increasingly concerned about withdrawing accumulated assets in a sustainable manner that provides an affordable, high-quality of life in retirement without depleting them too quickly.

Often compared to a football game, the accumulation period during working years is only the first half, with effective decumulation the second half in the quest to reach the goal line. It’s one reason for the development of the previously discussed retirement income products, as well as for “to” versus “through” target-date fund glidepaths.

Decumulation strategies are essential to successful retirement outcomes, yet 401(k)s (and defined contribution plans in general) are—again— primarily accumulation vehicles, something plan sponsors, advisors, and participants should not lose sight of.

So, how is an effective balance achieved, one that provides necessary resources in retirement without sacrificing the accumulation focus?

Professional financial advice has been shown to make a material difference in retirement savings and outcomes, but it involves more than just dollars and cents. It’s a process that

can add value through behavioral coaching, asset allocation, periodic rebalancing, spending/ withdrawal strategies, and asset location, leading to an almost immeasurable benefit—participant peace of mind.

Indeed, this “advisor alpha” can add an estimated 1.5% to 3% in net annual value to a retirement portfolio versus a do-ityourself approach.12

REALITY CHECK:

Plan sponsors value personalized advice twice as much (70% saying it is “extremely/ very important for outcomes”) versus in-plan retirement income solutions (34%).

– 2026 MFS DC Plan Sponsor Survey

Active management can also positively affect the accumulation process through key benefits such as integrated fundamental research, risk management, longer-term conviction, and the ability to capitalize on market inefficiencies.

Active management is part of MFS Investment Management’s QDIA solutions, anchored by the MFS Lifetime® Funds, a series of target-date mutual funds.

The suite utilizes an active management approach with a “toretirement” glide path that aims for long-term growth before shifting to a more conservative allocation upon

reaching the target date. Key Features of MFS Lifetime Funds include:

• Active Management: The series are built with actively managed underlying MFS funds, allowing the managers to seek alpha rather than solely tracking benchmarks.

• Glide Path Strategy: The funds follow a “to-retirement” glide path. In the early years, they maintain higher equity allocations to maximize capital appreciation to help build wealth during participants’ long-time horizons. In the later years, they adjust risk gradually, transitioning to a conservative allocation at retirement,

protecting participants’ capital when they need it most.

• Diversification: The series span geographies, styles, market caps, investment approaches, credit quality, and duration, maintaining exposure to equities, fixed income, and nontraditional asset classes depending on the horizon.

• Breadth of Capabilities: MFS offers multiple share classes (including Class R6 and Class I) and vehicle options (mutual funds and collective investment trusts) tailored for institutional retirement plans and defined contribution platforms.

11 How Much Does 401(k) Auto-Enrollment Help Workers Save for Retirement? Munnell, Alicia. crr.bc.edu. January 9, 2025.

12 “The Value of a Financial Advisor.” Bergenn, Eric. bergenn.com. February 13, 2025

Before investing, consider the fund’s investment objectives, risks, charges, and expenses. For a prospectus, or summary prospectus, containing this and other information, contact MFS or view online at mfs.com. Please read it carefully.

Important Lifetime Fund Risk Considerations: The fund may not achieve its objective and/or you could lose money on your investment in the fund. You may experience losses near, at, or after the target date. There is no guarantee of the fund’s principal value, including at the target date, or that the fund will provide adequate income at and through your retirement. Stock: Stock markets and investments in individual stocks are volatile and can decline significantly in response to or investor perception of, issuer, market, economic, industry, political, regulatory, geopolitical, environmental, public health, and other conditions. Bond: Investments in debt instruments may decline in value as the result of, or perception of, declines in the credit quality of the issuer, borrower, counterparty, or other entity responsible for payment, underlying collateral, or changes in economic, political, issuer-specific, or other conditions. Certain types of debt instruments can be more sensitive to these factors and therefore more volatile. In addition, debt instruments entail interest rate risk (as interest rates rise, prices usually fall). Therefore, the portfolio’s value may decline during rising rates. Portfolios that consist of debt instruments with longer durations are generally more sensitive to a rise in interest rates than those with shorter durations. At times, and particularly during periods of market turmoil, all or a large portion of segments of the market may not have an active trading market. As a result, it may be difficult to value these investments and it may not be possible to sell a particular investment or type of investment at any particular time or at an acceptable price. The price of an instrument trading at a negative interest rate responds to interest rate changes like other debt instruments; however, an instrument purchased at a negative interest rate is expected to produce a negative return if held to maturity. International: Investments in foreign markets can involve greater risk and volatility than U.S. investments because of adverse market, currency, economic, industry, political, regulatory, geopolitical, or other conditions. Underlying Funds: MFS’ strategy of investing in underlying funds exposes the fund to the risks of the underlying funds. Each underlying fund pursues its own objective and strategies and may not achieve its objective. In addition, shareholders of the fund will indirectly bear the fees and expenses of the underlying funds.

Sponsor Spotlight

A discussion with MFS Lead Retirement Strategist and Managing Director Jeri Savage.

Q Research suggests a disconnect between industry enthusiasm for products like retirement income solutions/private market investments and actual demand. What’s driving that ‘perception’ gap?

A That gap is largely driven by a mismatch between industry conversation and sponsor priorities. The strongest evidence in our research is that sponsors still see better retirement outcomes as coming first from the fundamentals: participation, deferral rates, diversification, and staying invested over time. 70% of sponsors say personalized advice is very or extremely important to improving outcomes, versus just 34% for retirement income solutions and 6% for private assets. In other words, the industry may be innovating quickly, but most sponsors are still focused on simpler, more immediate ways to improve participant readiness.

Q Retirement income products are marketed as a way to reduce longevity risk and provide retirement ‘stability,’ yet adoption remains low. Why, and what are the current barriers to greater adoption?

A Adoption remains low in part because many sponsors are still unconvinced that an in-plan retirement income solution fits the realities of their participant base. One barrier is philosophical:

more than half of sponsors say they are neutral about keeping retirees in the plan, which makes it harder to design around long-term in-plan distribution. Another is practical: many of the solutions currently available still feel complex, difficult to explain, or insufficiently flexible for a participant population with highly varied needs. And perhaps the biggest issue is that a DC plan is often only one piece of an individual’s broader retirement puzzle, alongside Social Security, personal savings, spousal assets, and sometimes legacy DB benefits. Trying to solve for retirement income inside only one component can miss the bigger picture. That is why many sponsors still appear more comfortable treating the DC plan primarily as a strong accumulation vehicle, while using advice, planning, and optional distribution tools to help participants build a more complete income strategy.

Q Do average defined contribution participants actually want private market investment offerings, or is this more industry-driven?

A Right now, the evidence suggests private market demand is much more industry-driven than participant-driven. Sponsor interest remains limited: According to MFS’ DC Plan Sponsor Survey, only 4% are likely to implement private assets in the next 12 to 24 months, and just 6% view their inclusion as very or extremely

important to better participant outcomes. Most sponsors say participants are not asking for access to private or digital assets, and when they do ask, it is often to understand headlines rather than to gain actual exposure. That matters because defined contribution plans succeed when participants can use investments clearly and appropriately. Private markets may eventually earn a role in some structures, but today the data suggest they are still far from a mainstream participant need.

Q Do you agree that the industry risks overcomplicating the 401(k)’s original mission primarily as an accumulation vehicle, or is a more ‘holistic approach’ (accumulation/ decumulation) inevitable?

A Yes, there is a real risk of overcomplicating the 401(k)’s core mission. The strongest retirement outcomes still start with accumulation: getting participants into the plan, encouraging appropriate savings rates, diversifying prudently, and helping people stay invested through volatility. That is why target-date funds remain so dominant, with more than 90% of plans offering them and 86% using them as the QDIA, according to MFS’ DC Plan Sponsor Survey. At the same time, a broader conversation about decumulation is inevitable as the workforce ages. The

better answer is not to replace accumulation with a more complicated framework, but to build around it. In practice, that means keeping TDFs and core plan design focused on long-term accumulation while adding optional tools, advice, and withdrawal support for participants whose needs become more individualized near or in retirement.

Q We hear so much about the value of personalized advice. How important is human guidance in helping participants make retirement decisions, and can technology alone realistically fill that role?

A Human guidance remains extremely important, especially as retirement decisions become more complex and personal. Sponsors clearly recognize that: nearly three-quarters of plan sponsors say they offer access to an advisor in some form, MFS’ DC Plan Sponsor Survey found. Participants appear receptive as well, with 71% saying they would use advisory help if their employer offered it. Technology can do a great deal, but it may not fully replace human judgment, particularly when participants face tradeoffs around spending, timing, risk, and income in retirement. The next phase is likely not human versus technology, but human guidance supported by technology so advice can remain both personal and scalable.

Use AI

By Rebecca Hourihan AIF, PPC

As a 401(k) advisor, you understand that your business development campaigns are about building trust with employers, helping plan sponsors see what their plan may be missing, and showing up with relevance that a CFO, HR leader, benefits committee, or business owner thinks, “This advisor understands our company.”

That is where AI can help. AI will not replace your experience with fiduciary process, investment menus, participant outcomes, fee benchmarking, plan design, payroll integration, or committee education. But it can absolutely help you communicate more clearly and personalize your outreach.

Motivation. Insight. Action:

10 Ways 401(k) Advisors Can

Enjoy AI, but do not confuse a helpful tool with hard-earned 401(k) experience.

To get started, let’s think of your sales pipeline in four phases: awareness, interest, decision, and action. In each phase, we will explore how AI can slide in and support you.

Awareness

1. Build Smarter Prospect Lists

Use AI to help segment employers by industry, employee demographics, geography, Form 5500 codes, and retirement plan needs.

For example, a fast-growing construction company may care about employee retention and reducing plan loans. Whereas a professional services firm may care about Roth Catch-up contributions. AI can help you tag prospects into niche outreach themes

instead of a macro-distribution strategy.

2. Turn Pain Points into Content

Ask AI to brainstorm a blog, webinar, LinkedIn, or email topic around real 401(k) issues: low participation, investment questions, fee reasonableness, and fiduciary risk.

3. Repurpose One Idea into Five Marketing Assets

A great 401(k) insight should not live once and then disappear. Use AI to turn one topic into a LinkedIn post, email campaign, webinar, checklist, and call script. For example, your article on “Improving Participant Outcomes Without Increasing Employer Cost” can become a short video

outline, a prospecting email, and a meeting agenda for your upcoming plan reviews.

Interest

4. Personalize Outreach Using the Prospect’s Own Words

This is one of the most practical uses of AI that we’ve heard from 401(k) advisors.

Copy and paste the prospect company’s website, careers page, social media pages, or other information into your favorite AI tool. Then ask it to identify the company’s priorities, tone, employee value proposition, and possible retirement plan conversation starters.

For example, if a company says, “We invest in our people and build long-term careers,” do not lead with, “We help reduce 401(k) fees.” Lead with their message.

Try: “I noticed your website emphasizes long-term careers and investing in your people. A strong 401(k) plan can reinforce that promise by helping employees build a healthier retirement with [Company Name]. Would you be open to a quick conversation next week?”

Use their words in your RFP reply, pitch deck, meeting openers, and email correspondence. Not to manipulate, but to show that you paid attention.

5. Create Better Discovery Questions

Before the 1st meeting, ask AI to generate discovery questions for that specific employer type. Here are examples: a local manufacturing company may need questions about hourly employee engagement, multilanguage financial education, and workforce turnover. A medical group may need questions about highly compensated employees, profit sharing, cash balance coordination, or senior-level savings options.

You still need to know which questions matter, but AI can help you prepare faster.

6. Draft Specific Follow-Up Emails

After a call, AI can help summarize conversation topics and draft a clear next-step email.

Give it your notes: “The HR director is frustrated with low participation, the committee has not benchmarked fees in three years, and payroll integration has been very clunky.” Then ask for a concise follow-up that confirms what you heard, outlines the next step, and positions your process around participant engagement, fiduciary support, and measurable plan improvements.

Decision

7. Improve Your RFP Response

AI can help turn technical, hard-to-explain retirement plan knowledge into clear, friendly language.

For example, when responding to an RFP question about fiduciary process, AI can help organize your answer around committee governance, investment monitoring, fee benchmarking, documentation, participant education, and service accountability. You supply your experience and substance. AI helps with clarity, flow, and formatting.

8. Build a Stronger Pitch Deck

Customize your 401(k)-finalist presentation for that specific prospect.

AI can help you connect your solution with the plan sponsors’ goals. If the prospect talks about retention, make the retirement plan a part of their long-term retention story/strategy. If they talk about financial wellness, show how your employee education campaigns align with their objective.

9. Practice Objection Handling

Use AI as a role-play partner. Ask it to act like a skeptical CFO, an overworked HR director, or a committee member worried about advisor transition. Practice answers to questions like, “Why should we change advisors?” “How

will this reduce our workload?” “What makes your participant education better?” The goal is not to memorize scripts. The goal is to sharpen your thinking before you get into the room.

Action

10. Buildout Onboarding Timelines

After a plan sponsor says yes, AI can help organize timelines, communication drafts, FAQ documents, and education calendars.

For example, it can create a 90-day transition communication plan with separate messaging for executives, HR, employees, and committee members. It can help draft participant emails about enrollment meetings, investment options, and savings rate best practices.

AI helps with the first draft. Your team has the experience to review, edit, and approve.

Experience vs AI

AI is wonderful for drafts, ideas, outlines, brainstorming, personalization, and a little extra creative energy. It can help you write the follow-up, polish the pitch, organize the meeting notes, and get to a better first draft faster.

But AI is not a 401(k) advisor, and the same is true for marketing.

AI can help with the words. Experienced retirement plan marketing professionals know how to build the campaign. They know how to shape the message, sequence the outreach, coordinate the moving pieces, support the sales process, respect compliance requirements, and turn a good idea into measurable business development activity.

So, use AI. Enjoy it. Let it add spark, speed, and fresh thinking to your business. Let it help you show up sharper for plan sponsors, participants, and prospects. Just do not confuse a helpful tool with hard-earned 401(k) experience.

Thanks for reading & Happy Marketing!

Helping your clients clean up small-balance accounts

In today’s workforce, employees’ first jobs are rarely their last. In fact, the average tenure of employees is less than four years, leaving employers to grapple with a growing number of small-balance retirement accounts left behind by former employees. And according to a 2024 survey, more than 60% of plan sponsors are concerned about the number of missing or non-responsive participants in their retirement plans — in particular, tracking them down when their distribution checks go uncashed. Here are two strategies that can help your clients resolve these issues.

Strategy 1: Advise your clients to set up a cash-out policy

The U.S. Department of Labor allows employers with 401(k)s, 403(b)s, or similar retirement plans to cash out former employees’ small-balance accounts of $7,000 or less. But having a mandatory distribution is not required, so employers can choose to allow former employees to remain in their retirement plans regardless of their account balance. Alternatively, employers can force ex-employees out if their retirement account balances are between $1,000 and $7,000 and cash out small-balance accounts of $1,000 or less via checks.

There are three problems associated with allowing former employees’ small-balance accounts to remain in retirement plans:

• Retirement plans with transitory participants’ small-balance accounts often generate higher administrative fees.

• Employers continue to be fiduciarily responsible for ex-employees’ small-balance accounts, therefore elevating fiduciary risk.

• For small plans, the presence of former employees’ small-balance accounts may put them at risk of plan audits.

Here’s how you can help your clients navigate these challenges:

• Work with your clients to change their retirement plans’ mandatory cash-out limit to $7,000 or less and implement an automatic rollover IRA program. This will allow your clients to roll over ex-employees’ retirement savings into safe harbor IRAs if those individuals don’t specify what they want to do with their money.

• Inform your clients of the consequences of cashing out retirement account balances of $1,000 or less with checks: uncashed checks. Suggest that they consider rolling over small-balance accounts of $1,000 or less into safe harbor IRAs. This will minimize uncashed checks and help decrease plan maintenance, plan fees, and fiduciary liability.

Strategy 2: Suggest ways to help minimize forgotten retirement plan accounts

When small-balance retirement plan accounts belonging to missing and non-responsive participants remain in retirement plans, there are usually two root causes: 1) employees’ obliviousness to the existence of their retirement plan accounts and 2) outdated employee contact information. A couple of tactics can address these issues:

Changing the employee offboarding process

When individuals voluntarily terminate their employment, many are subjected to exit interviews. Most exit interviews are almost entirely focused on employers: how to improve their brand, culture, and policies to attract and retain valuable employees. But it could also be an opportunity for employers to do the following:

• Remind departing employees of their retirement plan account

• Update contact information

Suggest that your clients adjust the exit interview process to help minimize the number of small-balance accounts left behind and ensure that contact information is current. The payoff — fewer missing participants, lower administrative costs, and cleaner plans — can be significant.

Helping your clients clean up small-balance accounts

Using search services

Plan sponsors have a fiduciary duty to search for missing or non-responsive participants. For employers whose workloads are already brimming with issues involving current employees, this can be a sizeable challenge. In the absence of exit interviews or other options to update employees’ contact information before they leave, advise your clients to work with a third-party search services provider. The right search services provider employs several methods to find people and can help clean up clients’ retirement plans by reconnecting missing plan participants with their retirement savings — allowing them to build a more secure financial future.

When you help your clients take a more proactive approach with retirement plan management, you’re not just solving an administrative problem. You’re protecting plan participants who don’t realize they need protection.

When Polish Is Free, Experience Is Your Moat

Here’s my question: What happened in your practice this week that an AI could never have written about?

By Spencer X Smith

In 2011, I was a 401(k) wholesaler covering four named accounts in Chicago. Social media wasn’t yet prominent, and compliance definitely hadn’t approved its use by advisors. An advisor posting on LinkedIn back then? That was a fast track to an awkward phone call with the home office.

One advisor I worked with built a strategy that almost no one else did. He proactively hunted for local speaking events. Rotary clubs, chambers of commerce, industry lunches, you name it. It didn’t matter who was in the audience, even when the room didn’t fit his “target” demographic at all.

Why would a retirement plan advisor spend his afternoons presenting to people who’d never hire him?

He knew public speaking forced him (in a good way) to do two things:

1.) “Perform” his knowledge in front of an audience, thereby getting in more reps.

2.) Codify what were often disparate ideas into a cohesive presentation.

The speaking built his brand, sure. But the bigger benefit was internal: it forced him to think about his thoughts, if you will. Ideas that lived as instincts in his head had to become sentences other people could follow. Every

audience question revealed a gap, and every confused face in the third row told him exactly where his explanation broke down.

He got better, really, really fast. Not because he read more than his competitors. Because he performed more.

Public speaking is still important and valuable. I’ve built a large part of my career on it. But here’s what’s changed: social media now lets you perform that same content on video, recorded or live, and reach people anywhere. Same discipline … infinite reach.

And here’s the ironic part. The channel compliance wouldn’t let us touch in 2011 is now your best differentiation tool.

Why does this matter more right now than it did even a year ago?

Because AI-generated content is flooding every feed you’re on. Polished posts, slick graphics, even full video with synthetic presenters (aka “avatars” that look and sound like real people). The cost of producing professionallooking content has dropped to nearly zero, and the volume is exploding accordingly. Anyone can now publish something that looks credible.

Said another way: Polish used to be a signal of effort. Now it’s free.

Plan sponsors and participants are getting better at sensing

generic content, even when they can’t articulate why. They scroll past it the same way you scroll past a templated cold email. Something about it feels manufactured, because it is.

So, if polish is free, what’s left?

Your lived experience.

An AI model can generate a perfectly competent post about fiduciary best practices. It can write ten of them before you finish your coffee. What it can’t do is describe the plan committee meeting that went sideways last Tuesday. It can’t recount the participant question that stumped you during an enrollment meeting, or the hallway conversation afterward that changed how you explain Roth deferrals. Only you can share those.

That’s the moat. Not your credentials, and not your production quality. Your reps. Now, I know what you might be thinking, “I’m not a content creator.” Right, and that advisor in Chicago wasn’t a “public speaker” either. He was an advisor who used speaking as a forcing function. You’re not becoming an influencer. You’re doing exactly what he did, on a stage that happens to fit in your pocket.

The second objection is the bigger one: “Compliance won’t let me.”

In 2011, that was true. It’s not 2011 anymore. Most brokerdealers and RIAs now have

social media policies, archiving tools, and approval workflows because they’ve seen this channel become the place where plan sponsors actually do their homework on advisors. And sharing an anonymized lesson from a committee meeting is very different from giving specific investment advice. Work within your firm’s policy, not around it. If your policy is genuinely silent on video, that’s a conversation worth starting this month, because your competitors’ firms have already had it.

Okay, so what does this look like in practice?

1. Once a week, record a 60-90 second video recapping one real (anonymized) conversation from your week and the lesson inside it. One take. Don’t edit it to

death. The slightly imperfect delivery is proof that a human made it.

2. Treat every plan committee meeting as source material. Walk out asking yourself one question: “What surprised me?” If it surprised you, with everything you’ve seen, it’ll be genuinely useful to a plan sponsor who’s seen far less.

3. When industry news breaks, don’t summarize the news. AI does that instantly, and so does everyone else in your market. React instead with what you’re actually seeing. “Here’s what this means for the committees I sat with this quarter” beats a recap every single time.

4. Start with a recorded video before going live. The advisor in Chicago didn’t

book a keynote on day one. He got his reps in small rooms first. Recorded video is your small room.

Notice what all four have in common. None of them requires you to be clever. They require you to have done the work, then say what you saw.

That advisor I worked with fifteen years ago understood something most of us are just now catching up to. Performing your knowledge isn’t really about the audience in front of you. It’s about what the performance forces you to become: clearer, sharper, more concrete. The stage got bigger. The discipline didn’t change.

So, here’s my question: what happened in your practice this week that an AI could never have written about?

That’s your next post. NNTM

The Retirement ‘Hunger Games?’

Buried inside this grim arithmetic are some surprisingly encouraging signs — and you don’t have to look very far.

By Nevin Adams

Retirement surveys tend to read like actuarial obituaries — a long litany of percentages chronicling regret, anxiety, and insufficient preparation. Unless, of course, you look at the underlying data. A recent survey from Schroders[i] offers plenty of the former; inflation remains public

enemy No. 1; healthcare costs continue to ambush expectations — and more than half of retirees apparently have no idea how long their money will last.

But wait.

Buried inside that grim arithmetic are some surprisingly encouraging signs — and you don’t have to look very far.

For instance, yes, the survey

says that 58% of retirees[ii] don’t know how long their savings will last. Which means … 42% actually do (or at least claim to).

Given the complexity of retirement income planning — sequence risk, inflation assumptions, healthcare shocks, longevity projections, required minimum distributions, tax strategy, market volatility, and

the occasional Congressional “enhancement” — it’s arguably remarkable (if just a tad unbelievable) that nearly half of retirees feel they have at least some handle on the runway ahead.

Likewise, while only 4% describe themselves as “living the dream,” another 37% say they’re “comfortable,” and 35% report life is “not great but not bad.”

Put differently, roughly 3 out of 4 retirees are somewhere between stable and genuinely content, despite years of inflation headlines and constant (dare I say incessant, strident) warnings about retirement catastrophe. Not that the press release positioning — or media reporting — conveys that sense.

Yes, NEARLY 1 in 5 say they are struggling financially. But that means that more than 4 in 5 … aren’t.

And perhaps most notably, 79% say retirement gives them freedom to pursue passions and hobbies, while 68% say leaving work opened the door to trying new things.

That matters.

Because for years, retirement industry messaging by both the provider community AND the industry trade press (and don’t even get me started on mainstream media) has leaned heavily into fear: fear of outliving assets, fear of healthcare costs, fear of market crashes, fear of claiming Social Security “wrong,” fear of not saving enough, fear of spending too much, fear of spending too little. Signs of comfort or confidence are routinely dismissed as “naïve” or uninformed. Indeed, the industry’s dominant emotional tone has often been less “golden years” and more “financial Hunger Games.”

To be clear, the concerns reflected in the survey are real. [iii] Ninety percent worry about

Roughly 3 out of 4 retirees are somewhere between stable and genuinely content, despite years of inflation headlines and constant (dare I say incessant, strident) warnings about retirement catastrophe.

inflation eroding assets. Eightyseven percent worry about healthcare costs. Eighty-one percent fear a major market downturn. Those aren’t irrational anxieties — especially when retirees report spending 16% of monthly income on healthcare alone, and most say they expected Medicare to cover more than it does.[iv]

Still, there’s an important distinction between financial pressure and personal despair.

• A rational retiree can be worried and happy.

• Concerned and fulfilled.

• Budget-conscious and optimistic.

The survey quietly reflects that complexity — but the positioning treats those as polar opposites. And while nearly two-thirds (64%) of retirees wish they had done more planning, exactly how

much planning for those kinds of uncertainties would anyone ever consider to be…enough?

In other words, the picture is neither utopia nor dystopia.

And, despite the industry press coverage, retirement today appears to be what it has probably always been: a balancing act between financial uncertainty and personal freedom.

The difference is that today’s retirees are navigating that balance in public, against a backdrop of inflation spikes, market volatility, and relentless media narratives warning that disaster is just one bad CPI report away.

Yet somehow, most retirees still manage to find meaning in their retirement.

And maybe that’s the real headline here. Or should be. NNTM

Your clients look to you for retirement guidance they can count on. You can look to T. Rowe Price.

Blending

BEYOND THE

MORE COMMON GROUND THAN CONFLICT IN THE DOL INVESTMENT SELECTION DEBATE

DIVIDE BEYOND THE

A final rule that clearly reinforces ERISA’s process-based, asset-neutral framework can provide the clarity fiduciaries need and the protection participants deserve.

BY KELSEY MAYO

The public debate over the Department of Labor’s proposed investment selection rule has generally been

framed as a clash between two irreconcilable camps: one seeking solely to add alternative investments and

one seeking solely participant protections.

Neither is accurate. The comment record tells a much more interesting story.

Yes, commenters disagreed — sometimes sharply — about alternative investments, litigation risk, and the strength of the proposed safe harbor. But the most substantive letters do not reflect a binary choice between fiduciary discretion and participant protection. They reflect a shared recognition that both depend on the same thing: a clear, rigorous, administrable fiduciary process.

That is the real through-line of the comment record. The question is not whether ERISA fiduciaries should have discretion to make decisions or whether participants should be protected. The question is how the final rule can make clear that discretion exists in a meaningful fiduciary process — and that participant protection is provided through that process.

The Shared Lens: A Strong Fiduciary Process

Commenters from all walks — financial services, investment management, consumer groups, and industry groups — were broadly supportive of ERISA’s framework. They emphasized that ERISA prudence has long been grounded in process and that a fiduciary is required to engage in a prudent process based on the facts and circumstances at the time.

The proposed rule is relatively narrow. It addresses a fiduciary’s ERISA duty of prudence when selecting the available investment options

for a participant-directed defined contribution plan. It identifies a series of factors that fiduciaries need to consider — performance, fees, liquidity, valuation, benchmarking, and complexity — and provides a process-based framework under which fiduciary judgments may receive deference.

More supportive commenters viewed the proposal as providing potentially helpful clarifications and details regarding how a fiduciary satisfies ERISA’s duty of prudence. Many raised concerns about where the safe harbor might be interpreted as limiting the fiduciary’s appropriate considerations if the examples are read too prescriptively.

More critical commenters approached the proposal from a different angle, not a different universe. Many raised concerns that the safe harbor could be read to limit the need for fiduciary analysis; that certain examples could be interpreted as encouraging a certain asset class (namely, alternative investments), thereby influencing fiduciary decisionmaking; or that the rule could weaken participant protections if courts treat procedural compliance as conclusive.

The common ground is obvious: fiduciary process matters. It was a nearly universally accepted starting point and preserving a strong process, a universal objective.

Process Is the Protection

One of the most important misconceptions in the debate is the idea that a process-based rule is

somehow in tension with participant protection.

It is not.

Under ERISA, the fiduciary process is the participant protection. ERISA’s prudence standard is widely regarded as the highest duty known to law. A fiduciary must evaluate the relevant facts, understand the investment, compare appropriate alternatives, assess risk and value, consider fees, examine liquidity and valuation, and determine whether the investment fits the plan and its participants. If an investment cannot withstand that analysis, it should not be selected.

That is fundamentally different from a “check-the-box” exercise. That is fiduciary prudence.

The concern raised by some commenters is that the final rule could be read to bless a thin, rote, or disconnected process. Or that a formal process could be treated as conclusive — even where the underlying decision lacks substantive support.

I didn’t read a single letter supporting the rule that suggested that should be the outcome. The number of adjectives the proposal uses to say the fiduciary must engage in a robust review of the enumerated factors and other relevant considerations suggests the Department agrees as well.

So, there is alignment on the desired outcome here — prudence should require more than thin consideration; it requires a substantive, informed, reasoned fiduciary analysis. And that robust fiduciary analysis is (as it has been through the decades

under ERISA) strong protection for participants.

Asset Neutrality Is Not Asset Promotion

The proposal has also become a proxy debate over private markets, digital assets, and other alternative investments. Perhaps that was inevitable, given the executive order that preceded the rulemaking.

But here again, the comment record shows more convergence than the headlines suggest.

Supportive commenters generally argued that ERISA should remain assetneutral. Fiduciaries should (perhaps must) consider all legal investment options, and the government should ensure it stays out of the business of sanctioning or vetoing any particular asset class.

Critical commenters, meanwhile, warned that private markets and other alternative assets may involve higher fees, limited liquidity, valuation challenges, complexity, and reduced transparency.

But the two positions aren’t really so different. Aside from alternative asset managers, the supportive commenters were not extolling the glories of alternative assets — they were extolling their faith in fiduciaries. They largely agreed that all the factors raised by critical commentators were real, legitimate fiduciary considerations.

The difference, perhaps, is that more supportive commentators believe that, when given asset-neutral guidance, fiduciaries will engage in a prudent process and make the right call (as they have been doing for decades). And therefore, the Department rightly kept the relevant question as whether the fiduciary prudently evaluated the investment option.

So, the difference among commenters is not their faith in certain asset classes — but rather their faith in the fiduciaries and the ERISA standard. An asset-neutral rule does not mean every investment is appropriate. It means that no investment is

automatically in or out, and fiduciaries must be the ones to decide — as the statute requires and as they have been doing through all the changes in asset classes since the dawn of ERISA.

The Safe Harbor Should Guide, Not Dictate

Many commenters — supportive and critical alike — focused on how the safe harbor will operate in practice. That focus is appropriate. A safe harbor can reduce uncertainty, but if drafted too rigidly, it can also become the very checklist it was intended to avoid. The safe harbor construct is likely the area of greatest disagreement, but not as much as you might think at first blush.

Several implementation points attracted broad agreement.

First, the examples should be expressly illustrative. They are useful because fiduciaries, advisers, courts, and litigants benefit from concrete applications of the Employee Retirement Income Security Act’s (ERISA) prudence standard.

But examples embedded in regulatory text can take on a life of their own. Commenters on both sides noted that without clarification, they may be treated as mandatory fact patterns, minimum requirements, or implicit product endorsements. The Department can preserve its value while reducing that risk by clearly stating that the examples illustrate possible prudent processes and do not define the only prudent path, and by providing additional examples.

Second, commenters on both sides agreed that the final rule should avoid language that inadvertently limits the fiduciary discretion to a single objective of maximizing net risk-adjusted returns. Fiduciaries evaluate expected value (including but not limited to returns), qualitative risks, participant needs, plan objectives, operational fit, services, communications, and other relevant considerations. This holistic review by fiduciaries is at the core of a prudent process and should be preserved.

Third, there was general agreement

that fiduciaries need to understand the investment to fully engage in the process. Critical commenters generally pointed to the complexity and opacity of alternative assets as reasons the Department should expressly limit them. Supportive commenters weren’t sanctioning these characteristics, but rather took a different tack, saying that fiduciaries must understand complex products and obtain transparency in order to consider and make investment decisions. So, again, there is more alignment than meets the eye.

But Should the Safe Harbor Exist at All?

There is at least one stark difference of opinion that might be irreconcilable — one where the supportive and critical commenters must agree to disagree. And that is the existence of the safe harbor at all.

The rule provides a presumption of prudence if the fiduciary engages in a robust evaluation and decision-making process related to the identified factor.

Supportive commenters emphasized that fiduciaries have faced significant enforcement risks, often based on hindsight comparisons, rather than the prudence of the decision-making process. They, therefore, see the presumption as the Department attempting to set the course right and ensure that fiduciaries are judged based on process.

Critical commenters, on the other hand, warned that attempting to provide deference could make it harder for participants to challenge genuinely imprudent decisions.

It’s a stark difference. This is where the disagreement is most substantive, but even here, both sides are attempting to calibrate the same balance.

At their core, both sides want what’s in the best interest of participants. The answer is not to choose between deference and accountability. It is to ensure there is deference when warranted and accountability when it isn’t. That’s a delicate needle to thread,

and the commenters might not all agree with the Department in the end, but certainly that is the objective being promoted.

And What About Participant Protections?

Some critical commenters advocated for participant-level protections that sit slightly adjacent to the proposed rule itself. They urged the Department to require more robust participant disclosures, more explicit discussion of the risks associated with alternative investments, and greater attention to the menu-level decision of whether a particular strategy is appropriate for a participant-directed plan or QDIA in the first place.

Those concerns are important. Participants should understand the investment options available to them. Fiduciaries should think carefully about how an option fits within the overall menu. And the decision to include any strategy — whether private markets, lifetime income, managed accounts, capital preservation, active management, or anything else — should not be treated as a mere product-selection exercise divorced from the broader menu design.

But this is less a point of irreconcilable disagreement than a question of regulatory scope.

The proposed rule is narrowly focused on the fiduciary process for selecting designated investment alternatives. It expressly states that menu construction is a different decision not addressed by the rule. Nor is this a participant disclosure rule or a QDIA rule.

That does not mean those issues are unimportant. It means they may require different guidance. But the absence of a full participant-disclosure regime in this rule is not a flaw in the investment selection framework itself.

Put differently, the final rule can clarify how fiduciaries prudently select investment options without pretending to answer every related question about how those investments are presented or explained to participants. Those questions matter. They just may belong in the next chapter, not this one.

The Path Forward Is Clarification, Not Retreat

The comment record does not support the view that DOL must choose between fiduciary discretion and participant protection. Those two go hand in hand. The commenters were often aligned that the Department could strengthen the final rule by making clear that:

• The fiduciary process must be substantive, fully informed, and tailored to the investment’s role in the plan.

• Fiduciaries should consider all relevant factors and not just riskadjusted returns.

• The safe harbor is nonexclusive and does not establish a mandatory minimum process for every investment decision.

• The examples are illustrative and should not be treated as independent requirements.

• The rule should not encourage

alternative investments (or any particular investment type).

While there may ultimately be disagreement on deference, all seem to agree that these refinements would not weaken the proposal. They would make it stronger.

Conclusion

The debate over the Department’s investment selection proposal has too often been framed as a fight between expanding access to investment options and protecting retirement savers. That framing misses the central point.

The comment record shows disagreement over the details, but also meaningful alignment on the core principle: participants are protected when fiduciaries engage in a careful, informed, well-documented process.

Ultimately, the debate reflected less disagreement about objectives than about how best to ensure those objectives are met in practice. Commenters across the spectrum agreed that fiduciary decisions must be grounded in careful analysis and informed judgment. The remaining challenge for the Department is to ensure that the final rule reinforces that standard — without inadvertently creating either a rigid checklist or an unbounded shield.

A final rule that clearly reinforces ERISA’s process-based, asset-neutral framework — while preserving accountability when decisions are not made through a prudent process — can provide the clarity fiduciaries need and the protection participants deserve. NNTM

ACCOUNTS

CERTIFIC ATE PROG R A M

Raise Your Standard.

Reinforce Your Value.

LE ARN MO R E

BY JOHN SULLIVAN

THANK YOU ONCE AGAIN TO ALL WHO PARTICIPATED AND VOTED, AND CONGRATULATIONS TO THE TOP RETIREMENT PLAN WHOLESALERS RECOGNIZED BY THE ADVISORS THEY SUPPORT!

HOW THE ADVISOR ALLIES ARE DETERMINED

This list is based on a nomination, voting/selection process that draws on the experience and perspectives of NAPA’s plan advisor members. It’s what sets it apart from other accolades. Here’s how the three-part process works:

1. Nominations: The process starts with NAPA’s DCIO and recordkeeper Firm Partners submitting their wholesalers for nomination. Wholesalers who work directly in the field with plan advisors are eligible for nomination; internal relationship managers are not eligible.

2. Voting: Our online voting tool allows NAPA members and other advisors to vote for their favorites. Only votes from advisors submitted from a corporate/business email account are tallied. Duplicates are discarded.

3. Selection: The final vote tallies are reviewed by the NAPA Top DC Wholesalers Blue Ribbon Committee, which selects the top wholesalers, including the Top 10, in both the Recordkeeping and DCIO categories.

10 DCIO Wholesaler

It’s the most wonderful time of the year, when we once again get to announce our “Advisor Allies” — the defined contribution wholesalers recognized by their advisor partners for the help and resources they provide!

NAPA’s 2026 100 Top DC Wholesalers — the “Advisor Allies” — were selected through voting by thousands of registered NAPA Net users and NAPA members, from a pool of nominees submitted by NAPA Firm Partners.

We have traditionally referred to the Top DC Wholesalers as “Wingmen” because if they are doing their job, they have advisors’ backs.

While that’s certainly a description of the traditional role, the most successful wholesalers do more — they are true partners, often working side by side with advisors to introduce new ideas and help grow their businesses — and so we now acknowledge that expanded role with an enhanced name: Advisor Allies. With tech support, business best practices, sales support, marketing help, product offerings, and so much more, they help thousands of advisors build and sustain their books.

Once again, this year’s Top 100 were spread across the nation, with the size of their territories as varied and diverse as the wholesalers and firms themselves.

Thank you once again to all who participated and voted, and congratulations to the Advisor Allies recognized by the retirement plan advisors they — and their respective firms — support!

BOBBY ALLEN

American Century DCIO

DOUG ALLEN

Manulife John Hancock

Retirement RK

CHRIS ATHENS

BlackRock DCIO

LINDSEY BAHR

Fidelity Investments

DCIO

CHRIS BILELLO

Victory Capital DCIO

SHANNON BIRKES

The Standard RK

KEITH BLACKMON

T. Rowe Price DCIO

KATELYN BOONE

Fidelity Investments DCIO

JENNIFER BROCKWELLHENDERSON

Janus Henderson Investors DCIO

ANDREW BROSCO

Franklin Templeton DCIO

BLAKE BURKETT

Manulife John Hancock Retirement RK

ANGELO CABRAL

Manulife John Hancock Retirement RK

FRANK CASTELLVI

Transamerica RK

CHRIS CASTRO

Transamerica RK

MARTY COURAGE PIMCO DCIO

TIM CURRAN

Lincoln Financial RK

MATT DEMARCO PIMCO DCIO

BAILEY DOMER T. Rowe Price RK

MARC DOUCETTE

Ascensus RK

JIM DOWLING

Fidelity Investments DCIO

ROBERT DUFFEY Invesco DCIO

ALEX EATON

T. Rowe Price RK

RYAN FAY

Manulife John Hancock Investments DCIO

MICA FISHER

Fidelity Investments RK

DANIEL FLORINA

Franklin Templeton DCIO

ERIC FOX

The Standard RK

DANIEL FRATALIA

Manulife John Hancock Retirement RK

BRETT GALLINGER

Transamerica RK

TIM GANNON

J.P. Morgan DCIO

ANDREW GARCIA Principal RK

TRAVIS GAVINSKI

T. Rowe Price RK

NANCY GERSTNER

Franklin Templeton DCIO

GLENN GODIN

American Century DCIO

JOHN GONSIOR

Fidelity Investments RK

MARK HAMILTON

Transamerica RK

GREG HANDRAHAN

AllianceBernstein (AB) DCIO

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Fish

LABOR DEPARTMENT REDIRECTS EBSA INVESTIGATIONS TOWARD HIGHER-IMPACT CASES

HERE’S A CLOSER LOOK AT THE LABOR DEPARTMENT’S NEW ENFORCEMENT PRIORITIES, AND WHAT THEY MEAN FOR PLAN ADVISORS, SPONSORS, AND PARTICIPANTS.

BY JUDY WARD

The

Department of Labor’s investigative arm, the Employee Benefits Security Administration (EBSA), isn’t sweating the smaller stuff as much these days.

Calling the changes “the most significant EBSA has made in years,” the Labor Department announced in January that EBSA had shifted its focus to place greater emphasis on investigations into broad-based employee benefit plan compliance, as well as abusive practices and bad actors. Previously, EBSA investigations frequently focused on operational details of retirement plans.

“I think of the old enforcement position as being like a traffic cop who stops you if you’re going two miles over the speed limit,” said Kevin Brady, an attorney and Chicago-based senior vice president and Employee Benefits Compliance Practice Leader at HUB International. “With the new priorities, they’re not going to spend a lot of time on finding people going two miles over the speed limit. Now they’re saying, ‘When we’re out there doing investigations, we want to maximize the impact that we have.’”

Deputy Secretary of Labor

Keith Sonderling said in the DOL’s announcement that EBSA investigations will “be more efficient, responsive, and prioritize serious misconduct rather than minor foot faults.” EBSA will now prioritize investigations in six areas: cybersecurity; barriers to mental health and substance use disorder benefits; protecting benefit distributions; retirement asset management; surprise billing; and criminal abuse of contributory benefit plans.

This doesn’t mean it’s OK to get lax about the DOL’s reporting or participant disclosure requirements, Brady cautioned.

“But EBSA is going to focus less on technical violations, and more on situations where there can be real harm to participants,” Brady continued. “This means we’re looking at higher-stakes conversations for employers that have a plan under investigation. Now, if EBSA comes to your door, they think there may be something serious going on.”

Here are five significant implications of EBSA’s new enforcement priorities: Fewer “Gotcha!” Investigations

“It’s very possible we will see less focus on these ‘Gotcha!’ type investigations,” said Robert Projansky, a New York-based partner at law firm Proskauer Rose LLP.

He’s thinking of previous investigations into cases where a fiduciary had good processes in place but had a short-term issue with process execution or relied on a good-faith interpretation that was within the bounds of reasonableness.

“Now, it appears that EBSA is going to focus more on investigations of instances in which there was clear participant harm caused by systemic process deficiencies,” he said.

During the remainder of the second Trump administration, EBSA seems more likely to focus on big-picture processes and assess whether things are being done well overall, said Matthew Eickman, the Omaha, Nebraska-based managing partner of the Fiduciary Law Center.

Previously, EBSA focused somewhat less on the overall reasonableness of retirement plan operations and more on the consistency of specific operational patterns.

For example, an employer could be out of compliance if it experienced a brief delay in transferring employees’ contributions because the staffer who handles that was out of the office on transfer day, or if there was a short delay in filing required plan reporting or sending required participant disclosures.

Now, EBSA’s investigations may lean more toward a big picture look at whether a plan sponsor has reasonable processes for selecting and monitoring investments, and for selecting and monitoring providers and their fees, Eickman said.

“As opposed to ‘Hey, we’re just going to dig around and see if we find some minor foot faults,’” he said.

Not surprisingly, given the overall interest of the second Trump administration in taking big swings at big issues, this DOL wants to have a big impact on retirement and health plans, said Richard Nowak, a Chicago-based partner at the law firm Mayer Brown and co-leader of the ERISA litigation practice.

“So, they want to identify big issues and really go after those issues and then be able to say, ‘We tackled this big issue, and this has helped X number of people,’” Nowak said.

When thinking of ERISA’s fiduciary obligations, the focus has historically boiled down to two main things, he said: the duty of loyalty and the duty of prudence. The DOL’s investigative priorities in recent years leaned more toward the duty of prudence, leading to its focus on operational details.

The DOL now appears to want to focus more on the duty of loyalty, Nowak said. A violation of this duty can occur when a plan sponsor or provider acts not in the best interests of a plan’s participants, but rather in their own or in the best interests

of other entities with which they have a business relationship.

“The DOL is now approaching this as, ‘We should be going after truly bad actors,’ as opposed to focusing on judgment calls,” Nowak said.

Whether the duty of loyalty has been met depends on a clear nexus between an action and its impact on participants, he said.

“They are focused now on catching big fish, and not on catching small fish that might make a minor mistake on a form,” said Katherine Kohn, a Washington, D.C.-based partner at law firm Thompson Hine LLP. “Now, they are looking for more consistent and widespread errors.”

More Provider-Centric Probes, Including Advisors

With the DOL’s recalibration to focus on consistent, widespread issues, Kohn said it’s logical to anticipate that EBSA will conduct more provider-focused investigations rather than just those focused on a particular plan sponsor. On the health plan side, this could come into play when investigating whether a TPA (third-party administrator) is systematically denying certain valid medical claims across multiple employers.

And on the retirement plan side, when Kohn looked at what’s been added to the investigative priorities, what jumped out to her is the DOL’s concern about conflicts of interest among outsourced fiduciaries that provide 3(21) or 3(38) investment services to a plan.

“I think there will be more investigations to determine whether there is a conflict of interest with outsourced fiduciary services,” Kohn said. She anticipates that EBSA investigators will be interested in whether outside fiduciaries steered their plan clients toward proprietary investments of their company or an affiliated company. So, plan sponsors will need to get as much disclosure as possible on this issue and document that they’ve received it, she said.

And advisory firms would be welladvised to disclose all aspects of the compensation they receive as a result of the client engagement, Kohn said. Advisors should further consider the plan fiduciary’s awareness of ancillary services when they’re provided to participants, she said, referring to additional work such as wealth management.

“You want to make sure that everybody is aware of all of the forms

of compensation that your advisory firm is receiving as a result of its work with that plan and its participants,” Kohn said. “Of course, conflicts of interest aren’t necessarily wrong: Everyone has conflicts of interest. Where you get into trouble is where there are undisclosed conflicts of interest.”

Not infrequently, Nowak has seen that a 3(38)-investment manager has been adding to a retirement plan client’s menu investments that are proprietary to that entity or an affiliated firm. That’s not inherently a problematic conflict of interest, he said, if the 3(38) managers can document the prudent process it followed in selecting an investment for a particular plan’s participants.

The DOL definitely does not want to dissuade plan sponsors from hiring an investment advisor or investment manager who will be beneficial to the plan and its participants, Nowak said.

“But the DOL is going to be interested in, are these investment advisors acting in self-interest, recommending or selecting investments that are not in plan participants’ best interests?” Nowak continued. “If you are a fiduciary advisor who is picking proprietary funds for your plan clients, there is going to be a spotlight on you. The DOL is going to say, ‘Let’s peel the onion back and look at the advisor’s motivation for recommending these investments.’”

Out: ESOPs, Missing Participants, & Many Investigators

In its announcement on EBSA’s recalibrated priorities, the DOL said it had removed ESOPs (employee stock ownership plans) from the national enforcement project list and would also reduce its focus on missing participants.

DOL has dedicated significant investigative resources to these two areas in recent years, said Michael Kreps, a Washington, D.C.-based partner and Fiduciary Practice Leader at Groom Law Group.

The missing-participants removal didn’t surprise him, given that over the past several years, the retirement industry has put more infrastructure in place to help locate missing participants. So, the prevalence of this issue will likely lessen over time.

But the removal of ESOPs from the enforcement priority list is a huge deal for employers that have an ESOP, Kreps

said. The DOL and the ESOP community have disagreed on some core issues for 20 years, he said, with the valuation of privately held companies being a particular sticking point.

“I think the DOL has realized that the primary areas of disagreement over ESOPs aren’t being resolved in investigations,” Kreps continued. “They’ve also had essentially the same enforcement priorities for 15 years, and there are only so many ESOPs that they can investigate.”

The removal of two focus areas and the recalibration of investigative focus to bigger-picture issues is not surprising given the decrease in EBSA investigative staff. Eickman has been hearing at industry events that with the recent reductions in the federal workforce, the number of EBSA investigators has dropped by roughly half since early 2025.

“I don’t know the exact number of EBSA investigators currently, but they have some things that they always have to investigate, like if an employer is stealing employees’ retirement plan contributions,” Kreps said. “If you figure that half of the remaining investigators will be doing this ‘pure’ law enforcement type of investigation, then it’s likely that they’re not going to focus as much on some of the non-systemic issues that DOL has focused on in the past. Presumably, they’re going to have less interest in citing plans for small-dollar, non-systemic issues.”

Cybersecurity Scrutiny Intensifies

Cybersecurity appears on EBSA’s enforcement project list for the first time, according to sources. However, the DOL has previously published best practices and tips to guide plan sponsors on cybersecurity governance. Its 2021 guidance (“Tips for Hiring a Service Provider with Strong Cybersecurity Practices”) provides a roadmap for plan sponsors on what questions to ask plan providers, and the DOL updated the guidance in 2024 (Compliance Assistance Release No. 2024-01).

“If we’re looking to make sure that we’re doing the right thing in EBSA’s mind, then we should definitely utilize the DOL’s resources to help determine that,” Brady said. A key takeaway: It isn’t just about sponsors and providers having cybersecurity policies and procedures in place; it’s about ongoing compliance.

“The last thing that you want to do is to put together policies and procedures that

look good on paper, and then not actually follow those policies and procedures consistently,” Brady said.

Projansky anticipates that EBSA’s investigators will focus on a retirement plan’s vulnerabilities to fraudulent participant distributions and to criminals gaining unauthorized access to individual participant data. Health plans, pension plans, and 401(k) plans contain some of the most sensitive data you can imagine about people, and that information is sometimes housed across multiple vendors, he continued. EBSA may require plan sponsors to have mechanisms in place to ensure they periodically reach out to all vendors that house participant data and conduct a security risk assessment. Plan sponsors that house participant data themselves may also want to periodically conduct a self-audit to ensure that the employer has prudent cybersecurity processes in place to protect that data and consistently follows best practices, he added.

“The DOL will want to know: What steps are you as a plan fiduciary taking to help participants—particularly older participants—to ensure that they are not taken advantage of by bad actors who make unauthorized withdrawals? Also, are you taking reasonable steps to ensure that a plan’s participants are not at risk of a bad actor coming in and accessing participant data?” Nowak said. “What are you insisting that your plan’s providers do to protect plan assets and data? Are you asking periodically what specific safeguards they have in place, or are you just trusting your plan’s providers to protect the assets and data?”

Retirement and health plan fiduciaries don’t have an obligation to be an expert on everything, including cybersecurity, as Nowak said.

“But they should be informed enough to know: ‘Is the response we received from this provider sufficient to answer the question that we asked?’” Nowak added. “What the DOL is going to want to know is: Are plan sponsors paying attention, and focusing on this issue? If they are, that gets them a long way there with the DOL. But for a lot of plans, they’ve never even asked the questions before.”

Health Plans Enter the Spotlight

The DOL has been foreshadowing for a couple of years that it would shift its focus more toward health and welfare

plans, Kohn said. With a lot of talk currently about the unaffordability of health care for many everyday Americans, she said, it’s logical that DOL moved to make two health plan issues–surprise billing, and barriers to mental health and substance use disorder benefits–an explicit investigative focus.

“It’s a nice, juicy topic that has not historically been a priority for the DOL,” Kohn said. “The DOL probably sees this as a way that it can impact everyday Americans’ lives in a meaningfully positive way.”

Much of the DOL’s enforcement energy is now shifting to focus on health plans, Kreps said.

“For years, the Department of Labor has kind of punted on these issues,” Kreps said. “Now, there is a focus on health plans, and a desire to tackle some of these issues that have been hanging out there for a long time.”

Likewise, many employers probably haven’t given their health plan its due fiduciary focus. Eickman outlined a few first steps that employers can take if they haven’t previously established rigorous governance processes for their health plan, as many have for years for their retirement plan. It starts at a fundamental level, with people who work on an employer’s health plan receiving education to understand the general nature of fiduciary responsibilities.

Second, it’s important to clearly identify who, among those who perform tasks for the plan at an employer, is and isn’t a fiduciary under ERISA.

And third, he said, people who are fiduciaries need to understand, from a practical perspective, when their fiduciary responsibilities come into play in their work with the health plan.

Since many employers likely have had less extensive governance in place for their health plan than for their retirement plan, EBSA officials may believe that more room exists to improve fiduciary processes on the health plan side than on the retirement plan side, Projansky said.

“On a broad scale, health plan sponsors need to think about governance, documentation, compliance, and prudence,” Projansky said. “I think that EBSA is going to be looking at whether, from a fiduciary process standpoint, plan sponsors are paying attention to their health plan similar to how they pay attention to their retirement plan.” NNTM

TOP OF THE

CLASS

WE APPRECIATE THE COMMITMENT AND HARD WORK OF THE TEAMS ACKNOWLEDGED — AND ARE PROUD TO HAVE THE OPPORTUNITY TO SHARE IT HERE.

BY JOHN SULLIVAN

WE ARE PROUD TO ANNOUNCE

our list of the 2026 NAPA Top DC Advisor Teams and Multi-Office Fims. Read on to find out whether your team (and others) made it.

Unlike our other accolade lists, 2026 NAPA Top DC Advisor Teams one focuses on firms (or, in a wirehouse environment, teams) located in a single physical location and on the defined contribution portion of their practice.

Since their inception, NAPA’s various industry lists have been a venerable who’s-who of standouts in the world of retirement plans and retirement plan advisors, representing a cross section of demographics and business models that point to a robust — and growing — industry.

This one — the NAPA Top DC Advisor Teams with AUA Over $100 Million, ranked by self-reported DC assets under advisement — is a compelling case for their impact on the nation’s private retirement system.

And please remember that several years ago, we brought the list in line with the year it was released (even though it’s based on last year’s numbers) to avoid unnecessary confusion.

Each team listed — and to be here they are all in a single physical location — has more than $100 million in AUA, based on selfreported assets under advisement as of Dec. 31, 2025 (unless otherwise noted). Those teams are in 43 different states and the District of Columbia.

We know it’s not just about the numbers — but the reality is that advisors are having a huge impact every single day, not only on the quality of retirement plan advice but also on building a more financially secure retirement for millions of Americans.

We appreciate the commitment and hard work of the teams acknowledged — and are proud to have the opportunity to share it here.

CAPTRUST - New York

New York, NY

Year Est.: 2012

# of Advisors: 12

Total Asset Value: $238,615,439,658

Total # of Plans: 565

Total Participants: 1,397,257

CAPTRUST - Raleigh

Raleigh, NC

Year Est.: 1997

# of Advisors: 18

Total Asset Value: $170,572,110,013

Total # of Plans: 713

Total Participants: 1,383,844

CAPTRUST - Richmond Richmond, VA

Year Est.: 1998

# of Advisors: 2

Total Asset Value: $108,557,673,043

Total # of Plans: 230

Total Participants: 923,033

CAPTRUST - Charlotte Charlotte, NC

Year Est.: 2003

# of Advisors: 5

Total Asset Value: $96,818,651,134

Total # of Plans: 152

Total Participants: 682,555

CAPTRUST - Warren

Warren, NJ

Year Est.: 1992

# of Advisors: 11

Total Asset Value: $82,815,666,204

Total # of Plans: 270

Total Participants: 671,246

CAPTRUST - Allentown

Allentown, PA

Year Est.: 2000

# of Advisors: 4

Total Asset Value: $67,408,877,016

Total # of Plans: 205

Total Participants: 365,049

Multnomah Group

Portland, OR

Year Est.: 2003

# of Advisors: 8

Total Asset Value: $52,142,088,963

Total # of Plans: 306

Total Participants: 341,000

Innovest Portfolio Solutions, LLC

Denver, CO

Year Est.: 1996

# of Advisors: 18

Total Asset Value: $48,500,000,000

Total # of Plans: 300

Total Participants: 413,855

CAPTRUST - Doylestown

Doylestown, PA

Year Est.: 2006

# of Advisors: 4

Total Asset Value: $41,948,123,031

Total # of Plans: 160

Total Participants: 449,352

Global Institutional Advisory Solutions

New York, NY

Year Est.: 2007

# of Advisors: 17

Total Asset Value: $34,363,463,976

Total # of Plans: 55

Total Participants: 289,760

CAPTRUST - Minneapolis

Minneapolis, MN Year Est.: 1995

# of Advisors: 5

Total Asset Value: $34,181,528,536

Total # of Plans: 871

Total Participants: 276,762

Newfront Retirement Services

San Mateo, CA Year Est.: 2012

# of Advisors: 21

Total Asset Value: $33,663,782,046

Total # of Plans: 506

Total Participants: 318,565

CAPTRUST - Chicago Chicago, IL

Year Est.: 1977

# of Advisors: 17

Total Asset Value: $32,331,181,611

Total # of Plans: 70

Total Participants: 138,000

MMA Retirement & Wealth - East Region

Conshohocken, PA

Year Est.: 2006

# of Advisors: 21

Total Asset Value: $30,978,807,134

Total # of Plans: 268

Total Participants: 465,000

CAPTRUST - Orlando

Lake Mary, FL

Year Est.: 2010

# of Advisors: 1

Total Asset Value: $30,242,485,165

Total # of Plans: 71

Total Participants: 290,245

Compass Financial Partners, a Marsh & McLennan Agency LLC

Company

Greensboro, NC

Year Est.: 2002

# of Advisors: 9

Total Asset Value: $28,438,817,595

Total # of Plans: 239

Total Participants: 300,126

CAPTRUST - South Michigan Southfield, MI Year Est.: 2000

# of Advisors: 9

Total Asset Value: $26,955,868,354

Total # of Plans: 305

Total Participants: 245,802

CAPTRUST - Portland Falmouth, ME Year Est.: 2006

# of Advisors: 1

Total Asset Value: $25,327,254,251

Total # of Plans: 67

Total Participants: 225,701

OneDigital - New York, NY New York, NY

# of Advisors: 6

Total Asset Value: $25,167,766,764

Total # of Plans: 200

Total Participants: 218,849

Advanced Capital Group Minneapolis, MN Year Est.: 2002

# of Advisors: 7

Total Asset Value: $24,702,544,632

Total # of Plans: 133

Total Participants: 160,000

CAPTRUST - Dallas Dallas, TX

Year Est.: 2010

# of Advisors: 2

Total Asset Value: $24,514,648,283

Total # of Plans: 80

Total Participants: 228,881

HUB Retirement and Wealth Management

Northbrook/Mequon, IL/WI Year Est.: 2004

# of Advisors: 14

Total Asset Value: $22,017,476,196

Total # of Plans: 311

Total Participants: 536,000

CAPTRUST - Des Moines West Des Moines, IA Year Est.: 1998

# of Advisors: 6

Total Asset Value: $21,896,070,393

Total # of Plans: 134

Total Participants: 133,690

Retirement Plan Analytics (RPA) Charlotte, NC Year Est.: 2015

# of Advisors: 6

Total Asset Value: $21,017,672,487

Total # of Plans: 1,856

Total Participants: 712,872

Newport Capital Group

Red Bank, NJ

Year Est.: 2004

# of Advisors: 13

Total Asset Value: $20,241,149,729

Total # of Plans: 142

Total Participants: 160,000

Institutional Investment

Consulting

Bloomfield Hill, MI Year Est.: 2003

Total Asset Value: $20,000,000,000

Total Participants: 39

BFSG Institutional Services Irvine, CA Year Est.: 1991

# of Advisors: 13

Total Asset Value: $17,593,724,397

Total # of Plans: 100

Total Participants: 180,000

CAPTRUST - Tampa Tampa, FL Year Est.: 1998

# of Advisors: 5

Total Asset Value: $15,919,857,758

Total # of Plans: 99

Total Participants: 179,980

CAPTRUST - Atlanta Alpharetta, GA

Year Est.: 2005

# of Advisors: 5

Total Asset Value: $15,312,914,463

Total # of Plans: 61

Total Participants: 108,983

Graystone Consulting

Boston North Shore

Middleton, MA Year Est.: 1998

# of Advisors: 6

Total Asset Value: $15,125,000,000

Total # of Plans: 103

Total Participants: 300,000

Clearstead Cleveland, OH

Year Est.: 1989

# of Advisors: 7

Total Asset Value: $15,000,000,000

Total # of Plans: 104

Total Participants: N/A

MMA Retirement & Wealth – West Region

San Diego, CA

Year Est.: 2002

# of Advisors: 8

Total Asset Value: $14,650,201,130

Total # of Plans: 571

Total Participants: 114,200

Retirement Plan Advisors Seattle, WA Year Est.: 1988

# of Advisors: 6

Total Asset Value: $14,500,000,000

Total # of Plans: 270

Total Participants: 162,000

CAPTRUST - Birmingham Birmingham, AL Year Est.: 2008

# of Advisors: 3

Total Asset Value: $14,452,445,437

Total # of Plans: 67

Total Participants: 154,413

Marsh McLennan AgencyNortheast Boston, MA Year Est.: 1973

# of Advisors: 28

Total Asset Value: $14,310,000,000

Total # of Plans: 570

Total Participants: 315,000

Regions Institutional Services Birmingham, AL Year Est.: 1971

# of Advisors: 26

Total Asset Value: $14,207,775,074

Total # of Plans: 387

Total Participants: N/A

OneDigital - Atlanta, GA Atlanta, GA

# of Advisors: 8

Total Asset Value: $13,795,350,733

Total # of Plans: 345

Total Participants: 157,041

The Robertson Group at Graystone Consulting Columbus, OH Year Est.: 1994

# of Advisors: 15

Total Asset Value: $13,466,643,603

Total # of Plans: 118

Total Participants: 113,766

CAPTRUST - Akron Akron, OH Year Est.: 2001

# of Advisors: 4

Total Asset Value: $13,140,217,531

Total # of Plans: 151

Total Participants: 111,377

MMA Retirement & Wealth - Upper Midwest Region (Minneapolis) Minneapolis, MN Year Est.: 1986

# of Advisors: 16

Total Asset Value: $12,289,115,657

Total # of Plans: 410

Total Participants: 260,000

OneDigital - Bethesda, MD Bethesda, MD

# of Advisors: 7

Total Asset Value: $12,108,084,882

Total # of Plans: 348

Total Participants: 150,597

The Parks Group at Graystone Consulting Milwaukee, WI

Year Est.: 1981

# of Advisors: 8

Total Asset Value: $11,764,777,373

Total # of Plans: 69

Total Participants: 170,000

Houston Prime Capital Retirement

Overland Park, KS

Year Est.: 2011

# of Advisors: 5

Total Asset Value: $9,906,934,722

Total # of Plans: 93

Total Participants: 108,000

PearlStreet Investment Management of Stifel St. Louis, MO Year Est.: 1992

# of Advisors: 3

Total Asset Value: $9,878,788,962

Total # of Plans: 48

Total Participants: 92,763

Graystone ConsultingMetro NY | Allentown PA | Cleveland OHMorgan Stanley New York, NY

Year Est.: 1999

# of Advisors: 7

Total Asset Value: $9,743,122,732

Total # of Plans: 121

Total Participants: 121,000

OneDigital - Charlotte, NC Charlotte, NC

# of Advisors: 4

Total Asset Value: $9,453,540,611

Total # of Plans: 262

Total Participants: 122,322

CAPTRUST - Denver Fort Collins, CO

# of Advisors: 2

Total Asset Value: $9,072,135,924

Total # of Plans: 37

Total Participants: 93,371

Conrad Siegel Investment Advisors, Inc. Harrisburg, PA

Year Est.: 2002

# of Advisors: 3

Total Asset Value: $9,022,776,422

Total # of Plans: 121

Total Participants: 86,886

OneDigital - Overland Park, KS

Overland Park, KS

Total Asset Value: $8,038,697,194

Total # of Plans: 589

Total Participants: 190,184

CAPTRUST - Santa Barbara Santa Barbara, CA Year Est.: 1988

# of Advisors: 4

Total Asset Value: $8,035,480,203

Total # of Plans: 94

Total Participants: 88,550

ARC - Alpharetta Alpharetta, GA Year Est.: 2007

# of Advisors: 2

Total Asset Value: $7,754,828,423

Total # of Plans: 92

Total Participants: N/A

CAPTRUST - Pittsburgh Pittsburgh, PA Year Est.: 2003

# of Advisors: 2

Total Asset Value: $7,695,384,627

Total # of Plans: 34

Total Participants: 57,569

OneDigital - Sandy, UT Sandy, UT

# of Advisors: 11

Total Asset Value: $7,659,384,575

Total # of Plans: 243

Total Participants: 136,268

HUB InternationalNewport Beach Newport Beach, CA Year Est.: 2014

# of Advisors: 6

Total Asset Value: $7,612,550,000

Total # of Plans: 152

Total Participants: 124,271

Bolton Investment Towson, MD Year Est.: 1994

# of Advisors: 5

Total Asset Value: $7,106,176,070

Total # of Plans: 96

Total Participants: 121,754

ARC - NYC New York, NY Year Est.: 2013

# of Advisors: 2

Total Asset Value: $7,013,122,931

Total # of Plans: 580

Total Participants: 143,611

D’Aiutolo Malcolm & Associates Investment Consulting Group Buffalo, NY

Year Est.: 2008

# of Advisors: 3

Total Asset Value: $6,641,283,680

Total # of Plans: 110

Total Participants: 60,000

Trillium Partners of UBS New York, NY

1983

# of Advisors: 3

Total Asset Value: $6,600,000,000

Total # of Plans: 102

Total Participants: 150,000

OneDigital - Irvine and San Diego, CA Irvine, CA

# of Advisors: 7

Total Asset Value: $6,499,861,418

Total # of Plans: 222

Total Participants: 64,701

DH Consulting Group of Raymond James Beverly Hills, CA Year Est.: 2014

# of Advisors: 8

Total Asset Value: $6,445,000,000

Total # of Plans: 53

Total Participants: 49,500

HUB Retirement and Wealth Management –Bethesda Bethesda, MD Year Est.: 2006

# of Advisors: 4

Total Asset Value: $6,443,007,880

Total # of Plans: 181

Total Participants: 51,000

The Mott Group | Graystone Consulting - Morgan Stanley Houston, TX Year Est.: 2013

# of Advisors: 3

Total Asset Value: $6,430,861,746

Total # of Plans: 57

Total Participants: 53,701

HUB International Glen Allen Glen Allen, VA Year Est.: 2001

# of Advisors: 13

Total Asset Value: $6,400,000,000

Total # of Plans: 113

Total Participants: 59,000

Graystone ConsultingAtlanta Atlanta, GA Year Est.: 1997

# of Advisors: 3

Total Asset Value: $6,389,445,762

Total # of Plans: 82

Total Participants: 72,000

The Catanella Institutional Consulting Team Philadelphia, PA Year Est.: 1992

# of Advisors: 5

Total Asset Value: $6,310,153,649

Total # of Plans: 25

Total Participants: 69,993

Retirement Plan Advisors Chicago, IL Year Est.: 2000

# of Advisors: 36

Total Asset Value: $6,135,214,880

Total # of Plans: 754

Total Participants: 98,115

Lebel & Harriman Retirement Advisors Falmouth, ME Year Est.: 1983

# of Advisors: 4

Total Asset Value: $6,100,000,000

Total # of Plans: 266

Total Participants: 50,000

Graystone Consulting Columbus|Grand Rapids Columbus, OH Year Est.: 1999

# of Advisors: 6

Total Asset Value: $6,041,638,145

Total # of Plans: 74

Total Participants: 52,727

OneDigitalWalnut Creek, CA Walnut Creek, CA Year Est.: 2007

# of Advisors: 11

Total Asset Value: $6,036,318,124

Total # of Plans: 439

Total Participants: 52,480

Gallagher Retirement Boston Boston, MA

# of Advisors: 6

Total Asset Value: $5,900,000,000

Total # of Plans: 240

Total Participants: 91,500

South Central Group

The Woodlands, TX Year Est.: 1984

# of Advisors: 1

Total Asset Value: $5,900,000,000

Total # of Plans: 28

Total Participants: 40,000

CAPTRUST - Austin

Austin, TX Year Est.: 2010

# of Advisors: 2

Total Asset Value: $5,849,467,374

Total # of Plans: 62

Total Participants: 38,278

Morgan Stanley Graystone - Carlsbad Carlsbad, CA

Total Asset Value: $5,816,262,000

Total # of Plans: 125

Total Participants: 67,104

CAPTRUST - Houston Houston, TX Year Est.: 2009

# of Advisors: 3

Total Asset Value: $5,651,955,588

Total # of Plans: 36

Total Participants: 79,729

CAPTRUST - Boston Boston, MA Year Est.: 2012

# of Advisors: 2

Total Asset Value: $5,595,020,981

Total # of Plans: 37

Total Participants: 43,861

TruSource Advisors Chicago, IL Year Est.: 2025

# of Advisors: 3

Total Asset Value: $5,500,000,000

Total # of Plans: 82

Total Participants: 59,000

MJ Retirement Carmel, IN Year Est.: 1998

# of Advisors: 4

Total Asset Value: $5,492,591,864

Total # of Plans: 171

Total Participants: 120,000

OneDigital - Wall, NJ Wall, NJ Year Est.: 1981

# of Advisors: 7

Total Asset Value: $5,184,521,783

Total # of Plans: 204

Total Participants: 47,960

Fuchs Team

New York, NY Year Est.: 1998

# of Advisors: 2

Total Asset Value: $5,179,063,067

Total # of Plans: 64

Total Participants: 50,634

WIA - Nashville Brentwood , TN Year Est.: 2014

# of Advisors: 5

Total Asset Value: $5,100,000,000

Total # of Plans: 113

Total Participants: 50,000

HUB Retirement and Wealth ManagementMcLean

McLean, VA Year Est.: 1983

# of Advisors: 4

Total Asset Value: $5,060,000,000

Total # of Plans: 205

Total Participants: 57,000

MMA Retirement & Wealth – Midwest Region Schaumburg, IL Year Est.: 2006

# of Advisors: 6

Total Asset Value: $5,009,057,350

Total # of Plans: 245

Total Participants: 82,761

OneDigital - Clayton, MO Clayton, MO

# of Advisors: 2

Total Asset Value: $4,926,271,843

Total # of Plans: 40

Total Participants: 33,479

Bridgehaven Fiduciary Partners Warren, NJ Year Est.: 2006

# of Advisors: 5

Total Asset Value: $4,800,000,000

Total # of Plans: 71

Total Participants: 124,000

The Wilshinsky Group at Graystone Consulting Scranton, PA Year Est.: 1972

# of Advisors: 6

Total Asset Value: $4,777,895,500

Total # of Plans: 69

Total Participants: 153,000

OneDigitalAshburn Hills, MI Ashburn Hills, MI

# of Advisors: 10

Total Asset Value: $4,742,525,487

Total # of Plans: 93

Total Participants: 39,967

NWK Group | Retirement Advisors

San Francisco, CA

Year Est.: 2002

# of Advisors: 2

Total Asset Value: $4,428,000,000

Total # of Plans: 60

Total Participants: 19,860

HUB Retirement and Wealth ManagementHouston Houston, TX Year Est.: 2002

# of Advisors: 5

Total Asset Value: $4,303,268,985

Total # of Plans: 156

Total Participants: 57,695

Graystone Consulting | Cincinnati Cincinnati, OH Year Est.: 1990

# of Advisors: 5

Total Asset Value: $4,300,000,000

Total # of Plans: 66

Total Participants: 20,000

Spectrum Investment Advisors Mequon, WI Year Est.: 1995

# of Advisors: 19

Total Asset Value: $4,200,831,982

Total # of Plans: 166

Total Participants: 40,174

Cornerstone Advisors

Asset Management, LLC

Bethlehem, PA Year Est.: 1997

# of Advisors: 22

Total Asset Value: $4,179,514,089

Total # of Plans: 113

Total Participants: 45,183

CAPTRUST - Phoenix Phoenix, AZ Year Est.: 2002

# of Advisors: 2

Total Asset Value: $4,139,733,147

Total # of Plans: 74

Total Participants: 40,937

OneDigital - Chicago, IL Chicago, IL

# of Advisors: 2

Total Asset Value: $4,131,480,565

Total # of Plans: 243

Total Participants: 31,860

Henderson Brothers Financial Partners Pittsburgh, PA Year Est.: 2005

# of Advisors: 13

Total Asset Value: $4,105,533,000

Total # of Plans: 274

Total Participants: 55,827

OneDigital - Akron, OH Akron, OH

# of Advisors: 7

Total Asset Value: $4,102,064,944

Total # of Plans: 388

Total Participants: 34,324

HUB Three Rivers Pittsburgh, PA Year Est.: 2009

# of Advisors: 4

Total Asset Value: $4,034,104,596

Total # of Plans: 82

Total Participants: 35,320

The Chasin Group Greenwich, CT Year Est.: 1992

# of Advisors: 5

Total Asset Value: $3,883,545,631

Total # of Plans: 23

Total Participants: 38,159

The Kelliher Corbett Group at Morgan Stanley Norwell, MA Year Est.: 1998

# of Advisors: 7

Total Asset Value: $3,821,094,639

Total # of Plans: 74

Total Participants: 30,000

Capitol Group Institutional Consulting Washington, DC Year Est.: 2000

# of Advisors: 3

Total Asset Value: $3,728,595,807

Total # of Plans: 120

Total Participants: 25,000

The Vierra Group of UBS Financial Services Boston, MA Year Est.: 1993

# of Advisors: 2

Total Asset Value: $3,625,395,831

Total # of Plans: 90

Total Participants: 55,190

Eisen-Sessa Consulting Group at Graystone Philadelphia, PA Year Est.: 1990

# of Advisors: 4

Total Asset Value: $3,563,289,237

Total # of Plans: 12

Total Participants: 37,511

Strategic Retirement Partners - Northeast Providence, RI Year Est.: 2000

# of Advisors: 6

Total Asset Value: $3,492,799,809

Total # of Plans: 76

Total Participants: 24,188

Wilmington Trust Retirement Advisory Services

New York, NY Year Est.: 2010

# of Advisors: 7

Total Asset Value: $3,388,700,080

Total # of Plans: 312

Total Participants: 59,142

ARC - Seattle Seattle, WA Year Est.: 2010

# of Advisors: 1

Total Asset Value: $3,251,984,958

Total # of Plans: 87

Total Participants: N/A

OneDigital - Tampa, FL Tampa, FL

Year Est.: 2004

# of Advisors: 5

Total Asset Value: $3,207,539,463

Total # of Plans: 132

Total Participants: 40,821

Graystone ConsultingTroy Troy, MI

Year Est.: 2021

# of Advisors: 4

Total Asset Value: $3,183,400,000

Total # of Plans: 20

Total Participants: 26,327

Strategic Retirement Partners - Midwest Urbandale, IA

Year Est.: 2000

# of Advisors: 5

Total Asset Value: $3,175,318,185

Total # of Plans: 133

Total Participants: 43,640

Blueprint Financial Group

Reston, VA

Year Est.: 1987

# of Advisors: 20

Total Asset Value: $3,156,535,650

Total # of Plans: 412

Total Participants: 42,000

CAPTRUST - Harrisonburg Harrisonburg, VA

Year Est.: 1994

# of Advisors: 1

Total Asset Value: $3,149,527,299

Total # of Plans: 31

Total Participants: 23,485

Top DC Advisor Teams

Top DC Advisor Teams

The Mammini Company

Solana Beach, CA Year Est.: 2001

# of Advisors: 3

Total Asset Value: $3,039,226,407

Total # of Plans: 50

Total Participants: 27,638

OneDigital - Orlando, FL Orlando, FL

# of Advisors: 3

Total Asset Value: $2,927,243,045

Total # of Plans: 103

Total Participants: 147,538

HUB Investment Partners, LLC

Omaha, NE Year Est.: 1992

# of Advisors: 3

Total Asset Value: $2,901,831,406

Total # of Plans: 104

Total Participants: 32,810

OneDigital - Nashville, TN Nashville, TN

# of Advisors: 6

Total Asset Value: $2,876,666,775

OneDigital - Danvers, MA Danvers, MA

# of Advisors: 5

Total Asset Value: $2,766,407,541

Total # of Plans: 97

Total Participants: 27,301

The Ryan Klein Group Denver, CO Year Est.: 2009

# of Advisors: 3

Total Asset Value: $2,750,000,000

Total # of Plans: 75

Total Participants: 25,000

Graystone ConsultingPacific Mountain Lake Oswego, OR Year Est.: 2004

# of Advisors: 1

Total Asset Value: $2,700,000,000

Total # of Plans: 53

Total Participants: 38,000

CAPTRUST - Los Angeles

Westlake Village, CA Year Est.: 2009

# of Advisors: 1

Total Asset Value: $2,664,572,999

Total # of Plans: 13

Total Participants: 22,188

Handler Investment Consulting Group of Raymond James

Beverly Hills, CA

Year Est.: 2014

# of Advisors: 8

Total Asset Value: $2,664,445,125

Total # of Plans: 55

Total Participants: 48,000

Princeton Financial Partners

Princeton, NJ Year Est.: 2018

# of Advisors: 4

Total Asset Value: $2,658,000,000

Total # of Plans: 37

Total Participants: 33,800

Graystone Consulting –

New York, NY - Penn Plaza New York, NY

Total Asset Value: $2,607,305,171

Total # of Plans: 65

Total Participants: 26,385

MMA Retirement & Wealth – Southeast Region

Dallas, TX

Year Est.: 2014

# of Advisors: 7

Total Asset Value: $2,575,000,000

Total # of Plans: 170

Total Participants: 52,000

Guidance Point Retirement Services

Bangor, ME Year Est.: 2012

# of Advisors: 5

Total Asset Value: $2,472,157,726

Total # of Plans: 66

Total Participants: N/A

HUB International - CSi Advisory Services Indianapolis, IN Year Est.: 1971

# of Advisors: 3

Total Asset Value: $2,466,000,000

Total # of Plans: 284

Total Participants: 33,404

Princeton/Park Avenue Investment Consulting Princeton, NJ

Year Est.: 2019

# of Advisors: 7

Total Asset Value: $2,457,933,116

Total # of Plans: 21

Total Participants: 18,106

CAPTRUST - Sacramento

Sacramento, CA Year Est.: 1987

# of Advisors: 3

Total Asset Value: $2,425,267,324

Total # of Plans: 147

Total Participants: 11,927

Valley Forge Investment Consultants, Inc.

Audubon, PA Year Est.: 1991

# of Advisors: 6

Total Asset Value: $2,400,000,000

Total # of Plans: 122

Total Participants: 31,400

HUB International Sacramento Sacramento, CA Year Est.: 2012

# of Advisors: 2

Total Asset Value: $2,400,000,000

Total # of Plans: 280

Total Participants: 30,000

The Ratay Group at Morgan Stanley Fort Myers, FL Year Est.: 1990

# of Advisors: 2

Total Asset Value: $2,300,000,000

Total # of Plans: 64

Total Participants: 14,000

Deshutes Investment Consulting Portland, OR Year Est.: 1997

# of Advisors: 5

Total Asset Value: $2,290,281,364

Total # of Plans: 80

Total Participants: 50,700

SFP Wealth Wellesley, MA Year Est.: 2005

# of Advisors: 4

Total Asset Value: $2,222,842,077

Total # of Plans: 367

Total Participants: 41,000

Plexus Financial Services, LLC Deer Park, IL Year Est.: 1993

# of Advisors: 3

Total Asset Value: $2,211,743,000

Total # of Plans: 74

Total Participants: 27,650

Aldrich Wealth LP

Lake Oswego, OR Year Est.: 1998

# of Advisors: 5

Total Asset Value: $2,210,360,526

Total # of Plans: 91

Total Participants: 15,667

HUB InternationalMelville, NY Melville, NY

Year Est.: 1992

# of Advisors: 2

Total Asset Value: $2,200,000,000

Total # of Plans: 48

Total Participants: 26,000

Kathmere Capital Management Wayne, PA Year Est.: 2016

# of Advisors: 3

Total Asset Value: $2,200,000,000

Total # of Plans: 135

Total Participants: 18,500

Cleveland Wealth Management Team Westlake, OH

Year Est.: 2005

# of Advisors: 4

Total Asset Value: $2,198,000,000

Total # of Plans: 120

Total Participants: 24,772

Lawley Retirement Advisors Buffalo, NY Year Est.: 2011

# of Advisors: 5

Total Asset Value: $2,150,000,000

Total # of Plans: 190

Total Participants: 34,000

World Investment Advisors Southern California Irvine, CA Year Est.: 2023

# of Advisors: 4

Total Asset Value: $2,126,000,000

Total # of Plans: 212

Total Participants: 42,000

Northeast Financial Group Westfield, NJ Year Est.: 1993

# of Advisors: 3

Total Asset Value: $2,108,496,283

Total # of Plans: 67

Total Participants: 14,775

The Retirement Strategies Group of UBS

Cincinatti, OH Year Est.: 1990

# of Advisors: 4

Total Asset Value: $2,100,000,000

Total # of Plans: 68

Total Participants: 25,000

OneGroup Retirement Advisors Syracuse, NY Year Est.: 2015

# of Advisors: 5

Total Asset Value: $2,061,394,574

Total # of Plans: 186

Total Participants: 23,500

Graystone ConsultingThe Atlantic Group at Morgan Stanley Boca Raton, FL Year Est.: 2002

# of Advisors: 10

Total Asset Value: $2,019,411,844

Total # of Plans: 59

Total Participants: 40,668

Comperio Retirement Consulting Cary, NC Year Est.: 2006

# of Advisors: 3

Total Asset Value: $2,012,138,965

Total # of Plans: 27

Total Participants: 24,702

Comperiorc.com Cary, NC Year Est.: 2006

# of Advisors: 3

Total Asset Value: $2,012,138,965

Total # of Plans: 27

Total Participants: 24,702

The Beacon Group of Morgan Stanley Blue Bell, PA Year Est.: 1997

# of Advisors: 3

Total Asset Value: $2,004,000,000

Total # of Plans: 80

Total Participants: 34,000

Fiduciary Pension Partners Westfield, NJ Year Est.: 2016

# of Advisors: 1

Total Asset Value: $2,002,942,244

Total # of Plans: 165

Total Participants: 48,000

Graystone West Los Angeles

Los Angeles, CA Year Est.: 2022

# of Advisors: 4

Total Asset Value: $2,000,000,000

Total # of Plans: 105

Total Participants: 65,000

Strategic Retirement Partners – Great Lakes Shorewood, IL Year Est.: 2001

# of Advisors: 6

Total Asset Value: $1,993,203,183

Total # of Plans: 124

Total Participants: 21,342

Excelsior Wealth Management at Morgan Stanley New York, NY Year Est.: 1996

# of Advisors: 3

Total Asset Value: $1,972,654,762

Total # of Plans: 39

Total Participants: 16,200

Graystone Consulting Green Bay Green Bay, WI Year Est.: 1985

# of Advisors: 4

Total Asset Value: $1,955,249,506

Total # of Plans: 35

Total Participants: 23,000

RSG Advisory Portsmouth, NH Year Est.: 2015

# of Advisors: 7

Total Asset Value: $1,930,322,070

Total # of Plans: 209

Total Participants: 29,200

Connor & Gallagher OneSource Lisle, IL Year Est.: 2016

# of Advisors: 3

Total Asset Value: $1,917,909,969

Total # of Plans: 116

Total Participants: 16,000

M3 Financial Madison, WI Year Est.: 2010

# of Advisors: 10

Total Asset Value: $1,904,298,541

Total # of Plans: 190

Total Participants: 31,635

Graystone ConsultingCharleston Charleston, WV Year Est.: 2006

# of Advisors: 6

Total Asset Value: $1,900,000,000

Total # of Plans: 55

Total Participants: 40,250

CAPTRUST - Columbia, MD Columbia, MD

# of Advisors: 1

Total Asset Value: $1,897,869,935

Total # of Plans: 20

Total Participants: 10,222

Financial Strategies

Retirement Partners Bedford, NH Year Est.: 1995

# of Advisors: 12

Total Asset Value: $1,870,000,000

Total # of Plans: 293

Total Participants: 31,419

Financial Strategies Retirement Partners

Bedford, NH Year Est.: 1997

# of Advisors: 12

Total Asset Value: $1,870,000,000

Total # of Plans: 293

Total Participants: 31,419

FRS Advisors Wayne, PA Year Est.: 2002

# of Advisors: 8

Total Asset Value: $1,853,319,712

Total # of Plans: 169

Total Participants: 35,081

ARC - Los Angeles Los Angeles, CA Year Est.: 2023

# of Advisors: 1

Total Asset Value: $1,839,468,534

Total # of Plans: 40

Total Participants: N/A

The Braun-Dubie Group at Morgan Stanley Colchester, VT Year Est.: 2010

# of Advisors: 2

Total Asset Value: $1,836,000,000

Total # of Plans: 160

Total Participants: 32,225

Rockland Trust Hanover, MA Year Est.: 2005

# of Advisors: 5

Total Asset Value: $1,817,697,352

Total # of Plans: 259

Total Participants: 10,260

Strategic Retirement Partners – Southern California/Las Vegas

Rancho Palos Verdes, CA Year Est.: 2012

# of Advisors: 3

Total Asset Value: $1,789,900,981

Total # of Plans: 105

Total Participants: 34,723

Renaissance Benefit Advisors, a HUB International Company Atlanta, GA Year Est.: 2008

# of Advisors: 2

Total Asset Value: $1,785,828,912

Total # of Plans: 26

Total Participants: 14,097

Summit Group 401(k) Consulting, an Alera Group Company Virginia Beach, VA Year Est.: 2007

# of Advisors: 3

Total Asset Value: $1,750,000,000

Total # of Plans: 70

Total Participants: 18,000

CAPTRUST - Chesterton Chesterton, IN Year Est.: 2004

# of Advisors: 10

Total Asset Value: $1,686,579,803

Total # of Plans: 121

Total Participants: 15,959

ARC - Austin Austin, TX Year Est.: 2018

# of Advisors: 2

Total Asset Value: $1,683,823,480

Total # of Plans: 86

Total Participants: N/A

Advo(k)ate Advisors Birmingham, AL Year Est.: 2022

# of Advisors: 2

Total Asset Value: $1,669,091,895

Total # of Plans: 111

Total Participants: 34,200

Graystone ConsultingThe Brice Group Birmingham, MI Year Est.: 1967

# of Advisors: 4

Total Asset Value: $1,651,000,000

Total # of Plans: 80

Total Participants: 22,000

Top DC Advisor Teams

Top DC Advisor Teams

A.P. Lubrano & Company, Inc.

Glenmore, PA Year Est.: 1989

# of Advisors: 16

Total Asset Value: $1,632,393,972

Total # of Plans: 43

Total Participants: 20,222

Infinitas

Overland Park, KS Year Est.: 1990

# of Advisors: 22

Total Asset Value: $1,583,809,724

Total # of Plans: 150

Total Participants: 13,084

Hartmann Astor Investment Consulting

Suwannee, GA Year Est.: 2013

# of Advisors: 1

Total Asset Value: $1,575,577,877

Total # of Plans: 48

Total Participants: 31,300

GBS Retire

Salt Lake City, UT Year Est.: 2018

# of Advisors: 5

Total Asset Value: $1,563,189,800

Total # of Plans: 265

Total Participants: 72,650

Twelve Points

Retirement Advisors

Concord, MA Year Est.: 2014

# of Advisors: 5

Total Asset Value: $1,540,581,318

Total # of Plans: 185

Total Participants: 19,791

Ancora Retirement Plan Advisors, LLC Cleveland, OH Year Est.: 2003

# of Advisors: 3

Total Asset Value: $1,534,388,933

Total # of Plans: 202

Total Participants: 19,638

RCM&D Retirement Services

Hunt Valley, MD Year Est.: 2013

# of Advisors: 4

Total Asset Value: $1,500,000,000

Total # of Plans: 93

Total Participants: 13,000

The Legacy Group of Jericho at Morgan Stanley Jericho, NY Year Est.: 2019

# of Advisors: 10

Total Asset Value: $1,500,000,000

Total # of Plans: 220

Total Participants: 40,000

Bosart Wealth Management Group

Bloomfield Hills, MI

# of Advisors: 3

Total Asset Value: $1,468,830,707

Total # of Plans: 64

Total Participants: 11,203

Vita Planning Group LLC

Camas, WA Year Est.: 2021

# of Advisors: 4

Total Asset Value: $1,472,040,277

Total # of Plans: 66

Total Participants: 8,086

Ironshore Financial Foley, AL Year Est.: 2018

# of Advisors: 1

Total Asset Value: $1,437,785,973

Total # of Plans: 12

Total Participants: 8,142

Integrated Pension Advisors

Leominster, MA Year Est.: 1980

# of Advisors: 3

Total Asset Value: $1,395,000,000

Total # of Plans: 840

Total Participants: 13,000

Bernstein Private Wealth (New York Office) New York, NY

# of Advisors: 3

Total Asset Value: $1,375,000,000

Total # of Plans: 109

Total Participants: 13,000

JKJ Retirement Services Newtown, PA Year Est.: 1934

# of Advisors: 2

Total Asset Value: $1,373,000,000

Total # of Plans: 87

Total Participants: 20,500

SEIA - Team Keenan McLean, VA Year Est.: 1997

# of Advisors: 3

Total Asset Value: $1,350,000,000

Total # of Plans: 150

Total Participants: 23,000

Smith Thornton Advisors, LLC

Huntsville, AL Year Est.: 2011

# of Advisors: 6

Total Asset Value: $1,337,851,307

Total # of Plans: 25

Total Participants: 10,172

Experiential Wealth, Inc.

Cabin John, MD Year Est.: 1991

# of Advisors: 1

Total Asset Value: $1,309,113,319

Total # of Plans: 469

Total Participants: 500,000

Campbell Courtright Peterson Group Eagle, ID Year Est.: 2002

# of Advisors: 3

Total Asset Value: $1,305,927,236

Total # of Plans: 56

Total Participants: 14,890

The Bearing Group at Morgan Stanley Chcicago, IL Year Est.: 1992

# of Advisors: 5

Total Asset Value: $1,300,000,000

Total # of Plans: 46

Total Participants: 9,000

Heffernan Financial Orange County Irvine, CA Year Est.: 2016

# of Advisors: 2

Total Asset Value: $1,300,000,000

Total # of Plans: 65

Total Participants: 22,000

Penniman Wealth & Institutional Consulting Group Plymouth, MI Year Est.: 2007

# of Advisors: 7

Total Asset Value: $1,300,000,000

Total # of Plans: 40

Total Participants: 10,000

HUB Fort Worth Fort Worth, TX Year Est.: 2007

# of Advisors: 2

Total Asset Value: $1,272,300,000

Total # of Plans: 142

Total Participants: 23,000

Venture Visionary Partners Sylvania, OH Year Est.: 2019

# of Advisors: 3

Total Asset Value: $1,240,753,608

Total # of Plans: 101

Total Participants: 16,148

Alera Group Retirement Plan Services NW Portland, OR Year Est.: 2024

# of Advisors: 4

Total Asset Value: $1,238,500,200

Total # of Plans: 163

Total Participants: 14,075

LoVasco Consulting Group Detroit, MI Year Est.: 2013

# of Advisors: 2

Total Asset Value: $1,218,512,114

Total # of Plans: 102

Total Participants: 13,232

Hauser Retirement Solutions Cincinnati, NC Year Est.: 2012

# of Advisors: 4

Total Asset Value: $1,214,865,035

Total # of Plans: 75

Total Participants: 24,235

The TSF Group Middelton, MA Year Est.: 1999

# of Advisors: 3

Total Asset Value: $1,205,000,000

Total # of Plans: 68

Total Participants: 14,680

The Abeyta Benton Childress & Sanders Group at Morgan Stanley San Antonio, TX Year Est.: 2005

# of Advisors: 4

Total Asset Value: $1,200,000,000

Total # of Plans: 53

Total Participants: 15,000

First Western Trust Retirement Services Denver, CO Year Est.: 2007

# of Advisors: 2

Total Asset Value: $1,199,049,676

Total # of Plans: 84

Total Participants: 12,929

Alera Group -TriState New York, NY Year Est.: 2019

# of Advisors: 2

Total Asset Value: $1,180,800,000

Total # of Plans: 86

Total Participants: 24,000

AIAS Retirement Burlington, VT Year Est.: 1998

# of Advisors: 4

Total Asset Value: $1,177,537,397

Total # of Plans: 94

Total Participants: 13,344

The Clift Group at RBC Wealth Management Dallas, TX Year Est.: 1985

# of Advisors: 3

Total Asset Value: $1,174,251,425

Total # of Plans: 38

Total Participants: 35,700

The Barnett Group Melville, NY Year Est.: 2013

# of Advisors: 1

Total Asset Value: $1,168,000,000

Total # of Plans: 8

Total Participants: 40,000

CAPTRUST - Greenwich Greenwich, CT Year Est.: 2013

# of Advisors: 2

Total Asset Value: $1,140,040,252

Total # of Plans: 10

Total Participants: 7,816

The Schneck Kelnhofer Group Milwaukee, WI Year Est.: 1999

# of Advisors: 2

Total Asset Value: $1,110,000,000

Total # of Plans: 44

Total Participants: 4,387

SRP - Nashville Shorewood, IL Year Est.: 2019

# of Advisors: 2

Total Asset Value: $1,100,000,000

Total # of Plans: 45

Total Participants: 17,000

The MTND Group Dallas, TX Year Est.: 2009

# of Advisors: 3

Total Asset Value: $1,087,559,509

Total # of Plans: 40

Total Participants: 12,795

Hilb Group Retirement Services

Cranston, RI Year Est.: 2009

# of Advisors: 1

Total Asset Value: $1,085,081,986

Total # of Plans: 241

Total Participants: 19,664

Great Lakes Michigan Group

Rochester, MI Year Est.: 2003

# of Advisors: 4

Total Asset Value: $1,083,951,076

Total # of Plans: 68

Total Participants: 36,040

Accelerate Retirement

Aliso Viejo, CA Year Est.: 2023

# of Advisors: 5

Total Asset Value: $1,082,487,815

Total # of Plans: 153

Total Participants: 11,620

LHD Retirement

Indianapolis, IN Year Est.: 2004

# of Advisors: 3

Total Asset Value: $1,075,000,000

Total # of Plans: 95

Total Participants: 14,000

OneDigital - Denver, CO Englewood, CO Year Est.: 2015

# of Advisors: 2

Total Asset Value: $1,052,238,261

Total # of Plans: 406

Total Participants: 38,375

OneDigital - Bend, OR Bend, OR

# of Advisors: 3

Total Asset Value: $1,014,055,013

Total # of Plans: 26

Total Participants: 8,206

DDMP Investment Advisors

Elizabethtown, PA Year Est.: 2006

# of Advisors: 5

Total Asset Value: $1,038,552,693

Total # of Plans: 148

Total Participants: 15,540

Modern Wealth ManagementRochester, NY Lenexa, KS Year Est.: 2001

# of Advisors: 10

Total Asset Value: $1,038,398,638

Total # of Plans: 119

Total Participants: 11,659

CAPTRUST - Bellevue (Trutina) Bellevue, WA

# of Advisors: 5

Total Asset Value: $1,020,695,790

Total # of Plans: 114

Total Participants: 13,204

The Karelitz Group at Morgan Stanley Wellesley, MA Year Est.: 2005

# of Advisors: 5

Total Asset Value: $1,000,000,000

Total # of Plans: 105

Total Participants: 25,000

ISC Advisors, Inc. Dallas, TX Year Est.: 1989

# of Advisors: 8

Total Asset Value: $998,739,461

Total # of Plans: 208

Total Participants: 14,000

The Math Group at Morgan Stanley Sugar Land, TX Year Est.: 2009

# of Advisors: 10

Total Asset Value: $991,000,000

Total # of Plans: 47

Total Participants: 19,514

The J.K. Meek Group at Graystone Consulting Baltimore, MD Year Est.: 1992

# of Advisors: 5

Total Asset Value: $986,436,007

Total # of Plans: 23

Total Participants: 10,629

Strategic Financial Solutions

Cedar Rapids, IA Year Est.: 2003

# of Advisors: 9

Total Asset Value: $980,872,784

Total # of Plans: 73

Total Participants: 15,675

Strategic Retirement Partners - Mid-Atlantic Shorewood, IL Year Est.: 2000

# of Advisors: 4

Total Asset Value: $977,788,121

Total # of Plans: 98

Total Participants: 14,547

The TRC Group at Morgan Stanley San Diego, CA Year Est.: 2003

# of Advisors: 2

Total Asset Value: $956,613,128

Total # of Plans: 73

Total Participants: 26,721

Heller Stieffel and Noto Wealth Management

New Orleans, LA Year Est.: 2011

# of Advisors: 3

Total Asset Value: $950,000,000

Total # of Plans: 15

Total Participants: 2,750

Smooth 401K Strongsville, OH

Year Est.: 2018

# of Advisors: 6

Total Asset Value: $943,000,000

Total # of Plans: 167

Total Participants: 21,000

Arvest Retirement Plan Consulting Fort Smith, AR Year Est.: 1986

# of Advisors: 7

Total Asset Value: $939,811,262

Total # of Plans: 267

Total Participants: 16,361

GEN Group - RBC Wealth Management Vienna, VA

Year Est.: 2009

# of Advisors: 4

Total Asset Value: $930,000,000

Total # of Plans: 54

Total Participants: 5,200

Summit Financial Group, Inc Dallas, TX

Year Est.: 1988

# of Advisors: 5

Total Asset Value: $912,000,000

Total # of Plans: 137

Total Participants: 12,056

The Pacific Alpha Group at Morgan Stanley New York, NY Year Est.: 2024

# of Advisors: 6

Total Asset Value: $900,500,000

Total # of Plans: 101

Total Participants: 26,037

Vital Planning Group LLC

New York, NY

Year Est.: 2008

# of Advisors: 7

Total Asset Value: $900,000,000

Total # of Plans: 120

Total Participants: 12,000

Top DC Advisor Teams

Top DC Advisor Teams

The Promus Group of RBC WM Minneapolis, MN Year Est.: 2000

# of Advisors: 5

Total Asset Value: $896,641,228

85

Total Participants: 14,000

HUB International/ Aegis Retirement Group

Memphis, TN Year Est.: 2012

# of Advisors: 1

Total Asset Value: $875,000,000

Total # of Plans: 149

Total Participants: 22,300

Abbey Street

Eden Prairie, MN Year Est.: 2018

# of Advisors: 4

Total Asset Value: $870,000,000

Total # of Plans: 55

Total Participants: 13,000

The HF Retirement Group of Wells Fargo Advisors

Los Angeles, CA Year Est.: 2006

# of Advisors: 2

Total Asset Value: $859,742,099

Total # of Plans: 94

Total Participants: 7,900

Forrester Wealth Advisors of Janney Montgomery Scott LLC

Washington, DC Year Est.: 2001

# of Advisors: 3

Total Asset Value: $838,567,365

Total # of Plans: 19

Total Participants: 6,974

RTD Financial Advisors, Inc. Philadelphia, PA Year Est.: 1983

# of Advisors: 19

Total Asset Value: $822,295,983

Total # of Plans: 49

Total Participants: 5,657

The Strategic Retirement Benefits Group

Salem, NH Year Est.: 2018

# of Advisors: 3

Total Asset Value: $806,970,018

Total # of Plans: 108

Total Participants: 12,350

Peninsula Financial Group at UBS

San Mateo, CA

Year Est.: 2019

# of Advisors: 5

Total Asset Value: $806,709,203

Total # of Plans: 64

Total Participants: 7,419

mFORCE Capital

Fort Worth, TX

Year Est.: 2021

# of Advisors: 9

Total Asset Value: $806,649,594

Total # of Plans: 30

Total Participants: 5,665

Colton Groome Retirement Plan Advisors

Asheville, NC

Year Est.: 1950

# of Advisors: 3

Total Asset Value: $800,000,000

Total # of Plans: 105

Total Participants: 15,000

CAPTRUST - Lake Success

Lake Success, NY

Year Est.: 1981

# of Advisors: 3

Total Asset Value: $796,506,936

Total # of Plans: 8

Total Participants: 4,517

Strategic Retirement Partners – Upper Midwest

Shorewood, IL

Year Est.: 2018

# of Advisors: 2

Total Asset Value: $769,832,639

Total # of Plans: 73

Total Participants: 11,563

Stonebridge Financial Group

Grand Rapids, MI

Year Est.: 2004

# of Advisors: 10

Total Asset Value: $765,000,000

Total # of Plans: 115

Total Participants: 10,000

Mosaic Investment

Consulting Group

San Diego, CA

Year Est.: 2002

# of Advisors: 6

Total Asset Value: $760,000,000

Total # of Plans: 75

Total Participants: 20,000

Stokes Family Office, LLC

New Orleans, LA

Year Est.: 2019

# of Advisors: 12

Total Asset Value: $755,000,000

Total # of Plans: 66

Total Participants: 7,500

The McNamee Group Shrewsbury, NJ Year Est.: 2008

# of Advisors: 4

Total Asset Value: $743,323,355

Total # of Plans: 84

Total Participants: 18,251

OneDigitalMinnetonka, MN

Minnetonka, MN

# of Advisors: 3

Total Asset Value: $742,381,935

Total # of Plans: 59

Total Participants: 6,678

Summit Financial Group Fort Wayne, IN Year Est.: 2010

# of Advisors: 3

Total Asset Value: $742,000,000

Total # of Plans: 330

Total Participants: 13,000

OneDigital - St. Johns, FL St Johns, FL

# of Advisors: 5

Total Asset Value: $741,235,909

Total # of Plans: 118

Total Participants: 13,799

Fiduciary Wealth Management (World Investment Advisors) Vienna, VA Year Est.: 2011

# of Advisors: 2

Total Asset Value: $740,642,806

Total # of Plans: 85

Total Participants: 8,750

PPS Retirement Advisors

Williamsville, NY Year Est.: 2017

# of Advisors: 2

Total Asset Value: $728,000,000

Total # of Plans: 116

Total Participants: 7,426

THG Retirement Solutions Irvine, CA Year Est.: 2004

# of Advisors: 2

Total Asset Value: $720,000,000

Total # of Plans: 125

Total Participants: 10,000

MMA Retirement & Wealth – Southeast Region New York, NY Year Est.: 2006

# of Advisors: 2

Total Asset Value: $719,682,151

Total # of Plans: 50

Total Participants: 15,235

The Brown Group at Stifel Fairport, NY Year Est.: 1988

# of Advisors: 2

Total Asset Value: $718,747,768

Total # of Plans: 26

Total Participants: 18,500

The Banas-Yu Wealth Management Group Chicago, IL

Year Est.: 1998

# of Advisors: 2

Total Asset Value: $700,000,000

Total # of Plans: 31

Total Participants: 50,000

CSG Capital Partners of Janney Montgomery Scott Washington, DC Year Est.: 1998

# of Advisors: 4

Total Asset Value: $695,000,000

Total # of Plans: 38

Total Participants: 12,900

Bryson Wealth Management Long Beach, CA

Year Est.: 1969

# of Advisors: 4

Total Asset Value: $690,813,407

Total # of Plans: 158

Total Participants: 15,854

Newcleus Retirement Advisors

Yardley, PA

Year Est.: 2022

# of Advisors: 2

Total Asset Value: $688,800,000

Total # of Plans: 52

Total Participants: 6,200

Ellsworth Fair Wealth Management Group of RBC Houston, TX

Year Est.: 2019

# of Advisors: 2

Total Asset Value: $680,000,000

Total # of Plans: 150

Total Participants: 20,000

Retirement Plan Consulting Group Hauppauge, NY

Year Est.: 2016

# of Advisors: 5

Total Asset Value: $678,000,000

Total # of Plans: 117

Total Participants: 16,000

Legacy Wealth Management

Davenport, IA Year Est.: 2017

# of Advisors: 3

Total Asset Value: $675,130,000

Total # of Plans: 36

Total Participants: 2,592

The Oaktide Group at Morgan Stanley Naples, FL Year Est.: 2014

# of Advisors: 3

Total Asset Value: $675,000,000

Total # of Plans: 68

Total Participants: 14,265

Retirement Solutions at Citizens Private Wealth

New York, NY Year Est.: 2025

# of Advisors: 2

Total Asset Value: $670,000,000

Total # of Plans: 57

Total Participants: 15,000

OneDigitalMorristown, NJ Morristown, NJ

# of Advisors: 6

Total Asset Value: $659,670,451

Total # of Plans: 33

Total Participants: 8,342

The Wood Group at Morgan Stanley Stamford, CT Year Est.: 2009

# of Advisors: 6

Total Asset Value: $657,956,493

Total # of Plans: 17

Total Participants: 5,700

Alpha Capital Management Group Denver, CO Year Est.: 2015

# of Advisors: 2

Total Asset Value: $651,394,000

Total # of Plans: 394

Total Participants: 25,000

Insight Financial Solutions Grand Junction, CO Year Est.: 2007

# of Advisors: 3

Total Asset Value: $640,000,000

Total # of Plans: 44

Total Participants: 8,800

The Psaltis Group at Morgan Stanley Chicago, IL 2015

# of Advisors: 4

Total Asset Value: $628,598,707

Total # of Plans: 52

Total Participants: 13,301

Tao Investments Hawai`i Honolulu, HI Year Est.: 2004

# of Advisors: 5

Total Asset Value: $624,235,000

Total # of Plans: 87

Total Participants: 6,700

The Fortis Wealth Management Group Columbus, OH Year Est.: 2015

# of Advisors: 9

Total Asset Value: $622,519,802

Total # of Plans: 37

Total Participants: 14,407

Align Wealth Strategies, LLC Lancaster, PA Year Est.: 2007

# of Advisors: 3

Total Asset Value: $616,620,000

Total # of Plans: 41

Total Participants: 13,908

Retirement Impact Andover, MA Year Est.: 2021

# of Advisors: 2

Total Asset Value: $608,730,182

Total # of Plans: 41

Total Participants: 5,057

Stonebridge Financial Group, LLC Wormleysburg, PA

# of Advisors: 3

Total Asset Value: $590,200,000

Total # of Plans: 138

Total Participants: 8,000

Retirement Fiduciary Group, LLC Andover, MA

Year Est.: 2019

# of Advisors: 5

Total Asset Value: $589,091,105

Total # of Plans: 59

Total Participants: 8,716

Vision Wealth Partners Columbia, MD

Year Est.: 2009

# of Advisors: 4

Total Asset Value: $595,768,188

Total # of Plans: 90

Total Participants: 7,000

Kidder Advisers, Inc.

Urbandale, IA Year Est.: 1996

# of Advisors: 3

Total Asset Value: $585,000,000

Total # of Plans: 54

Total Participants: 4,200

Cadence Financial Management

Marlton, NJ Year Est.: 2018

# of Advisors: 4

Total Asset Value: $584,782,864

Total # of Plans: 74

Total Participants: 8,735

Strategic Financial Services, Inc.

Utica, NY Year Est.: 1979

# of Advisors: 3

Total Asset Value: $582,902,153

Total # of Plans: 98

Total Participants: 7,856

OneDigital - OneDigital Complete Retirement Solution

Atlanta, GA

# of Advisors: 3

Total Asset Value: $560,173,635

Total # of Plans: 422

Total Participants: 12,560

Freedom Fiduciaries Eagle, ID Year Est.: 2023

# of Advisors: 2

Total Asset Value: $575,000,000

Total # of Plans: 124

Total Participants: 12,000

Tritis Wealth Management, LLC

Sugar Land, TX Year Est.: 2009

# of Advisors: 3

Total Asset Value: $575,000,000

Total # of Plans: 275

Total Participants: 8,800

The Resnick Group Chicago, IL

Total Asset Value: $570,767,491

Total # of Plans: 9

Total Participants: 10,644

Veery Capital Wilmington, DE Year Est.: 2012

# of Advisors: 4

Total Asset Value: $569,989,256

Total # of Plans: 74

Total Participants: 5,759

Pathlight Advisors

Scottsdale, AZ Year Est.: 2019

# of Advisors: 6

Total Asset Value: $569,151,068

Total # of Plans: 75

Total Participants: 11,459

HUB RPW Pasadena Pasadena, CA Year Est.: 2014

# of Advisors: 2

Total Asset Value: $560,000,000

Total # of Plans: 45

Total Participants: 9,955

Becker Suffern McLanahan, Ltd. Mandeville, LA Year Est.: 1962

# of Advisors: 3

Total Asset Value: $556,616,994

Total # of Plans: 152

Total Participants: 5,809

Westgate Capital Consultants, a HUB International Company University Place, WA Year Est.: 1986

# of Advisors: 3

Total Asset Value: $555,058,151

Total # of Plans: 93

Total Participants: 7,786

Capital Benefits LLC Fairfield, NJ Year Est.: 2006

# of Advisors: 2

Total Asset Value: $550,000,000

Total # of Plans: 80

Total Participants: 3,400

Strategic Retirement Partners - Charleston Mount Pleasant, SC Year Est.: 2000

# of Advisors: 1

Total Asset Value: $537,110,096

Total # of Plans: 43

Total Participants: 9,674

KerberRose Retirement Shawano, WI Year Est.: 2017

# of Advisors: 4

Total Asset Value: $532,580,861

Total # of Plans: 215

Total Participants: 8,495

Top DC Advisor Teams

Franklin & Lewis Investment Group at RBC Wealth Management Minneapolis, MN Year Est.: 2000

# of Advisors: 3

Total Asset Value: $532,000,000

Total # of Plans: 10

Total Participants: 3,101

PWMG 401(k) Advisors Worcester, MA Year Est.: 2007

# of Advisors: 3

Total Asset Value: $531,847,646

Total # of Plans: 119

Total Participants: 7,658

Manhattan Ridge Advisors New York, NY Year Est.: 2006

# of Advisors: 4

Total Asset Value: $530,790,823

Total # of Plans: 78

Total Participants: 7,815

Mountain Wealth Management Pasadena, CA Year Est.: 2016

# of Advisors: 2

Total Asset Value: $529,607,940

Total # of Plans: 55

Total Participants: 13,370

PensionmarkMeridien Warwick, RI Year Est.: 1975

# of Advisors: 6

Total Asset Value: $526,000,000

Total # of Plans: 66

Total Participants: 4,080

OneDigital - Portland, OR Portland, OR

# of Advisors: 2

Total Asset Value: $522,185,576

Total # of Plans: 60

Total Participants: 7,480

The Austin Group at Morgan Stanley San Diego, CA Year Est.: 2009

# of Advisors: 3

Total Asset Value: $522,000,328

Total # of Plans: 32

Total Participants: 4,500

Comprehensive Financial Planning, Inc.

East Petersburg, PA Year Est.: 1978

# of Advisors: 3

Total Asset Value: $515,125,965

Total # of Plans: 62

Total Participants: 5,448

The Beacon Ridge Group at Morgan Stanley Bloomington, MN

Year Est.: 2025

# of Advisors: 4

Total Asset Value: $515,000,000

Total # of Plans: 52

Total Participants: 13,000

BHS Financial Services Grandville, MI

Year Est.: 2012

# of Advisors: 3

Total Asset Value: $515,000,000

Total # of Plans: 100

Total Participants: 75,000

Bienville Capital Group Metairie, LA Year Est.: 2003

# of Advisors: 2

Total Asset Value: $514,443,041

Total # of Plans: 120

Total Participants: 8,500

Varney Financial Portland, ME Year Est.: 1996

# of Advisors: 4

Total Asset Value: $510,000,000

Total # of Plans: 98

Total Participants: 6,000

OneDigital - Houston, TX Houston, TX

# of Advisors: 6

Total Asset Value: $507,036,922

John Barry - JMB Wealth Management, Inc. Torrance, CA Year Est.: 2006

# of Advisors: 1

Total Asset Value: $505,000,000

Total # of Plans: 65

Total Participants: 10,000

Graystone ConsultingRaleigh, Wichita, Dallas, and Kansas City Raleigh, NC Year Est.: 2014

# of Advisors: 11

Total Asset Value: $504,015,865

Total # of Plans: 42

Total Participants: 9,518

HUB South Florida Fort Lauderdale, FL Year Est.: 2002

# of Advisors: 8

Total Asset Value: $503,387,015

Total # of Plans: 96

Total Participants: 11,000

The BBM Wealth Management Group at Morgan Stanley Morristown, NJ Year Est.: 2021

# of Advisors: 7

Total Asset Value: $501,403,907

Total # of Plans: 62

Total Participants: 10,600

Beacon Financial Services Wayne, PA Year Est.: 1996

# of Advisors: 6

Total Asset Value: $501,000,000

Total # of Plans: 74

Total Participants: 7,153

Plan Sponsor Consultants, a division of Hub International Alpharetta, GA Year Est.: 2008

# of Advisors: 2

Total Asset Value: $488,000,000

Total # of Plans: 16

Total Participants: 6,600

Saiph Capital Wyckoff, NJ Year Est.: 2021

# of Advisors: 3

Total Asset Value: $487,000,000

Total # of Plans: 42

Total Participants: 5,050

DeNovo Advisory Group Dallas, TX Year Est.: 2012

# of Advisors: 11

Total Asset Value: $478,000,000

Total # of Plans: 74

Total Participants: 13,500

Horizon Financial Group Baton Rouge, LA Year Est.: 1999

# of Advisors: 7

Total Asset Value: $469,570,202

Total # of Plans: 76

Total Participants: 4,200

Equity Planning Group Toledo, OH Year Est.: 1999

# of Advisors: 3

Total Asset Value: $466,795,865

Total # of Plans: 80

Total Participants: 5,250

MPD Park Avenue Group New York, NY Year Est.: 2010

# of Advisors: 3

Total Asset Value: $463,098,514

Total # of Plans: 48

Total Participants: 14,250

EverThrive Financial Group

Birmingham, AL Year Est.: 2004

# of Advisors: 4

Total Asset Value: $462,372,069

Total # of Plans: 38

Total Participants: 12,640

QP Consulting, LLC

Takoma Park, MD

Year Est.: 2002

# of Advisors: 2

Total Asset Value: $461,000,000

Total # of Plans: 40

Total Participants: 3,000

The Dimino Group at RBC Wealth Management Red Bank, NJ Year Est.: 2013

# of Advisors: 3

Total Asset Value: $459,643,867

Total # of Plans: 130

Total Participants: 8,010

CAPTRUST - Greenville Greenville, SC

Year Est.: 1996

# of Advisors: 8

Total Asset Value: $458,315,035

Total # of Plans: 45

Total Participants: 4,856

The Saunders Investment Group

New York, NY Year Est.: 1999

# of Advisors: 1

Total Asset Value: $457,377,270

Total # of Plans: 37

Total Participants: 6,801

DJM Financial Irvine, CA

Year Est.: 2017

# of Advisors: 10

Total Asset Value: $452,165,437

Total # of Plans: 198

Total Participants: 5,353

Stark Miller Financial Benefits Group Lafayette, CA

Year Est.: 2005

# of Advisors: 2

Total Asset Value: $448,109,723

Total # of Plans: 32

Total Participants: 4,200

Sentinel Harbor Wealth Management Group Lutherville, MD

# of Advisors: 8

Total Asset Value: $446,729,582

Total # of Plans: 47

Total Participants: 14,857

IBS Financial Group

Grand Rapids, MI Year Est.: 1979

# of Advisors: 1

Total Asset Value: $406,864,568

Total # of Plans: 38

Total Participants: 3,157

Ressler Financial Consulting Group of Wells Fargo Advisors Radnor, PA Year Est.: 2009

# of Advisors: 2

Total Asset Value: $405,220,400

Total # of Plans: 36

Total Participants: 4,200

Legacy 401k Partners Grapevine, TX 2009

# of Advisors: 3

Total Asset Value: $401,000,000

Total # of Plans: 25

Total Participants: 5,624

SRP Houston Shorewood, IL Year Est.: 1998

# of Advisors: 3

Total Asset Value: $398,000,000

Total # of Plans: 14

Total Participants: 6,200

OneDigital - Scottsdale, AZ Scottsdale, AZ

# of Advisors: 1

Total Asset Value: $395,426,402

Total # of Plans: 31

Total Participants: 8,972

Kirby Wealth Management Group Champaign, IL Year Est.: 1995

# of Advisors: 1

Total Asset Value: $391,720,757

Total # of Plans: 150

Total Participants: 5,299

The Lynnvest Group at RBC Wealth Management Beverly Hills, CA Year Est.: 1999

# of Advisors: 2

Total Asset Value: $387,332,098

Total # of Plans: 32

Total Participants: 5,183

The Passman Saperstein Bahr Group Purchase, NY Year Est.: 2020

# of Advisors: 4

Total Asset Value: $385,000,000

Total # of Plans: 40

Total Participants: 5,943

Equanimity Wealth Management Okemos, MI Year Est.: 1992

# of Advisors: 1

Total Asset Value: $364,654,816

Total # of Plans: 33

Total Participants: 3,500

HUB International Fort Myers Fort Myers, FL Year Est.: 2012

# of Advisors: 1

Total Asset Value: $356,000,000

Total # of Plans: 36

Total Participants: 6,793

The Lepore Group Birmingham, MI

Total Asset Value: $355,000,000

Total # of Plans: 41

Total Participants: 4,482

Modern Wealth ManagementEl Segundo, CA Lenexa, KS Year Est.: 2002

# of Advisors: 2

Total Asset Value: $354,693,212

Total # of Plans: 22

Total Participants: 2,291

Retirement Plan Solutions Waukesha, WI Year Est.: 2004

# of Advisors: 1

Total Asset Value: $354,175,287

Total # of Plans: 26

Total Participants: 3,381

The Oak Pointe Wealth Management Group at Morgan Stanley New Orleans, LA Year Est.: 2015

# of Advisors: 4

Total Asset Value: $350,000,000

Total # of Plans: 31

Total Participants: 3,100

Leavitt Group Wexford, PA Year Est.: 1976

# of Advisors: 10

Total Asset Value: $349,743,520

Total # of Plans: 58

Total Participants: 7,281

Sides Wealth Advisory Group

York, PA Year Est.: 2023

# of Advisors: 5

Total Asset Value: $345,000,000

Total # of Plans: 54

Total Participants: 4,457

The Nicoletti Financial Group of Stifel Palm Beach, FL Year Est.: 2000

# of Advisors: 2

Total # of Plans: Total Asset Value:

$333,001,970

Total # of Plans: 20

Total Participants: 5,506

Vista Wealth Management Schaumburg, IL Year Est.: 2021

# of Advisors: 4

Total Asset Value: $330,717,679

Total # of Plans: 184

Total Participants: 5,278

The Converse Team Wichita, KS Year Est.: 2002

# of Advisors: 6

Total Asset Value: $326,264,167

Total # of Plans: 140

Total Participants: 6,000

Jbara and Rogers Financial Management Group Farmington Hills, MI

# of Advisors: 3

Total Asset Value: $324,891,240

Total # of Plans: 19

Total Participants: 2,243

Blueprint Financial Cleveland, OH Year Est.: 2007

# of Advisors: 2

Total Asset Value: $320,300,000

Total # of Plans: 20

Total Participants: 3,350

The Dallas Consulting Group at Morgan Stanley Dallas, TX Year Est.: 1996

# of Advisors: 6

Total Asset Value: $303,995,109

Total # of Plans: 13

Total Participants: 15,777

The Tide Point Group New York, NY Year Est.: 2013

# of Advisors: 2

Total Asset Value: $300,000,000

Total # of Plans: 10

Total Participants: 4,762

Financial Integrators

Des Moines, IA Year Est.: 2006

# of Advisors: 1

Total Asset Value: $287,019,735

Total # of Plans: 137

Total Participants: 5,959

The Edwards Group at Morgan Stanley Columbus, OH Year Est.: 1989

# of Advisors: 5

Total Asset Value: $281,286,310

Total # of Plans: 369

Total Participants: 9,324

Atkinson Group - RBC Wealth Management

St. Paul, MN Year Est.: 2007

# of Advisors: 1

Total Asset Value: $276,173,524

Total # of Plans: 14

Total Participants: 2,005

Hamilton Capital Columbus, OH Year Est.: 1997

# of Advisors: 42

Total Asset Value: $273,225,888

Total # of Plans: 120

Total Participants: N/A

Morgan Capital Solutions Southlake, TX Year Est.: 2013

# of Advisors: 1

Total Asset Value: $271,235,000

Total # of Plans: 6

Total Participants: 1,000

Integrated Wealth Solutions

Overland Park, KS Year Est.: 1998

# of Advisors: 3

Total Asset Value: $269,362,769

Total # of Plans: 36

Total Participants: 3,553

Panfang Fu Weehawken, NJ

Year Est.: 1993

# of Advisors: 1

Total Asset Value: $260,000,000

Total # of Plans: 30

Total Participants: 1,400

The LaCross Team Albuquerque, NM Year Est.: 2017

# of Advisors: 5

Total Asset Value: $255,370,000

Total # of Plans: 57

Total Participants: 3,400

Top DC Advisor Teams

The Zelniker Dorfman Carr & Heritage Group New York, NY Year Est.: 1992

# of Advisors: 7

Total Asset Value: $249,258,000

Total # of Plans: 46

Total Participants: 1,450

Michigan 401K Advisors

Bloomfield Hills, MI Year Est.: 1995

# of Advisors: 6

Total Asset Value: $248,000,000

Total # of Plans: 105

Total Participants: 6,000

Summit Group Retirement, Planners Inc.

Exton, PA Year Est.: 2013

# of Advisors: 2

Total Asset Value: $241,837,884

Total # of Plans: 58

Total Participants: 6,000

Power Financial Partners Tampa, FL Year Est.: 2023

# of Advisors: 1

Total Asset Value: $239,008,376

Total # of Plans: 127

Total Participants: 4,937

The Sentinel Ponte Vedra Group at Morgan Stanley Ponte Vedra Beach, Fl Year Est.: 2020

# of Advisors: 3

Total Asset Value: $236,863,193

Total # of Plans: 76

Total Participants: 11,410

Polaris Advisors, LLC Camp Hill, PA

# of Advisors: 5

Total Asset Value: $235,788,065

Total # of Plans: 49

Total Participants: 6,307

LCJ Associates Brooklyn, NY Year Est.: 1987

# of Advisors: 4

Total Asset Value: $227,000,000

Total # of Plans: 49

Total Participants: 1,776

BQS Financial Advisors

New York, NY Year Est.: 2024

# of Advisors: 5

Total Asset Value: $224,400,000

Total # of Plans: 27

Total Participants: 6,650

Western Retirement Consultants

Greenwood Village, CO Year Est.: 2018

# of Advisors: 2

Total Asset Value: $224,324,031

Total # of Plans: 47

Total Participants: 2,151

IVC Wealth Advisors Silverdale, PA Year Est.: 2014

# of Advisors: 4

Total Asset Value: $219,366,596

Total # of Plans: 40

Total Participants: 2,216

The Okby Group at Morgan Stanley

Saratoga Springs, NY Year Est.: 1991

# of Advisors: 3

Total Asset Value: $218,260,488

Total # of Plans: 25

Total Participants: 6,604

LCG Wealth Management

Dothan, AL

Year Est.: 2025

# of Advisors: 6

Total Asset Value: $213,884,451

Total # of Plans: 68

Total Participants: 2,240

Investors Brokerage of Texas - Brian Bachik Waco, TX

Year Est.: 2000

# of Advisors: 1

Total Asset Value: $213,557,335

Total # of Plans: 31

Total Participants: 2,500

DDR Wealth Advisors

Rochester Hills, MI Year Est.: 2011

# of Advisors: 3

Total Asset Value: $212,159,235

Total # of Plans: 79

Total Participants: 4,451

Revant Wealth

Irvine, CA

Year Est.: 2025

# of Advisors: 5

Total Asset Value: $210,000,000

Total # of Plans: 94

Total Participants: 7,000

Allmerits Asset, LLC

Los Angeles, CA

Year Est.: 2018

# of Advisors: 12

Total Asset Value: $209,309,585

Total # of Plans: 124

Total Participants: 2,458

Montanti Advisory Services LLC

Boca Raton, FL Year Est.: 1969

# of Advisors: 1

Total Asset Value: $202,000,000

Total # of Plans: 48

Total Participants: 4,000

Rose Street Advisors

Kalamazoo, MI Year Est.: 2012

# of Advisors: 1

Total Asset Value: $196,325,737

Total # of Plans: 39

Total Participants: 2,348

Karl Nikodym Wealth Management Group

St. Cloud, MN Year Est.: 1981

# of Advisors: 2

Total Asset Value: $194,807,839

Total # of Plans: 22

Total Participants: 1,500

401TK.com | A Specialized Company Marquette, MI Year Est.: 2021

# of Advisors: 1

Total Asset Value: $186,206,412

Total # of Plans: 3

Total Participants: 2,183

Eukles Wealth Management Cincinnati.OH Year Est.: 2011

# of Advisors: 4

Total Asset Value: $186,000,000

Total # of Plans: 30

Total Participants: 3,700

Cottonwood Wealth Partners Wichita, KS Year Est.: 2001

# of Advisors: 2

Total Asset Value: $183,748,000

Total # of Plans: 18

Total Participants: 636

ProVise Management Group

Clearwater, FL Year Est.: 2012

# of Advisors: 3

Total Asset Value: $180,000,000

Total # of Plans: 37

Total Participants: 1,750

Paragon HM Wealth Management Group at Morgan Stanley Birmingham, AL Year Est.: 2005

# of Advisors: 9

Total Asset Value: $178,836,397

Total # of Plans: 38

Total Participants: 2,665

Insight Financial Partners, LLC

Crystal Lake, IL Year Est.: 2017

# of Advisors: 2

Total Asset Value: $174,810,113

Total # of Plans: 32

Total Participants: 3,017

Hull and Martin Wealth Management Group of Stifel

Bowling Green, KY Year Est.: 1995

# of Advisors: 2

Total Asset Value: $173,778,271

Total # of Plans: 8

Total Participants: 1,302

Coastal Financial Strategies Group of Stifel Southfield, MI Year Est.: 2019

# of Advisors: 6

Total Asset Value: $168,692,377

Total # of Plans: 31

Total Participants: 2,112

Discovery Financial Ada, MI

Year Est.: 2001

# of Advisors: 2

Total Asset Value: $167,929,029

Total # of Plans: 25

Total Participants: 2,797

The Belew and Connolly Team Florence, AL Year Est.: 2008

# of Advisors: 4

Total Asset Value: $167,000,000

Total # of Plans: 13

Total Participants: 3,832

Oakbourne Advisors West Chester, PA Year Est.: 2020

# of Advisors: 5

Total Asset Value: $163,417,880

Total # of Plans: 57

Total Participants: 2,100

Kieckhaefer Wealth Management Group of RBC Wealth Management

Delafield, WI Year Est.: 2010

# of Advisors: 3

Total Asset Value: $163,094,682

Total # of Plans: 81

Total Participants: 1,413

Bottema Callahan Financial Partners Wayzata, MN Year Est.: 1996

# of Advisors: 2

Total Asset Value: $160,000,000

Total # of Plans: 42

Total Participants: 2,425

The Clevenger Douglas Group

Austin, TX Year Est.: 2017

# of Advisors: 3

Total Asset Value: $151,000,000

Total # of Plans: 50

Total Participants: 5,000

The Wilkins Strout Group Colchester, VT Year Est.: 2021

# of Advisors: 2

Total Asset Value: $148,612,285

Total # of Plans: 39

Total Participants: 5,523

Forsberg Insurance Planning Plymouth, MA Year Est.: 1986

# of Advisors: 2

Total Asset Value: $145,000,000

Total # of Plans: 30

Total Participants: 1,232

Legacy Wealth Management

Melville, NY Year Est.: 2019

# of Advisors: 3

Total Asset Value: $141,852,752

Total # of Plans: 14

Total Participants: 1,500

High Probability Advisors Pittsford, NY Year Est.: 2017

# of Advisors: 6

Total Asset Value: $141,255,151

Total # of Plans: 37

Total Participants: 2,843

Baldwin Capital Management Northville, MI

Year Est.: 1985

# of Advisors: 7

Total Asset Value: $135,000,000

Total # of Plans: 42

Total Participants: 3,400

401(k) Advisory Group, LLC / Castle Hill Retirement Partners

Westwood, MA Year Est.: 2013

# of Advisors: 2

Total Asset Value: $131,689,090

Total # of Plans: 111

Total Participants: 1,139

The Heath-Grooms Group Birmingham, AL Year Est.: 2009

# of Advisors: 2

Total Asset Value: $130,575,267

Total # of Plans: 23

Total Participants: 3,731

Thimble Island Private Wealth Branford, CT Year Est.: 2024

# of Advisors: 7

Total Asset Value: $129,285,200

Total # of Plans: 35

Total Participants: 2,652

J.P. Morgan Wealth Management, Robert Thorburn

New York, NY

Year Est.: 2014

# of Advisors: 1

Total Asset Value: $125,000,000

Total # of Plans: 12

Total Participants: 1,200

OneDigital - St. Louis, MO

St. Louis, MO

# of Advisors: 4

Total Asset Value: $124,958,847

Total # of Plans: 26

Total Participants: 830

Armour Bellavia Stuhlman Group

New York, NY

Year Est.: 2022

# of Advisors: 4

Total Asset Value: $118,740,163

Total # of Plans: 6

Total Participants: 1,164

FGF Partners

Los Angeles, CA

Total Asset Value: $118,068,390

Total # of Plans: 15

Total Participants: 500

Horizon NY Melville, NY

Year Est.: 2019

# of Advisors: 3

Total Asset Value: $110,000,000

Total # of Plans: 11

Total Participants: 150

LPL Financial Scottsdale, AZ

Year Est.: 1990

# of Advisors: 3

Total Asset Value: $110,000,000

Total # of Plans: 90

Total Participants: 3,000

Blonkvist-Teller Legacy Wealth - RBC Wealth Management

Minneapolis, MN Year Est.: 2024

# of Advisors: 4

Total Asset Value: $105,385,370

Total # of Plans: 15

Total Participants: 713

Suissa Private Wealth Group

Chevy Chase, MD

Year Est.: 2001

# of Advisors: 2

Total Asset Value: $101,000,000

Total # of Plans: 19

Total Participants: 120

Top DC Advisor Teams

CAPTRUST

Raleigh, NC 1997

# of Individual Offices: 90

Total Plan Advisors: 190

Total Asset Value: $941,542,195,756

Total # of Plans: 4,396

Total Participants: 7,293,936

SageView Advisory Group, A Creative Planning Company Newport Beach, CA 1989

# of Individual Offices: 35

Total Plan Advisors: 170

Total Asset Value: $279,829,302,467

Total # of Plans: 2,427

Total Participants: 3,497,866

Creative Planning Retirement Services

Overland Park, KS 1983

# of Individual Offices: 19

Total Plan Advisors: 57

Total Asset Value: $209,818,720,354

Total # of Plans: 8,794

Total Participants: 2,651,391

HUB Retirement & Private Wealth Chicago, IL 1998

# of Individual Offices: 126

Total Plan Advisors: 320

Total Asset Value: $190,000,000,000

Total # of Plans: 13,600

Total Participants: 2,500,000

GRP Financial San Rafael, CA 2014

# of Individual Offices: 155

Total Plan Advisors: 513

$175,815,220,000

Total # of Plans: 11,790

Total Participants: 2,648,935

UBS Financial Services Weehawken, NJ 1862

# of Individual Offices: 300

Total Plan Advisors: 500

Total Asset Value: $169,000,000,000

Total # of Plans: 6,700

Total Participants: 2,000,000

Gallagher Fiduciary Advisors, LLC Rolling Meadows, IL 1978

# of Individual Offices: 38

Total Plan Advisors: 117

Total Asset Value: $150,658,137,787

Total # of Plans: 2,272

Total Participants: 1,749,512

OneDigital Atlanta, GA 1989

# of Individual Offices: 50

Total Plan Advisors: 175

Total Asset Value: $139,820,138,313

Total # of Plans: 5528

Total Participants: 1,740,664

MMA Retirement & Wealth New York, NY 2015

# of Individual Offices: 31

Total Plan Advisors: 138

Total Asset Value: $113,000,000,000

Total # of Plans: 2,862

Total Participants: 1,600,000

NFP Retirement Advisory New York, NY 1999

Total Plan Advisors: 97

Total Asset Value: $97,000,000,000

Total # of Plans: 3,500

CBIZ Investment Advisory Services, LLC Cleveland, OH 2018

# of Individual Offices: 22

Total Plan Advisors: 72

Total Asset Value: $64,590,530,969

Total # of Plans: 1,645

Total Participants: 450,001

World Investment Advisors Santa Barbara, CA 1988

# of Individual Offices: 80

Total Plan Advisors: 125

Total Asset Value: $56,200,000,000

Total # of Plans: 4,800

Alera Group Deerfield, IL 2017

# of Individual Offices: 15

Total Plan Advisors: 48

Total Asset Value: $28,500,000,000

Total # of Plans: 1,448

Alliant Retirement Consulting Alpharetta, GA

Total Asset Value: $26,726,821,721

Total # of Plans: 934

Strategic Retirement Partners Shorewood, IL 2015

# of Individual Offices: 36

Total Plan Advisors: 74

Total Asset Value: $24,933,530,643

Total # of Plans: 1,299

Total Participants: 405,751

Cerity Partners

New York, NY 2009

# of Individual Offices: 70

Total Plan Advisors: 78

Total Asset Value: $24,702,613,788

Total # of Plans: 791

Total Participants: 223,424

PNC Institutional Asset Management Pittsburgh, PA

Total Asset Value: $14,735,771,861

Total # of Plans: 462

Regions Institutional Services Birmingham, AL 1971

# of Individual Offices: 17

Total Plan Advisors: 26

Total Asset Value: $14,207,775,074

Total # of Plans: 371

HUB Retirement and Wealth ManagementMid-Atlantic Bethesda, MD 1998

# of Individual Offices: 6

Total Plan Advisors: 10

Total Asset Value: $12,192,112,936

Total # of Plans: 661

Total Participants: 143,035

Heffernan Financial Walnut Creek, CA 1995

# of Individual Offices: 5

Total Plan Advisors: 6

Total Asset Value: $8,338,964,291

Total # of Plans: 331

Total Participants: 95,407

intellicents

Albert Lea, MN 2015

# of Individual Offices: 11

Total Plan Advisors: 22

Total Asset Value: $8,000,000,000

Total # of Plans: 550

Total Participants: 80,000

Fisher/SMB Plano, TX 2014

# of Individual Offices: 2

Total Plan Advisors: 64

Total Asset Value: $7,003,107,036

Total # of Plans: 1,776

Total Participants: 89,000

Oswald Financial Cleveland, OH 1999

# of Individual Offices: 3

Total Plan Advisors: 14

Total Asset Value: $6,015,737,707

Total # of Plans: 346

Total Participants: 83,421

Moneta

St. Louis, MO 1869

# of Individual Offices: 7

Total Plan Advisors: 82

Total Asset Value: $5,628,100,876

Total # of Plans: 283

Accelerate Retirement

Aliso Viejo, CA 2023

# of Individual Offices: 18

Total Plan Advisors: 30

Total Asset Value: $5,500,000,000

Total # of Plans: 531

Total Participants: 40,670

Shepherd Financial Carmel, IN 2015

# of Individual Offices: 5

Total Plan Advisors: 18

Total Asset Value: $5,253,860,699

Total # of Plans: 357

Total Participants: 61,738

Procyon Advisors, LLC Shelton, CT 2017

# of Individual Offices: 7

Total Plan Advisors: 4

Total Asset Value: $5,160,000,000

Total # of Plans: 122

Total Participants: 43,500

Everhart Advisors Dublin, OH 1995

# of Individual Offices: 3

Total Plan Advisors: 14

Total Asset Value: $4,676,088,468

Total # of Plans: 544

Total Participants: 69,986

ClearSight Advisors of Raymond James Atlanta, GA 2023

# of Individual Offices: 3

Total Plan Advisors: 4

Total Asset Value: $4,300,000,000

Total # of Plans: 84

Total Participants: 57,000

Bernstein Private Wealth Management Nashville, TN 1967

# of Individual Offices: 19

Total Plan Advisors: 23

Total Asset Value: $4,210,000,000

Total # of Plans: 349

Total Participants: 35,000

Beacon Pointe Advisors Newport Beach, CA 2002

# of Individual Offices: 92

Total Plan Advisors: 84

Total Asset Value: $2,690,000,000

Total # of Plans: 345

Total Participants: 19,318

Guidance Point Retirement Services Bangor, ME 2012

# of Individual Offices: 2

Total Plan Advisors: 5

Total Asset Value: $2,472,157,726

Total # of Plans: 66

1834 Investment Advisors Milwaukee, WI 1976

# of Individual Offices: 10

Total Plan Advisors: 12

Total Asset Value: $2,400,000,000

Total Participants: 277

Plexus Financial Services, LLC Deer Park, IL 1993

# of Individual Offices: 3

Total Plan Advisors: 3

Total Asset Value: $2,211,743,000

Total # of Plans: 74

Total Participants: 27,650

Modern Wealth Management Lenexa, KS 2001

# of Individual Offices: 19

Total Plan Advisors: 6

Total Asset Value: $1,725,199,101

Total # of Plans: 200

Total Participants: 26,256

Level Four Advisory Services Dallas, TX 2000

# of Individual Offices: 38

Total Plan Advisors: 8

Total Asset Value: $1,354,155,201

Total # of Plans: 414

Total Participants: 15,525

Schneider Downs Wealth Management Advisors, LP Pittsburgh, PA 2000

# of Individual Offices: 2

Total Plan Advisors: 8

$1,272,164,735

Total # of Plans: 108

Total Participants: 16,236

ISC Group Dallas, TX 1987

# of Individual Offices: 6

Total Plan Advisors: 11

Total Asset Value: $1,180,012,305

Total # of Plans: 206

Total Participants: 18,000

Provenance Wealth Advisors Fort Lauderdale, FL 2006

# of Individual Offices: 6

Total Plan Advisors: 4

Total Asset Value: $1,097,770,849

Total # of Plans: 128

Total Participants: 11,890

CG Financial Services Williamston, MI 1999

# of Individual Offices: 8

Total Plan Advisors: 8

Total Asset Value: $885,517,511

Total # of Plans: 200

Total Participants: 11,967

Two Years Later: AI’s

Growing Role in Retirement Plan Advice

My core view is unchanged, and AI is an evolution (although significant), not a revolution, in the retirement community.

By David Levine, Groom Law Group, Chartered

Two years ago, I wrote a NAPA Net article about whether artificial intelligence in the retirement world was fact, fiction, or both. Some things that were fiction then are fact now, but AI remains an evolving solution. While AI was a novelty for many advisors two years ago, it is now a daily tool for many. It is increasingly a core part of

advisors’ internal processes, advice, and participant-facing services, as well as the platforms that advisors, plan sponsors, and participants use every day. So, where do things stand now, and where should an advisor focus today?

Data Ownership

Two years ago, a common question was “What happens

to my data?” Today, the better question is “who owns it, and what may they do with it?” These questions are not the same. Many AI providers and solutions now distinguish among the plan or participant data a client provides, the results an AI solution generates, and the de-identified or aggregated data a vendor derives from both. A contract may grant an advisor,

Personalized information is only as good as the data, guardrails, and reviews of the AI system providing it. An advisor can play a key role in proactively addressing these potential risks — both for its clients and themself.

plan, or participant ownership of its input data while giving the vendor a broad, perpetual license to use aggregated or anonymized data for other uses.

Anonymized data has long been used across the retirement industry, but understanding these lines and what an advisor, their organization, and their clients are comfortable with is key.

Data Privacy and Security

The regulatory backdrop I described two years ago has only intensified. The Department of Labor has continued to highlight its cybersecurity expectations; more states have enacted comprehensive privacy laws with their own consent and deletion requirements, and plaintiffs’ attorneys continue to scrutinize how plan data is handled. AI may be transmitted to a model provider, processed by another party, and retained for varying periods in various places. Understanding where your and your client’s data is stored and processed – and how it is retained (or can or cannot be deleted)- can be a key question.

Training and Retention

A question that increasingly comes up is whether the data input into an AI system by an advisor, plan sponsor, or participant is used to train the underlying AI or large language model.

Many enterprise offerings now provide “zero-retention”

or “no-training” options that contractually bar the vendor from using a client’s inputs to improve its models. Still, those terms are not universal and are frequently the default only for the most expensive tiers.

Understanding whether and how any vendor uses data for AI training is now a common focus because once a model has learned from confidential data, it is usually extremely difficult, if not impossible, to reverse the process.

Personalization at Scale

Personalization has been a significant focus in participantfocused services for many years. AI now allows advisors, recordkeepers, TPAs, and other parties to tailor participant communications, savings nudges, and education to an individual’s age, balance, and behavior in ways that were previously impractical.

These features hold the potential to move participants and beneficiaries toward enhanced retirement outcomes. However, one item to note is that errors still exist. As I noted two years ago, AI can “hallucinate” and make up answers.

Personalized information is only as good as the data, guardrails, and reviews of the AI system providing it. An advisor can play a key role in proactively addressing these potential risks — both for its clients and themself.

Efficiency and Cost Savings

There is no question that AI can increase efficiency. Firstdraft investment summaries and routine participant inquiries are increasingly handled with meaningful time savings, which can translate into lower costs or the capacity to serve more clients.

But savings can often benefit from being measured net of the new work AI creates — the human review, vetting, and documentation that prevent inaccurate output from becoming a permanent record. Advisors can use AI to leverage their judgment, not just replace it.

Two years later, my core view is unchanged: AI is an evolution (although significant), not a revolution, in the retirement community. What has changed is that the questions have moved from the abstract to the contractual — from “can AI do this?” to “who owns the data, who trained on it, and who is responsible when it is wrong?”

Advisors who can help their clients ask — and answer — those weedier questions, while capturing the genuine gains in personalization, efficiency, and cost, will be the ones who turn two steps forward and one step back into steady, durable progress, helping participants and beneficiaries prepare for and move through their retirement years. NNTM

Courts Push Back on Expanding ERISA Theories — Even as Plaintiffs Push New Ones

Here’s what you really need to know about emerging trends in litigation.

By Nevin E. Adams, JD & Bonnie Treichel, JD

The ERISA litigation landscape continues to evolve rapidly — but recent rulings suggest courts are becoming less willing to allow creative fiduciary theories to survive without concrete allegations of procedural failure. Here’s What You Really Need to Know

• Forfeiture reallocation challenges continue to be filed, and the Department of Labor (DOL) has now asked and been granted permission to participate in oral arguments in those cases.

• A new voluntary benefits suit has been filed by Schlichter Bogard LLC, suggesting there might be more to come.

• Fund performance suits continue to emerge, though prudent processes still often prevail, particularly if no meaningful benchmark is alleged.

• A massive suit against Ford Motor Company highlights an emerging litigation trend of alleging a “kitchen sink” of fiduciary breach allegations.

Let’s Dive In!

Forfeiture reallocation suits have proliferated rapidly over

the past two years, generally alleging that fiduciaries breached their duties by using forfeited employer contributions to reduce future employer contributions rather than using those forfeitures to offset participant-paid plan expenses.

Plaintiffs have argued that this practice improperly benefited employers at the expense of participants.

Recent dismissal rulings continue to give plan sponsors meaningful defenses where the challenged use of forfeitures was expressly permitted by the plan document and consistent with long-standing Internal Revenue Service (IRS) and Department of Treasury guidance. During the quarter, several cases alleging a fiduciary breach in the application of plan forfeitures were dismissed, including suits against BMO, Mohawk Valley Health, and WPP Group USA.1

Those decisions reinforce that plan sponsors are in a stronger position when their plan documents clearly authorize forfeitures to be used to reduce employer contributions and when fiduciaries can show that they acted within the plan’s terms. But the newer suits against Ford

Motor Company2 and U.S. Foods3 show where plaintiffs are likely to push next, and where plan sponsors and their advisors/ consultants should focus their review.

First, plaintiffs are focusing on plan-document language, arguing (as in the U.S. Foods suit) that forfeitures were required to offset plan expenses before reducing employer contributions, and treating later retroactive amendments as evidence of prior noncompliance.

Second, they are using forfeiture claims as an entry point for broader fiduciary challenges, as in the Ford complaint, which also attacks managed account fees, alleged indirect compensation, disclosure practices, and document production.

Third, even where plan sponsors have strong defenses under the plan document and IRS guidance, plaintiffs are likely to press for evidence of a real fiduciary process. The practical takeaway is that plan sponsors should be prepared to show that their forfeiture practices are clearly authorized, consistently administered, and reviewed through an ERISA fiduciary lens.45

CIT Selection Challenged

Noting that this case “demonstrates definitively what plan sponsors have observed from 401(k) litigation for decades: they will be a target for strike suits no matter what decisions they make,” the U.S. Chamber of Commerce has weighed in on a case challenging the use of a collective investment trust (CIT).6

The suit was filed earlier this year and while it targeted — as numerous other suits have — the use of plan forfeitures, not to mention allegedly excessive recordkeeping fees, it also pursued the decision to invest in what it termed “structurally opaque” CIT target-date fund (TDF) series by the $1.03 billion Lithia Motors, Inc. 401(k) Plan.7

“ERISA plaintiffs have spent more than a decade challenging fiduciaries for offering mutual funds instead of collective

investment trusts (CITs) that employ the same investment approach, claiming that the inclusion of mutual funds in a 401(k) plan lineup was a clear sign that fiduciaries were asleep at the wheel and failing in their obligation to ensure costconscious plan management,” the brief begins.

“Plaintiff here takes the exact opposite approach, claiming that the decision to offer CITs rather than mutual funds that employ the same investment approach is categorically indicative of imprudence.”

“If Plaintiff’s theory were the rule, then every fiduciary of a plan investing in CITs could be expected to be hauled into court — simply for making the extraordinarily popular decision to offer this low-cost method of investing to plan participants that ERISA plaintiffs’ lawyers have for

years posited is the only prudent option. That is not how the statute works.”8

Participant ‘Enter’ Actions?

The defendants in a massive participant data usage suit have asked the court to dismiss the case, arguing that as a recordkeeper they weren’t fiduciaries, that investment decisions made after a rollover aren’t governed by ERISA, and that a single transaction doesn’t constitute advice.9

The suit, filed in August 2025, argued that Empower used data it possessed as recordkeeper to target rollover candidates that its advisory unit encouraged to move to its managed account product.10

The suit further alleged that the additional fees, limited personal customization and incentives to promote that offering were

not disclosed. Moreover, it took issue with the plan sponsors as not monitoring or supervising these activities, though they aren’t parties to the suit.

The arguments echo those in a similar case also filed by the law firm of Schlichter Bogard LLC almost a year prior involving TIAA and multiple university plans using its managed account services (provided by Morningstar), which is still active.11

In their new motion, the Empower defendants first argue that their participant interactions did not constitute investment advice for a fee — essentially that it failed to meet the “regular basis” test from the so-called five-part test — “and that failure alone defeats Plaintiffs’ theory that Empower acted as an ERISA fiduciary by providing investment advice.”

The motion also pushed back on an attempt to link “multiple ongoing interactions” as advice, rather than “education or other routine interactions.”

Even so, “multiple unspecified ‘interactions’ leading up to a single rollover transaction do not constitute advice provided ‘on a regular basis.’ Both ERISA itself and the DOL regulatory test require an ongoing advisory relationship with respect to plan assets — not a series of unspecified pre-transaction ‘interactions’ culminating in a one-time rollover …because Plaintiffs do not plausibly allege fiduciary status under any theory, Counts I and II should be dismissed. And because fiduciary status is also a prerequisite to co-fiduciary liability, Plaintiffs’ co-fiduciary allegations fail as well,” the motion concludes. It also asserts that, as a non-fiduciary, Empower cannot be “charged solely with participating in a fiduciary breach.”

The plaintiffs will have the opportunity to brief their response before the court makes its decision on the motion to dismiss, which will decide if this case will proceed.

‘Massive’ Underperformance

Volatile markets have predictably produced another wave of suits alleging fiduciary breaches tied to allegedly underperforming investments.

But while plaintiffs continue to challenge investment lineups based on hindsight comparisons and disappointing returns, courts remain focused on a more fundamental question: whether fiduciaries employed a prudent decision-making process.12

Several recent cases underscore that simply alleging underperformance is not enough.

One suit against the fiduciaries of the Aon retirement plan alleged “massive underperformance” relative to supposedly comparable investment options and claimed that the breadth of that underperformance itself suggested a flawed monitoring process.

Yet notably, the complaint itself acknowledged that many of the facts necessary to support those allegations were “known only to Defendants or are exclusively within their control” — effectively conceding that the actual fiduciary process had not yet been identified.

A similar theory appeared in litigation involving the nearly $9 billion American Express plan, where plaintiffs challenged a custom TDF suite that allegedly compounded participant losses by investing heavily in other underperforming funds already included in the plan lineup.13

The suit further alleged conflicts of interest tied to relationships with Morgan Stanley Investment Management and claimed those relationships influenced investment selection and retention decisions.

Meanwhile, courts continue to emphasize that ERISA’s prudence standard is “process-oriented, not results-oriented.”

In dismissing excessive fee and underperformance claims involving the Sonic Automotive 401(k) Plan, a federal judge

reiterated that courts are not tasked with second-guessing investment outcomes but rather evaluating whether fiduciaries engaged in a reasoned decisionmaking process.14

That distinction proved critical.

The court rejected comparisons between actively managed funds and passive indices as “apples to oranges,” concluding that without a “meaningful benchmark,” allegations of underperformance alone could not plausibly establish imprudence. As the court succinctly observed: “Prudence does not mean clairvoyance.”

The same theme emerged in litigation involving the $2 billion Equitable 401(k) plan, where plaintiffs challenged the retention of certain guaranteed investment contracts and alleged excessive indirect compensation tied to recordkeeping arrangements.15

There too, the court concluded that the complaint relied primarily on hindsight critiques of investment performance rather than concrete allegations regarding fiduciary methodology or procedural deficiencies.

Taken together, these decisions reflect a continuing judicial reluctance to allow ERISA claims to proceed based solely on poor outcomes, fee comparisons, or retrospective disagreements with fiduciary judgments.

Increasingly, courts appear to be demanding specific allegations showing not merely that investments underperformed, but that fiduciaries failed to engage in a prudent and welldocumented process in selecting and monitoring those investments.

Healthcare ‘Fare’

We’ve previously covered a handful of healthcare fiduciary suits – a reminder that ERISA also applies to healthcare, and that the same fiduciary responsibilities with regard to reasonable fees and oversight apply.

These healthcare fiduciary suits have struggled to get past the

motion-to-dismiss stage — largely on grounds that the plaintiffs lacked standing — an injury that could be redressed via litigation. However, a federal judge recently shrugged off arguments that had been successful in dismissing other suits.

“The question is not whether the plaintiffs received the healthcare benefits they were promised. The question is instead whether, in receiving those benefits, they paid too much. Alleging that they paid more for the benefits than they should have is an injury sufficient to confer standing, according to Judge Jeremy C. Daniel.16

The plaintiffs in this case (current and former employees of defendant Northwestern University) filed a putative class action suit on behalf of the Northwestern University Employee Welfare Plan, alleging that Northwestern failed to (i) prudently select and monitor the Plan’s preferred provider

organization (PPO) insurance options, and (ii) disclose this material information to participants, causing injury in the form of loss from overpayment under the Plan.

In recognizing that participants can establish standing based on allegations of overpaying for benefits — rather than needing to show denied coverage or mismanaged assets- the court distinguished prior precedent and, in the process, lowered a key procedural hurdle. Just as importantly, the judge declined to resolve whether Northwestern acted in a settlor or fiduciary capacity at this stage, emphasizing that decisions around plan design, selection, and monitoring may carry fiduciary obligations – but subject to later factual scrutiny.

The ruling underscores growing judicial openness to claims that plan sponsors must not only offer benefits but do so prudently and transparently — particularly regarding cost-value

tradeoffs — raising the stakes for employers in how they structure, evaluate, and communicate healthcare plan options.

VBO ‘Row’

You may recall that just ahead of the 2025 holiday season, Schlichter Bogard LLC filed four suits alleging fiduciary breaches regarding voluntary benefit programs.17

Well, they’ve now filed a fifth, and they’re not the first firm to do so. In the most recent suit, they’re representing plaintiffs in a suit against defendants Banner Health, Lockton Companies, LLC, BCInsourcing, LLC, and John Does 1–20 “for breaches of fiduciary duties and other violations” of ERISA.18

More specifically, the suit alleged that the plan fiduciaries “violated their duties with respect to the management and administration of accident, critical illness, and hospital indemnity insurance programs (‘Voluntary

Benefits Insurance’) offered as a plan governed by ERISA” — a suit that, as the ones filed last December alleged, involves not only the employer, but the benefits consultant and third party administrator (TPA).

In April, a suit bringing similar claims against Banner was filed by the Seattle-based law firm Keller Rohrback LLP — no stranger to ERISA litigation.19

Standing ‘Put’

A federal judge saw the exchange of a pension commitment for an arguably less secure annuity as sufficient to allege injury, but the suit still failed to get past the motion to dismiss.

In this case, the defendants entered into an agreement to transfer $1.5 billion of Weyerhaeuser’s pension obligations to either Athene Annuity and Life Co. or Athene Annuity & Life Assurance Company of New York (collectively, “Athene”), which the suit described as “a highly risky private equity-controlled insurance company with a complex and opaque structure.”

Acknowledging that here “the question is a close one”, Judge Kymberly K. Evanson ruled that the Plaintiffs had adequately pleaded standing because as a result of Defendants’ actions, they received a less safe — and, thus, less valuable — annuity than they would have received had Defendants complied with their duties under ERISA – a “concrete” injury sufficient to “invoke the Court’s jurisdiction.”

However, she agreed with the Weyerhaeuser defendants that, as the plaintiffs’ allegations concerning Athene’s financial condition “almost entirely postdate the transaction at issue and thus have little bearing on whether Defendants complied with their fiduciary duties in

selecting Athene,” she granted their motion to dismiss the suit, though she gave the plaintiffs an opportunity to amend their suit –and try again.

Action Items for Plan Sponsors

• Revisit and document fiduciary processes — not just outcomes. Recent rulings continue to emphasize that ERISA prudence claims turn on process, not investment performance alone. Fiduciaries should ensure committee minutes, investment reviews, benchmarking analyses, and monitoring procedures demonstrate a thoughtful and consistent decision-making framework.

• Review plan provisions and administrative practices. Given the continuing wave of forfeiture litigation, plan sponsors should confirm that plan documents clearly authorize current forfeiture allocation practices and that administration aligns with those provisions. Even where courts have dismissed these suits, the litigation itself highlights the importance of operational consistency and clear documentation.

• Evaluate oversight of service providers and participant interactions.

Litigation involving managed accounts, rollover recommendations, voluntary benefits, and participant data usage underscores the need for closer oversight of recordkeepers, consultants, TPAs, and advisory providers. Sponsors should understand how participant data is being used, what disclosures are provided, and whether compensation arrangements create potential conflicts.

• Stress-test benchmarking and investment comparisons. Courts continue to reject claims based on weak or inapt comparisons, particularly “apples-to-oranges” benchmarking between active and passive strategies. Fiduciaries should periodically review how investments are benchmarked, how peer groups are selected, and whether IPS standards remain sufficiently specific and defensible. While addressing these action items, continue to monitor the DOL’s proposed regulation to determine its impact on these evolving action items. NNTM

FOOTNOTES

[1] Shulak v. BMO Financial Corp., No. 2:24-cv-09615 (N.D. Ill. Mar. 31, 2026); Gaetano v. MVHS Inc., No. 6:25-cv-00118 (N.D.N.Y. Mar. 31, 2026); Polanco v. WPP Group USA Inc., No. 1:24-cv-09548 (S.D.N.Y. Apr. 28, 2026).

[2] Complaint, Fuller v. Ford Motor Co., No. 2:26-cv-11541 (E.D. Mich. May 8, 2026).

[3] Bradford et al. v. US Foods, Inc., No. 1:26-cv-04758 (N.D. Ill. May 28, 2026).

[6] Brief of the U.S. Chamber of Commerce as Amicus Curiae in Support of Defendants, Ventura v. Lithia Motors, Inc. (C.D. Cal. 2026).

[7] Complaint, Ventura v. Lithia Motors, Inc. (C.D. Cal. Feb. 20, 2026).

[8] Complaint, Ventura v. Lithia Motors, Inc. (C.D. Cal. Feb. 20, 2026).

[10] Complaint, Williams-Linzey v. Empower Advisory Group, LLC, No. 3:25-cv-14660 (D.N.J. Aug. 15, 2025).

[11] Complaint, Kelley v. Teachers Insurance and Annuity Association of America, No. 24-5945 (S.D.N.Y. Aug. 5, 2024).

[12] Complaint, Clayton v. Aon Corp., No. 1:26-cv-06026 (N.D. Ill. May 22, 2026).

[13] Complaint, Rivetti v. American Express Co., No. 1:26-cv-04082 (S.D.N.Y. May 15, 2026).

[14] Nolan v. Sonic Automotive, Inc., No. 3:25-cv-00474 (W.D.N.C. May 1, 2026).

[15] Tedford v. Equitable Financial Life Insurance Co., No. 25-cv-2180 (D.N.J. May 19, 2026).

[16] Barbich v. Northwestern University, No. 25-cv-6849 (N.D. Ill. Apr. 3, 2026) (denying motion to dismiss).

[17] Nevin E. Adams, “Schlichter Bogard Unleashes a New ERISA Suit Genre,” NAPA-Net, December 23, 2025, https://www.napa-net.org/news/2025/12/schlichter-bogard-unleashes-a-new-erisa-suit-genre/.

[18] Complaint, Haller v. Banner Health, No. 2:26-cv-03114 (D. Ariz. May 5, 2026).

[19] Complaint, Hannum v. Banner Health, No. 2:26-cv-02944 (D. Ariz. Apr. 28, 2026).

[20] Maneman v. Weyerhaeuser Co., No. 2:24-cv-02050 (W.D. Wash. Mar. 31, 2026) (dismissed without prejudice).

www.napa-net.org/education/credentials/krs

Guaranteed Retirement Income in 401(k) Plans: The White House and DOL Speak

The proposal’s discussion of the considerations for guaranteed lifetime income products is, by and large, consistent with existing fiduciary principles.

By Fred Reish

At last! It seems that guaranteed lifetime income products are on their way into 401(k) and private-sector 403(b) retirement plans.

The president prioritized their inclusion in those plans, and the DOL has issued both sub-regulatory guidance and a proposed regulation.

To top that off, two of the investment managers with the most assets in target-date funds have announced they will offer TDFs with guaranteed lifetime income.

Recent History

We’ll start with SECURE Act 1.0.  That law expressed Congressional concern about retirees needing a lifelong income and Congressional intent to facilitate plans in providing that income.

In a strong statement of public policy, the Act created a fiduciary safe harbor for selecting insurance companies to underwrite the guarantee. The provision is a complete and simple check-thebox safe harbor.

On August 7, 2025, the White House issued an Executive

Order (EO) titled “Democratizing Access to Alternative Assets for 401(k) Investors.”  One of the six categories of alternative assets was “lifetime income investment strategies.”

The DOL explained in the preamble to its proposed regulation: “Lifetime income investment strategies are designed to provide individuals with a predictable stream of income for their lives and have sometimes been referred to as a form of monthly paycheck during retirement. A typical example of a lifetime income solution is an annuity.”

The Executive Order directed the Department of Labor (DOL) to provide both guidance on selecting alternative assets and a fiduciary safe harbor for such selection.

Shortly after the Order was issued, and in response to the EO, the DOL issued Advisory Opinion (AO) 2025-04A, which concluded that:

(i) guaranteed income products could be included in Qualified Default Investment Alternatives (QDIAs),

(ii) investment managers could be the fiduciaries for the selection of the products, and

(iii) the existing fiduciary safe harbors were available to investment managers.

The significance was that the arrangement would reduce the fiduciary burden on plan sponsors when selecting the types of products (e.g., annuities or guaranteed lifetime withdrawal benefits, GLWBs) and when selecting the particular product within a type).

Of course, the primary plan fiduciaries would need to vet the investment manager prudently.

The fourth step in this timeline was the DOL’s issuance of a proposed regulation on March 31, 2026.  The preamble explains that the proposed rule covers all investments offered by participant-directed plans, including the alternative assets listed in the EO.

The Proposal’s Provisions

The proposed rule identifies six factors to consider when selecting plan investments or designated investment alternatives (DIAs; for our purposes, that includes insurance products).

The proposal then discusses the six nonexclusive “factors” and provides 20 examples, some of which include guaranteed lifetime income products.

The two factors with examples

that address guaranteed lifetime income are Fees and Liquidity.

The other factors — Performance, Valuation, Complexity, and Performance Benchmarks — would also apply unless, in a given case, they are not an appropriate consideration for a particular type of product.

In the discussion of the Fee factor, the proposal gives this example:

Fees

(3) Example. Fees; Lifetime income—

(i) Facts. A plan sponsor makes a plan design decision to add a lifetime income benefit to its existing participant-directed individual account plan. The named fiduciary of the plan selects an asset allocation fund offered through a variable annuity contract to implement the plan sponsor’s decision.

The new designated investment alternative is similar in all material respects — risk, return, liquidity, and allocation profile — to another designated investment alternative already on the plan investment menu, except that the alternative on the plan investment menu does not offer lifetime income through a variable annuity contract.

The two designated investment alternatives have the same expense ratio. Still, the designated investment alternative offered through the variable annuity contract includes an additional fee for participants’ ability to select the lifetime income feature.

The additional fee typically secures more favorable annuity conversion rates throughout the life of the contract than would be available outside of the contract. The named fiduciary consults with an investment advice fiduciary within the meaning of section 3(21)(A)(ii) of ERISA.

The investment advice fiduciary analyzes the annuity market generally, as well as the break-even ages and

additional fee of the designated investment alternative, which analysis the named fiduciary critically evaluates and adopts in determining, within its discretion, that the designated investment alternative with the lifetime income benefit provides commensurate value for the fees charged.

Comment: A realistic example of this scenario would be one in which there are two versions of a target-date fund series.

One version would include a guarantee, and the other would not.  The only cost difference would be the added cost for the guarantee.

(ii) Analysis. The named fiduciary must act prudently when implementing the plan sponsor’s decision to add a lifetime income benefit to the plan.

Although the named fiduciary must appropriately consider a reasonable number of similar alternatives, the designated investment alternative already on the plan investment menu satisfies this standard because it is both sufficiently different from the designated investment alternative being added to the plan investment menu due to its lifetime income benefit feature and sufficiently comparable because it is identical in each other material respect.

The lifetime income feature has added value to the plan and therefore justifies higher total fees than the designated investment alternative without this feature.

Comment: Honestly, I am not quite sure what to make of the analysis. Obviously, the fiduciaries had already determined that the TDF suite was appropriate for their participants without the guarantee.

They determined that the guarantee and its cost were appropriate/prudent. The analysis may be that or may be saying something else, but if so, I can’t tell what.

Regardless, the fiduciaries would have the SECURE 1.0 fiduciary safe harbor for selecting the insurer; however, they would need to determine that the particular contract — its features and costs — was prudent. Alternatively, the fiduciaries could engage a 3(38)-investment manager to conduct that analysis and make the decisions.

(iii) Conclusion. The named fiduciary in this example did not act imprudently by adding the new designated investment alternative to the plan investment menu solely because it has higher fees than the similar designated investment alternative without the lifetime income benefit feature that is already on the plan investment menu.

To satisfy the consideration and determination requirements under paragraph (h) of this section and section 404(a)(1)(B) of ERISA, the named fiduciary considered and determined that the additional fee under the variable annuity contract is appropriate in relation to the value it brings to furthering the purposes of the plan.

Comment: No surprises here.  However, it would have been helpful if the DOL had added a brief discussion of evaluating the needs and circumstances of the covered participants as part of assessing whether the guarantee added value to the plan equivalent to its cost.

Liquidity

The DOL’s example in its discussion of the Liquidity Factor is:

(2) Example. Participant level liquidity; lifetime income—

(i) Facts. The investment policy statement of a participant-directed individual account plan calls for lifetime income options on the plan investment menu. The named fiduciary selects several designated investment alternatives with such features, including a deferred annuity contract.

Allocations to this contract, which are made on a monthly

basis, grow at a rate specified under the contract, and monthly payments for life begin when the participant reaches age 65. Allocations to this contract become fully committed after 90 days, and any immediate withdrawals by a participant before age 65 result in a penalty and a market value adjustment to the value of the annuity that begins at age 65.

The restrictions on liquidity throughout the growth period enable greater monthly payments at age 65.

I’m unclear why several DIAs with guarantees were selected, unless it refers to vintages of a target-date fund series.

Regardless, the example describes the liquidity issue — penalties and MVAs — and the potentially offsetting benefit — greater monthly benefits.  Those are the facts that the fiduciaries must understand and evaluate.

(ii) Analysis. Paragraph (i) of this section clarifies that plan fiduciaries must appropriately consider the potential participantlevel events that may trigger a plan’s need for immediate liquidity, and must determine that the designated investment alternative, at the time of selection, will have sufficient liquidity to meet the anticipated liquidity needs of the plan.

When assessing the liquidity needs of the plan, the plan fiduciary in this example must balance the restrictions on liquidity under the annuity contract with the value of the guaranteed monthly payments under the annuity contract, recognizing that such guarantees help plan participants manage investment and longevity risk.

The fact that a designated investment alternative is fully allocated to an illiquid product, like an annuity, does not foreclose its selection, including, for example, where the fiduciary determines within its discretion that the lack of liquidity is justified by a commensurate expected

increase in return on investment, certainty with respect to future payments, or both.

Comment: This describes the process that “the plan fiduciary… must balance”.  Then it makes the key point that illiquidity alone does not disqualify an investment; instead, the consequences of illiquidity should be balanced against the benefits to the product’s participants.

If fiduciaries obtain and carefully evaluate relevant information, including participants’ needs and circumstances, the detrimental effects of illiquidity can be mitigated.

(iii) Conclusion. In this example, the named fiduciary would satisfy the consideration and determination requirements of paragraph (i) of this section, and section 404(a)(1)(B) of ERISA, with respect to the designated investment alternative in question if the named fiduciary concluded that the increase in the value of the monthly payments and the certainty of the insurer’s guarantee under the annuity contract justified the restrictions on liquidity.

Comment: Again, no surprises here. In my view, this is consistent with the fiduciary principles in ERISA…the value to participants of a product or service can justify factors such as illiquidity and cost, so long as properly assessed.

Conclusion

The proposal’s discussion of the considerations for guaranteed lifetime income products is, by and large, consistent with existing fiduciary principles (other than, perhaps, the safe harbor).

The examples are consistent with the prudence standard under ERISA and, in that sense, are not new information. However, they will likely provide clarity and comfort to plan sponsors as they consider guaranteed lifetime income products for their participants. NNTM

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When Retirement Becomes Presidential

By Josh Oppenheimer

The Oval Office. The room where presidents address the nation during moments of crisis, announce defining decisions, and shape their legacy. It is where President Kennedy spoke during the Cuban Missile Crisis, where President Nixon announced his resignation, and where President George W. Bush addressed the nation in the aftermath of the September 11 attacks.

Which is why President Trump’s decision to announce TrumpIRA.gov from behind the Resolute Desk was so striking. Designed to expand access to retirement savings for American workers, the April 30th executive order directs the Treasury Department to launch an online marketplace that connects vetted private-sector IRAs with workers who lack access to workplace retirement plans. Whatever one thinks about the policy itself, one thing is

undeniable: retirement policy has rarely, if ever, received this level of presidential attention.

For decades, retirement policy has largely lived outside the political spotlight. Even major bipartisan achievements like the SECURE Act of 2019 and SECURE 2.0 in 2022 were developed primarily through years of stafflevel committee negotiations before ultimately becoming part of larger legislative packages. This moment feels different.

If retirement policy is truly becoming a presidential-level issue, then the stakes surrounding SECURE 3.0 have increased dramatically. Decisions made over the next year could shape the employer-sponsored retirement system for decades to come.

By elevating retirement coverage to an Oval Office priority — and directing the Treasury to develop additional legislative recommendations — the Trump Administration is signaling that expanding access to retirement benefits is no longer simply a technical tax issue. It is becoming a major domestic policy objective.

That is a significant development for everyone involved in the employersponsored retirement system.

So, what does this mean for SECURE 3.0?

Ironically, in an era of extraordinary political division, retirement policy remains one of the few areas where bipartisan cooperation is still possible.

The original SECURE Act was passed during President Trump’s first term with broad bipartisan support. SECURE 2.0 followed during the Biden Administration through collaboration among Republicans and Democrats across multiple congressional committees.

At ARA, we have already been helping lay the groundwork for the next phase of retirement reform. We have worked with lawmakers on both sides of the aisle to develop proposals to improve the system, including the Retirement Rollover Flexibility Act, which would allow Roth IRA assets to roll over into employer-sponsored plans, and the OPTIONS Act, which would give workers greater flexibility in how employer contributions are allocated. These are important reforms. But targeted improvements alone are unlikely to become the

central organizing force behind a broader SECURE 3.0 package.

Historically, comprehensive retirement legislation emerged when a broader policy objective has brought both parties to the negotiating table.

The expansion of retirement coverage may now become that objective.

Democrats have long prioritized closing the retirement coverage gap, particularly among small businesses, parttime workers, and lower-income employees. Republicans, meanwhile, increasingly view retirement savings through a populist lens centered on ownership, financial independence, and economic mobility.

Those political motivations may finally be converging, creating both opportunity and risk.

ARA strongly supports efforts to expand access to retirement plans. But any proposal must build upon the success of the existing employer-sponsored system rather than replace or undermine it. The current system works because employers, advisors, recordkeepers, consultants, TPAs, and financial professionals collaborate to help millions of Americans save successfully for retirement.

As discussions evolve, there will undoubtedly be competing visions for addressing coverage gaps. Some proposals may complement the existing system. Others may move toward greater federalization or create unnecessary disruption. There are also increasingly well-funded outside interests entering the

retirement policy arena, each advancing its own preferred vision for the future of retirement savings.

That is why ARA’s advocacy — and the engagement of our members — will be more important than ever.

If retirement policy is truly becoming a presidentiallevel issue, then the stakes surrounding SECURE 3.0 have increased dramatically. Decisions made over the next year could shape the employer-sponsored retirement system for decades to come.

ARA will remain vigilant and engaged throughout this process. We will continue working with lawmakers and regulators from both parties to ensure that any future retirement legislation expands coverage while preserving the strengths of the existing system.

But we cannot do it alone.

As SECURE 3.0 conversations accelerate, policymakers need to hear directly from the professionals who help Americans save for retirement every single day. The future of the employer-sponsored retirement system will not be shaped solely in committee rooms or Oval Office announcements, but by the continued expertise, advocacy, and engagement of ARA members across the country.

You have both an unprecedented opportunity and an important responsibility to help shape the next generation of retirement security and to ensure a secure and comfortable retirement for all working Americans. NNTM

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