What Should Trigger a Fiduciary Review — and Why Waiting Can Create Risk
What Should Trigger a Fiduciary Review — and Why Waiting Can Create Risk
Many plan sponsors assume fiduciary reviews happen on a schedule.
Reviews are triggered by plan changes and the calendar. Understanding what should prompt a review helps sponsors stay proactive — and avoid being caught off guard when scrutiny arises.
Fiduciary Reviews Are Responses to Change, Not Distrust
A fiduciary review is not an accusation or a sign that something is wrong.
It’s a prudent response to:
New information
Shifting circumstances
Evolving expectations
Evolving market conditions
Sponsors who treat reviews as routine responses to change are far better positioned than those who wait for issues to surface.
Why Waiting for a “Problem” Creates Exposure
Most fiduciary challenges don’t begin with obvious failures.
They begin with:
Gradual changes
Small shifts that go unexamined
Assumptions that nothing has changed “enough” to warrant review
When scrutiny arrives, sponsors are often asked why a review didn’t occur sooner — not why it happened at all.
Common Events That Should Trigger a Fiduciary Review
While every plan is different, certain events consistently signal the need for review.
Material Fee or Compensation Changes
Any change to:
Fees
Commission structures
Incentive arrangements
Indirect compensation
should prompt a review of reasonableness and potential conflicts.
If compensation changes, fiduciary oversight should follow.
Service or Performance Issues
Recurring issues such as:
Operational errors
Missed deadlines
Participant complaints
Declining responsiveness
indicate a need to reassess whether the provider remains an appropriate fit.
Vendor Organizational Changes
Changes at the provider level matter more than many sponsors realize, including:
Mergers or acquisitions
Ownership or leadership changes
Staff turnover affecting your account
What worked under one structure may not under another.
Changes to the Plan or Workforce
Significant changes in:
Plan size
Workforce demographics
Benefit design
Geographic footprint
can alter what “reasonable” looks like and warrant a fresh evaluation.
Regulatory or Litigation Developments
New regulations, enforcement priorities, or litigation trends often raise the bar for fiduciary oversight.
Sponsors are not expected to predict every change — but they are expected to respond thoughtfully when expectations shift.
Why Documentation Matters When Reviews Are Triggered
When a trigger occurs, documentation should reflect:
Why a review was initiated
What was evaluated
What conclusions were reached
How decisions were made
Even deciding not to change providers should be documented.
How Proactive Reviews Protect Sponsors
Sponsors who respond to triggers promptly:
Maintain credibility
Reduce reactive decision-making
Strengthen negotiating leverage
Preserve control over timing and scope
Proactive reviews are quieter — and far less expensive — than reactive defense.
The Bottom Line for Plan Sponsors
Fiduciary reviews shouldn’t be rare events driven by crisis.
They should be natural responses to plan and market changes, built into a thoughtful oversight framework.
Knowing what triggers a review — and acting when those triggers appear — is one of the most effective ways sponsors protect themselves.
More Information you might find interesting…
What It Means to Be a Fiduciary — and Why It Matters More Than Most Plan Sponsors Realize
Why Relying on Non-Fiduciaries Creates Risk — Even When Everyone Is Acting in Good Faith
What a Defensible Fiduciary Process Actually Looks Like for Plan Sponsors
Broker Compensation and Fiduciary Risk: What Plan Sponsors Need to Understand Now
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