How Vendor Relationships Can Create Hidden Fiduciary Risk — Even When Performance Is Strong



The Comfort Trap: Why Familiar Vendors Create Blind Spots

Most plan sponsors trust their long-time vendors. The advisor knows the culture. The broker knows the leadership team. The recordkeeper has “always been fine.”

But familiarity isn’t a fiduciary process — and the longer the relationship, the easier it becomes to overlook risk signals.

Vendor relationships often create:

  • Assumptions about competitiveness

  • Resistance to evaluating alternatives

  • A false sense of safety (“no complaints = no issues”)

These blind spots don’t matter… until they do.



The Legal Standard Doesn’t Care About Loyalty

Under ERISA, courts review:

  • Documentation

  • Impartiality

  • Benchmarking

  • Process

Not whether you “like” your vendor.

A decades-long relationship without competitive review can appear biased — even if your vendor is performing well. Loyalty may make sense operationally, but legally, it creates risk.


Three Areas Where Vendor Relationships Distort Decisions

Even high-performing vendors can unintentionally create fiduciary exposure.
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1. Fee Reasonableness

Long-term vendors rarely renegotiate aggressively.
Without benchmarking, fees may drift above market rates — and courts expect sponsors to know this.

2. Service Scope Creep

Over time, services expand informally:
“Can you help us with this?”
“Can you take on that?”
But informal expansions often lack updated pricing or contracts.

3. Overreliance on Vendor-Provided Data

Vendors naturally present themselves favorably.
But sponsors need independent validation to demonstrate neutral decision-making.

Why Independent Evaluation Restores Fiduciary Neutrality


Culpepper RFP brings objectivity back into the process.

Our evaluations:

  • Eliminate unintentional bias

  • Benchmark fees accurately

  • Provide impartial service comparisons

  • Create documentation that protects you in audits or litigation

You can keep your vendor — but with proof that the relationship is supported by process, not convenience.


How to Keep Long-Term Vendors and Still Meet Fiduciary Standards

You don’t need to change vendors to reduce risk. You need to:

  • Benchmark fees regularly

  • Conduct independent evaluations

  • Document renewal decisions

  • Ensure the vendor still fits your evolving needs

A neutral review strengthens your relationship while strengthening your compliance posture.

Protect the Relationship — and the Plan

Strong vendors deserve strong documentation.
And long-term relationships deserve fresh eyes.

Want an unbiased evaluation without disrupting trusted vendor partnerships? Let’s talk.


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The Parallel Paths: Why Health Benefit Plans Are Entering the Same Litigation Cycle as Retirement Plans

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Why Your Internal RFP May Not Hold Up in Court