Blog

By Mark Olsen, Managing Director at PlanPILOT

Ask a plan committee member what they did at the last investment review meeting, and you’ll likely hear some version of the same story: they pored over performance reports, debated a handful of funds, and walked away feeling like the lineup is solid. It’s a familiar ritual, but also may be the wrong conversation.

In our experience, the size and complexity of a retirement plan’s investment menu is one of the most underexamined levers in plan design. Plan sponsors who build menus around fund ratings and committee preferences often end up with options that are technically defensible but practically confusing. When participants are confused, they disengage. That’s a problem no fund rating can fix.

The better question isn’t whether the funds are good; it’s whether the menu itself is designed to help people make good decisions. That should be the focus of the plan committee.

More Options Don’t Mean Better Outcomes

There’s a persistent belief in retirement plan management that more choice signals more value. If the committee can offer a broad fund lineup (e.g., domestic equity, international equity, sector funds, alternative strategies), it looks thorough, complete and diversified. Sophisticated, even.

Research tells a different story. Studies on decision-making consistently show that when people face too many options, they don’t choose more carefully. They freeze up, defer, or default. In a retirement plan context, that often means sticking with a poorly suited default allocation, failing to rebalance, or avoiding enrollment altogether.

This phenomenon is sometimes called “choice overload,” and it has real consequences for participants. A 401(k) participant who can’t quickly identify which funds belong in their portfolio is less likely to engage meaningfully with the plan. As a result, lower engagement tends to translate into lower savings rates and worse retirement outcomes.

What “Streamlined” Actually Means

Simplifying an investment menu doesn’t mean stripping out useful options. It means organizing the menu with participant behavior in mind—building a clear hierarchy that guides decision-making without requiring expertise.

A well-structured menu typically works in tiers:

1. First, have a qualified default investment alternative (QDIA). This is usually a target-date fund series that serves participants who want a hands-off, age-appropriate option.
2. Then a core tier of broad, low-cost index funds covering major asset classes: domestic equity, international equity, and fixed income.
3. Finally, a supplemental tier for participants who want more specialized options: active strategies, real assets, lifetime income, or additional diversification options.

This kind of structure doesn’t limit participants; it orients them. Someone with no investment background can find a reasonable path without feeling lost. Others who want to customize have the tools to do so. Both groups are better served than they would be by a flat list of 30 funds with no clear organizing logic.

The Fiduciary Case for Simplicity

Beyond participant outcomes, there’s a clear governance incentive to menu design that plan sponsors sometimes overlook. A streamlined, well-documented lineup is easier to monitor, easier to explain, and a more effective defense.

When a committee can articulate why each fund is on the menu, what role it plays, how it fits the structure, and what criteria would trigger its removal, the committee is demonstrating procedural prudence. That’s a plan that can withstand a Department of Labor audit or a participant complaint without scrambling to reconstruct the reasoning.

Contrast that with a plan that has grown organically over years of incremental additions. Stating “It was a good idea at the time” just isn’t going to persuade an auditor. A fund added because a committee member liked its recent performance, another added to appease a vendor, a third retained out of inertia, are not components of a well-designed plan and procedure. 

That kind of menu is hard to justify and harder to manage. The documentation doesn’t reflect intentional design because there wasn’t any.

A defined Investment Policy Statement (IPS) that specifies the purpose and criteria for each tier gives committees a governance framework that holds up over time, not just during the next quarterly review.

How Many Funds Is Too Many?

There’s no universal right answer, but the federal Thrift Savings Plan (one of the largest defined contribution plans in the country) offers a useful reference point on the low end. It operates with a small number of broad index funds and a lifecycle fund series. Participation is high, internal investments costs are low and the choices are limited but effective.

For most institutional plans, a menu of 15 to 20 options (tops) is generally sufficient to meet the needs of a diverse workforce. Beyond that, additional funds tend to create complexity without adding meaningful diversification. The marginal participant benefit is low, the governance burden is not. Think of a restaurant menu; the more entree choices, the longer it takes a dining customer to decide what to order.

One area that deserves more attention is fixed income (bonds). Many plans emphasize equity diversification while leaving the fixed income side underdeveloped. Often, we see one broad-based bond market index fund and perhaps one other fund or nothing else. 

Participants who are closer to retirement or simply more conservative in their investing approach need adequate fixed income options to suit their own objectives. At minimum, a stable value or money market fund, an intermediate-term bond fund, and an international bond option along with a total bond market fund would cover most situations.

Starting the Redesign Conversation

For committees that want to revisit their menu structure, the first step is to separate the structural question from the fund-selection question. Before asking which funds to include, ask what the menu is supposed to do, who it’s serving, what decisions it needs to support, and how clearly it communicates those options to someone without a financial background.

From there, the conversation shifts to whether the current menu answers those questions, and where it falls short. That’s a more productive review than debating whether a given fund outperformed its benchmark last year.

At PlanPILOT, we work with plan sponsors to evaluate not just fund performance but the overall architecture of the investment menu. The goal is a lineup that works for participants as they actually are (not as we wish they were), and that holds up to the scrutiny that comes with fiduciary responsibility.

Is Your Investment Menu Working for Your Participants?

We’re creating the standard for client experience. Independent and impartial by design, we apply our skill to each facet of plan development, governance, and implementation to help you enjoy meaningful results. Our client partnerships are built on trust, communication, and responsibility—cornerstones of a healthy, prosperous relationship. We’re committed to providing objective guidance, informed innovation, and an integrated approach tailored to your unique objectives.

PlanPILOT’s team of seasoned professionals upholds the highest professional standards, so every strategy we recommend aims to support both your organization and the participants who depend on it.

To learn more about how we can help with fiduciary oversight and improving the effectiveness of your benefits program, reach out to us at (312) 973-4913 or send an email to mark.olsen@PlanPILOT.com to learn more about how we can customize our services and your plan to fit your unique needs.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, and CUPA-HR.

By Mark Olsen, Managing Director at PlanPILOT

When it comes to selecting the investments for the retirement plan, many plan sponsors and/or the benefits committee focus far too heavily on selecting “the best funds.” In reality, there is far more to an effective lineup than whether this fund or that has a “five star” or “five moon” rating.

In fact, the structure, not the ratings, of the investment lineup has a far greater impact on participant outcomes as well as fiduciary risk. A well-structured line-up can help improve decision-making, reduce participant confusion (and thereafter reluctance to enroll), as well as strengthen fiduciary defensibility—even if the underlying fund selections are simplified and perhaps similar in some ways to each other.

At PlanPILOT, one of our core strengths as a retirement plan consultant is our ability to look “under the hood” of participant plans and work with our clients to not only improve what is measurable, but also what is ultimately meaningful in achieving excellence with a benefits program. Let’s look at the issue of investment selection in a retirement plan and how to strengthen the structure of the lineup and to maximize results.

Framing the Problem

For many plan committees, the semi-annual or quarterly investment review is a hunt for the “best funds.” Hours are spent scrutinizing performance spreadsheets, chasing top-quartile performers, and replacing funds that underperformed their benchmark last year.

Plan sponsors often feel immense pressure to pick “winners,” yet the investment industry is cyclical; today’s top-performing fund is often tomorrow’s median or underperforming fund, a concept known as “reversion to the mean.” Selecting funds based on recent performance, or who’s the “hot manager,” is not a good foundation to promote participant success in saving and investing for their future.

The problem, therefore, lies not in whether good investments are selected, but in the question asked. Instead of: “Are we offering the best funds?” the question and objective ought to be:

“Is our investment lineup designed for how participants actually make decisions?”

How those decisions will be made can result in better outcomes, both in encouraging participation in the plan and in participants having the confidence to contribute in order to reach their own retirement goals. In other words, how the plan and its investment menu is designed and structured will ultimately shape the behavior of the participants. This is an often overlooked concept in plan design.

Where Plan Sponsors Go Wrong

Here are areas where plan sponsors and the committees often go astray:

• Overloaded menus: When committees focus on offering many “great” funds, they often create a menu with too many options. Studies have shown that employees overwhelmed by too many choices often freeze, fail to enroll, or default to improper allocations.
• Lack of clear hierarchy or tiers: A lack of a clear hierarchy or tiered structure (core vs. supplemental vs. specialized) in investment menus is a significant problem that causes employee confusion, “analysis paralysis,” and potentially lower investment returns for the participant. 

Without tiers, participants may struggle to identify foundational funds (like core funds or target-date funds) versus specialized options, leading them to either avoid the plan entirely or build sub-optimal portfolios 

• Misalignment between:

• • • QDIA (The default target retirement date fund)

• Core menu (The core index funds of U.S. equity, international and bonds)

• • • Supplemental/active funds (For further diversification or outperformance)
    • Brokerage window (If offered, for other investments not in the core menu)
  • Treating lineup changes as incremental fund swaps, rather than strategic redesign: This is the result of continually trying to find “a better fund.”

• Failure to revisit structure as plan demographics evolve: As your workforce changes, so must your plan design. Older workers may require different plan features than a younger, more tech-savvy participant base.

Why Structure Matters

The investment menu structure( the framework that dictates which asset classes are available and how they are presented) has a more direct impact on participant outcomes.

1. Participant Behavior

• Participants don’t optimize, they simplify: it’s nearly a certain human trait to avoid making a mistake.
• Poor structure leads to:
  • Decision paralysis
  • Over-diversification or concentration
• A thoughtful structure nudges better outcomes without requiring expertise.

2. Fiduciary Oversight

• A coherent structure demonstrates the plan sponsor’s procedural prudence.
• Easier to justify decisions in:
  • Committee documentation
  • DOL audits
• Shows intentional design vs. ad hoc fund accumulation

3. Governance Efficiency

• Streamlined lineup = more effective monitoring
• Reduces noise in:
  • Investment reviews
  • Watchlist decisions
• Allows committees to focus on material issues that occur from time to time

Best-Practice Framework

To build a robust lineup, focus on a “less is more” strategy and a tiered approach, as follows:

• Start with a default QDIA choice: This would be the target-retirement-year (TDF) selections that closely match the participant’s anticipated year of retirement. Such investments automatically rebalance the risk allocation on a time-horizon basis and are considered appropriate for those wishing an all-in-one approach to their retirement investments. 
• Implement a core-and-satellite approach: Implement a strong core (TDFs or index funds) that covers major asset classes. Add “satellite” funds only if they serve a specific, necessary role.
• Simplify the diversification approach: As an example, the federal Thrift Savings Plan (TSP) uses a limited number of high-quality, broad-index funds. This approach is simple, low-cost, and effective.
• Use a defined Investment Policy Statement (IPS): Your committee should adopt an IPS that focuses on the process of monitoring, not just selecting. This ensures that when a fund is removed, it’s due to a failure to meet predefined, qualitative criteria, rather than a subjective emotional reaction to performance.
• Limit options to reduce participant overwhelm: A strong menu rarely needs more than 15-20 options. Reducing excessive choices often improves employee participation and satisfaction.
• Include proper fixed-income options: Confirm the menu offers enough variety for risk-averse employees, such as a stable value or money market fund, an intermediate-term bond fund, and an international bond fund. A frequent complaint among participants is the emphasis on diversifying the equity (stock) menu but the fixed income menu is limited to 2-3 choices.

Build the House First, Then Add the Pictures

For plan sponsors, the duty of prudence is best served by creating a retirement plan structure that helps employees make good decisions. By focusing on a well-designed, simplified investment menu rather than hunting for “hot” funds, committees can better meet their fiduciary obligations, reduce costs, and, ultimately, improve the retirement stability of their employees.

How Do You Reach Excellence in Your Retirement Plan? Talk With Us.

At PlanPILOT, we’re creating the standard for client experience. Independent and impartial by design, we apply our skill to each facet of plan development, governance, and implementation to help you enjoy meaningful results. Our client partnerships are built on trust, communication, and responsibility—cornerstones of a healthy, prosperous relationship. We’re committed to providing objective guidance, informed innovation, and an integrated approach tailored to your unique objectives.

Our team of seasoned professionals upholds the highest professional standards, so every strategy we recommend aims to support both your organization and the participants who depend on it.

To learn more about how we can help with fiduciary oversight and improving the effectiveness of your benefits program, reach out to us at (312) 973-4913 or send an email to mark.olsen@PlanPILOT.com to learn more about how we can customize our services and your plan to fit your unique needs.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, and CUPA-HR.

By Mark Olsen, Managing Director at PlanPILOT

The use of loans within employer-sponsored retirement savings plans (commonly known as 401(k) loans) has transitioned from a rare emergency measure to a frequently used financial tool. Driven by rising cost-of-living pressures and insufficient emergency savings, loan usage has seen a consistent upward trend, surging 20% compared to 2022 levels. While these loans can offer short-term relief to employees, they present significant long-term risks to retirement readiness, often creating a “leakage” effect that erodes retirement stability.

At PlanPILOT, we believe that taking a proactive approach in understanding and mitigating these types of issues can help to maintain a robust and beneficial retirement plan for participants. Let’s take a look at the growing trend of participant reliance on retirement plan loans, how they can hamper retirement readiness, and potential solutions that can help solve this problem.

The Growing Trend: A Symptom of Financial Strain

Recent data highlights a steady increase in 401(k) loan activity. Studies indicate that as of late 2025, nearly 20% of participants had an outstanding loan from their retirement accounts. Average loan balances have also risen, with surveys placing them around $10,778, suggesting that participants are tapping into larger portions of their savings.

This trend is driven by a lack of accessible cash for emergencies. 60% of participants report being uncomfortable with the amount of emergency savings they have, likely making their 401(k) the only other available source of funds. Furthermore, the SECURE 2.0 Act, while promoting savings, has introduced provisions like penalty-free hardship withdrawals and relaxed rules that can inadvertently make it easier for employees to treat their retirement accounts as bank savings accounts.

Long-Term Impact on Retirement Readiness

While 401(k) loans are repaid with interest, that interest is paid back to the participant’s own account, making them seemingly harmless. However, the true damage to retirement readiness stems from two primary factors: lost opportunity cost and default risks.

1. Opportunity cost (lost growth): Money borrowed from a 401(k) is removed from the investment markets. During the loan period, that cash is not growing, meaning it misses out on potential compound investment gains. Given that loans can be outstanding for five years or more, this “lost time” can significantly reduce the final account balance at retirement, requiring higher future contributions to realize the same retirement goals or working longer than expected.
2. Default upon job change: A critical, often overlooked risk is the repayment requirement upon leaving a job. If an employee leaves or loses their job with an outstanding loan balance, they usually have a short window to repay it, or the loan defaults. A defaulted loan is treated as a taxable distribution, subjected to income taxes and, for those under 59½, a 10% early withdrawal penalty. Almost 40% of workers take a loan at some point, and 86% of those who change jobs do so with a loan default on the balance, per a 2019 study.
3. Reduced contributions: Although some research suggests contributions remain relatively stable after taking a loan, a subset of borrowers (roughly 26% in some studies) do decrease their contribution rates to accommodate loan repayments, thus further hindering their accumulation of savings. This points to the notion that participants are living “on the edge” of their income and savings capacity with little cushion for contingencies.

Solutions for Plan Sponsors to Mitigate Risks

Plan sponsors must balance providing flexibility to employees with their fiduciary duty to promote the long-term success of the retirement plan. Here are strategies to mitigate the downsides of 401(k) loans:

• Establish emergency savings accounts (ESAs): Implementing SECURE 2.0 provisions for pension-linked emergency savings accounts allows employees to build a “rainy day” fund alongside their retirement contributions. This may reduce the need to borrow from retirement funds to pay for unexpected expenses.
• Implement loan waiting periods: Introducing a mandatory waiting period for new hires or limiting the number of loans a participant can have outstanding at once (e.g., limiting to one loan) can discourage routine borrowing.
• Encourage continued contributions: Design plans so that participants must continue to make elective contributions during the repayment of a loan. Some plan designs allow for automatic contributions to continue uninterrupted.
• Enhance financial wellness programs: The root cause of most loans is a lack of financial literacy and liquidity. Providing robust financial wellness tools, including education on budgeting, debt management, and the high cost of defaulting on a 401(k) loan, can help employees build resilience before they encounter a crisis.
• Add non-loan financial products: Offering employer-negotiated, low-interest emergency loans through a third party can prevent employees from tapping into their retirement plans.

Plan Sponsors Must Understand the Downside of Participant Loans

401(k) loans are a double-edged sword. While they offer necessary liquidity for employees facing financial hardship, the long-term cost to their retirement readiness is often high. By shifting the focus to holistic financial wellness and providing alternative emergency resources, plan sponsors can help employees bridge the gap between financial stability today and confidence tomorrow, keeping 401(k) plans vehicles for retirement rather than short-term funding sources.

Are Loans a Problem in Your Retirement Plan? Talk With Us.

At PlanPILOT, we’re creating the standard for client experience. Independent and impartial by design, we apply our skill to each facet of plan development, governance, and implementation to help you enjoy meaningful results. Our client partnerships are built on trust, communication, and responsibility—cornerstones of a healthy, prosperous relationship. We’re committed to providing objective guidance, informed innovation, and an integrated approach tailored to your unique objectives.

Our team of seasoned professionals upholds the highest professional standards, so every strategy we recommend aims to support both your organization and the participants who depend on it.

To learn more about how we can help with fiduciary oversight and improving the effectiveness of your benefits program, reach out to us at (312) 973-4913 or send an email to mark.olsen@PlanPILOT.com to learn more about how we can customize our services and your plan to fit your unique needs.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, and CUPA-HR.

By Mark Olsen, Managing Director at PlanPILOT

Many plan sponsors are discovering that traditional benefit programs are no longer resonating with younger employees. Low retirement plan participation, rising turnover, and disengagement can signal a disconnect between what employers offer and what Generation Z actually needs.

As members of Gen Z (born between 1997 and 2012) enter the workforce, they bring different financial pressures, expectations, and digital habits. Many are grappling with student debt, a high cost of living, and a desire for flexibility and meaningful impact, prioritizing financial stability and comprehensive financial wellness from day one of their careers. For plan sponsors, attracting and retaining this emerging talent requires rethinking retirement plans and broader benefits through more personalized, technology-driven engagement that supports both immediate financial needs and long-term goals.

At PlanPILOT, we have long-espoused the necessity of customizing employee benefits to fit the ever-changing demographics of a company’s workforce. The emergence of Gen Z illustrates why this approach is necessary to maintain a productive and supportive environment for employees.

Understand the Gen Z Financial Landscape

Gen Zers are pragmatic and often financially conservative, largely due to watching their parents struggle with financial crises and entering the workforce during economic turbulence. They face significant challenges, including: 

• Student loan debt: Many enter the workforce with substantial debt, hindering their ability to save for retirement or emergencies.
• Cost-of-living pressures: High inflation and housing costs make living paycheck to paycheck a reality for many, with 28% reporting this status.
• Anxiety about the future: A significant number of Gen Zers worry they won’t be able to achieve milestones like homeownership or retire comfortably, with 60% claiming their needs are not being met. Many have been struggling to purchase their first home and have low confidence that Social Security will provide them any meaningful income in retirement.

To support them, plan sponsors must move beyond traditional retirement education to offer holistic financial wellness, including budgeting tools, emergency savings assistance, and debt management resources.

Modernize Retirement Plans: Automation and Flexibility

Gen Z is open to saving for their own retirement, but the program needs to be convenient and relevant to their lifestyle and communication tendencies, including:

• Automated solutions: Implementing automatic enrollment and automatic escalation helps overcome inertia, with past studies showing 88% of Gen Zers who were auto-enrolled started saving earlier, at least 6% of their pay.
• Roth options: Providing a Roth contribution option is crucial, as many young workers are currently in lower tax brackets and prefer tax-free income in retirement.
• Portability: Given their propensity to change jobs, ensuring retirement accounts are easily portable is a key attractor.
• Student loan support: Leveraging SECURE Act 2.0, sponsors can offer matching contributions to a 401(k) based on an employee’s student loan payments, a benefit highly valued by this demographic.

Digital-First Communication

As true digital natives, Gen Z expects communication that works on mobile devices and is as seamless as their daily social media use.

• Gamification: Turn retirement planning into a game, with badges or rewards for reaching milestones like setting up an account or completing financial education modules.
• Bite-sized content: Replace long, jargon-heavy documents with short videos, infographics, and interactive apps that provide instant, personalized insights.
• Peer influence and social media: Leverage social media platforms to deliver tips and highlight testimonials from peers, as 85% of Gen Z value peer-based recommendations.

Holistic Well-being: Beyond the 401(k)

To be effective, employee benefit programs should evolve with generational changes. Traditional benefit programs that your parents knew won’t work here. Gen Z views mental health, physical health, and financial health as interconnected. To engage them, plan sponsors should consider integrating these areas:

• Mental health support: Offering access to teletherapy, mental health apps, and dedicated “mental health days” is essential, as this generation is proactive in seeking support, especially among their peers and like-age professionals who understand their unique challenges and needs.
• Financial literacy: Offer education on basic finance topics like investing basics, budgeting, and building credit. 

Create a Supportive Culture

The support structure extends beyond financial tools to workplace culture.

• Flexibility and work-life balance: Remote/hybrid work and flexible hours are non-negotiable for many, and these arrangements support their overall well-being. Gen Zers are more willing to walk away from employment opportunities that don’t support these lifestyle needs.
• Purpose-driven work: Gen Z wants to work for companies that make a positive impact. Connecting their role to the company’s broader mission and community involvement fosters engagement.
• Mentorship and growth: With 94% of Gen Z employees citing career growth as important, mentorship programs and clear paths for advancement are critical for retention.

What This Means for Plan Sponsors

Supporting Gen Z’s entry into the workforce requires plan sponsors to act as partners in their overall financial journey. By providing personalized, tech-enabled, and flexible benefits—paired with a strong focus on mental health and financial education—employers can not only attract top Gen Z talent but also help them build a stable and prosperous future.

Maintaining a robust and effective employee benefit program is a continuous process, not a one-time event. With regular attention and review of their plan and whether it is meeting the expectations and needs of their workforce, plan sponsors can provide a high-quality benefit program to their employees that will improve morale, increase productivity, and reduce employee attrition. Seeking guidance from an experienced plan consultant can help plan sponsors navigate through these challenges and implement meaningful updates as needed.

Does Your Plan Support the Growing Gen Z Workforce?

At PlanPILOT, we’re creating the standard for client experience. Independent and impartial by design, we apply our skill to each facet of plan development, governance, and implementation to help you enjoy meaningful results. Our client partnerships are built on trust, communication, and responsibility—cornerstones of a healthy, prosperous relationship. We’re committed to providing objective guidance, informed innovation, and an integrated approach tailored to your unique objectives.

Our team of seasoned professionals upholds the highest professional standards, so every strategy we recommend aims to support both your organization and the participants who depend on it.

Reach out to us at (312) 973-4913 or send an email to mark.olsen@PlanPILOT.com to learn more about how we can customize our services and your plan to fit your unique needs.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, and CUPA-HR.

By Mark Olsen, Managing Director at PlanPILOT

Fulfilling fiduciary duties is the cornerstone of responsible retirement plan sponsorship. Under the Employee Retirement Income Security Act (ERISA), plan sponsors are legally obligated to act in the best interests of participants and their beneficiaries. 

Failure to meet these obligations can lead to personal and plan sponsor liability, significant penalties, and costly litigation. With regulatory focus increasing, particularly concerning fee transparency and investment performance, a proactive, documented approach is essential.

At PlanPILOT, we understand the depth of the responsibilities plan sponsors face as well as the complications that can arise due to changing regulations and legislation governing retirement plans. In our view, regular review and upgrades go a long way in maintaining a sound and successful retirement plan.

Here is a practical guide for plan sponsors on raising their standard for fulfilling fiduciary duties in 2026.

Fiduciary Duties Checklist

Plan sponsors must adhere to five core fiduciary principles. These are the core of every quality design of policies and procedures

• Act solely in the interest of participants: The primary purpose must be providing benefits and paying reasonable expenses.
• Prudent person standard: Act with the care, skill, prudence, and diligence of a “prudent expert.”
• Follow plan documents: Operate the plan according to its legal documents, unless they conflict with ERISA.
• Diversify investments: Minimize the risk of large losses.
• Pay reasonable expenses: Confirm fees paid for services are necessary and reasonable. 

Establishing and Running a Fiduciary Committee

Creating a formal committee is a best practice for managing fiduciary responsibility, allowing for collective decision-making and proficiency. 

• Composition: Committees should typically have three to seven members, including representatives from finance, human resources, or leadership.
• Charter: Adopt a formal committee charter defining its purpose, authority, and responsibilities.
• Regular meetings: Meet quarterly, or at least semi-annually, to review investment performance, fees, and administrative tasks.
• Training: Conduct regular training for committee members to understand their duties and stay updated on regulatory changes, such as SECURE 2.0. 

Documentation Best Practices

Because prudence is evaluated by the process rather than just the outcome, documentation is your best defense in an audit. 

• Meeting minutes: Maintain detailed minutes for every meeting. Document what was discussed, data reviewed, decisions made, and the rationale behind them.
• Investment policy statement (IPS): Establish an IPS that outlines investment strategy, objectives, and benchmarks for monitoring performance.
• Service provider selection: Document the process for hiring, evaluating, and monitoring service providers, including RFP processes and fee benchmarking.
• Secure record retention: Keep records of all committee meetings, participant communications, and fee disclosures for at least six years. 

Avoiding Common Fiduciary Pitfalls

Even well-meaning sponsors can fall into traps. Be aware of these common mistakes we often see in retirement plans:

• “Set it and forget it” investments: Failing to review the investment menu regularly, allowing underperforming or high-cost funds to remain
• Failing to benchmark fees: Not comparing plan fees (both direct and indirect/revenue sharing) to industry standards, resulting in overpayment
• Delayed contribution deposits: Failing to deposit employee deferrals on the earliest date they can reasonably be segregated from general assets; this is a high-risk area.
• Inadequate monitoring: Assuming that hiring a third-party administrator (TPA) or advisor removes all responsibility; sponsors must monitor the monitors.
• Ignoring operational defects: Failing to correct errors, such as missing a deadline for non-discrimination testing or ignoring participant complaints

Key 2026 Considerations

Taking steps now to review your plan can go a long way in heading off potential issues later in the year.

• SECURE 2.0 implementation: Verify your plan is updated to comply with SECURE 2.0 provisions, which have introduced new administrative, eligibility, and reporting requirements. Take note of changes from the One Big Beautiful Bill Act (OBBBA) legislation last year, one of which was the tax treatment of catch-up contributions.
• Data security: With the rise of cyber threats, fiduciaries are increasingly responsible for ensuring service providers have robust cybersecurity measures in place to protect participant data.
• Proactive oversight: As the regulatory environment becomes more complex, consider engaging an independent fiduciary professional to help with benchmarking and compliance reviews. 

Summary

Fiduciary duty is a continuous process, not a one-time event. By establishing a dedicated committee, thoroughly documenting decisions, and proactively monitoring fees and performance, plan sponsors can minimize risk and provide a high-quality retirement benefit to their employees. Seeking guidance from an experienced plan consultant can help plan sponsors navigate changes to regulations and requirements and streamline their oversight responsibilities.

How Robust Is Your Plan Oversight?

At PlanPILOT, we’re creating the standard for client experience. Independent and impartial by design, we apply our skill to each facet of plan development, governance, and implementation to help you enjoy meaningful results. Our client partnerships are built on trust, communication, and responsibility—cornerstones of a healthy, prosperous relationship. We’re committed to providing objective guidance, informed innovation, and an integrated approach tailored to your unique objectives.

Our team of seasoned professionals upholds the highest professional standards, so every strategy we recommend aims to support both your organization and the participants who depend on it.

Reach out to us at (312) 973-4913 or send an email to mark.olsen@PlanPILOT.com to learn more about how we can customize our services and your plan to fit your unique needs.

About Mark

Mark Olsen is the managing director at PlanPILOT, an independent retirement plan consulting firm headquartered in Chicago. PlanPILOT delivers comprehensive retirement plan advisory services to 401(k), 403(b), and 457 plan sponsors. His specialties include plan governance, investment searches, investment monitoring, and plan oversight. Mark is recognized as a leader in the industry and speaks at national conferences, including those organized by Pensions & Investments, and CUPA-HR.