How Often Should You Evaluate Your Retirement Plan Advisor?
How Often Should You Evaluate Your Retirement Plan Advisor?
Most retirement plan committees know they should review their advisor. Fewer know how often, what the review should include, or what counts as a real evaluation versus a routine check-in.
There's no single number in the law. But there is a clear expectation that plan fiduciaries keep watching the providers they hire — and a set of practical signals that tell you when it's time to look more closely.
The Duty Doesn't End at Hiring
Selecting an advisor is a fiduciary decision. So is keeping one.
In Tibble v. Edison International (2015), the U.S. Supreme Court unanimously held that plan fiduciaries have a continuing duty to monitor plan investments and remove imprudent ones — separate from the duty to choose them carefully in the first place. That case was about investments, but the principle it reflects runs through fiduciary practice generally: oversight is ongoing, not a one-time event.
For advisors, that means the committee should be able to show, at any point, that it has recently asked whether the relationship still serves participants and whether the fees are reasonable for the services provided.
Monitoring vs. a Full Evaluation
It helps to separate two activities that often get blended together.
Ongoing monitoring. Regular review of the advisor's service, reporting, fees, and responsiveness — usually at committee meetings throughout the year.
Periodic evaluation. A structured look at whether the current advisor is still the right fit, compared against real alternatives in the market. This is often done through an RFP.
Monitoring tells you whether the relationship is working. An evaluation tells you whether it's the best available option. Committees need both.
How Often Is Common?
Many plan sponsors conduct a full advisor evaluation every three to five years, with ongoing monitoring in between. That range isn't a legal requirement. It reflects a practical balance: long enough to give a relationship time to work, short enough that the committee's view of the market doesn't go stale.
If your last full evaluation was more than five years ago — or if no one on the committee can say when it was — that's a signal on its own.
Triggers That Should Move the Review Up
Some events justify an evaluation sooner than your normal cycle:
Fee changes. A change in how the advisor is paid, or in what the plan pays overall.
Service problems. Missed deliverables, slow responses, or reporting the committee can't use.
Ownership changes. The advisor's firm is acquired, merges, or changes its business model. Consolidation has been common across the advisory industry.
Team changes. The people who serve your plan leave or are replaced.
Plan changes. Significant growth, a merger, or a new plan design that changes what you need from an advisor.
Committee turnover. New members who weren't part of the original decision and can't explain it.
None of these automatically means a change is needed. Each means the committee should take a fresh look and document what it found.
What a Good Evaluation Includes
A periodic evaluation doesn't have to be adversarial, and it doesn't have to end in a change. It does need to be structured. The core elements:
Written criteria agreed on before vendors are contacted
Responses from several qualified firms, gathered on the same terms
A fair side-by-side comparison of services and fees
Clear documentation of the committee's reasoning and decision
Who runs the process matters too. An evaluation run by a party with a stake in the outcome is harder to rely on than one run independently.
Is Benchmarking Enough?
Fee benchmarking is a useful monitoring tool. It shows where your plan's costs sit compared with similar plans.
But a benchmark compares you to averages, not to actual alternatives. It can't tell you how your advisor would respond to real competition or whether a better-fit firm is available. For that, you need an evaluation.
Document Everything
Whatever your cycle, the record is what matters later. Committee minutes should show when reviews happened, what was considered, and why the committee decided as it did — including a decision to stay with the current advisor.
A decision to keep an advisor after a real evaluation is a strong position. A decision to keep one without looking is much harder to defend.
Questions to Ask Between Evaluations
Monitoring doesn't need to be complicated. At least once a year, the committee should be able to answer a short set of questions about its advisor:
Fees. What did the plan pay the advisor this year, in total, and how does that compare with the services delivered?
Deliverables. Did the advisor provide everything promised in the service agreement — investment reviews, committee education, participant support?
Independence. Has anything changed in how the advisor is paid, or in its relationships with the plan's other providers?
Participant outcomes. Are participation, savings rates, and participant questions moving in the right direction, and is the advisor helping?
Fit. Has the plan changed in ways that call for different expertise or a different service model?
The answers belong in the minutes. Over time, that record shows a committee that is actively watching the relationship — and gives it a clear basis for deciding when a full evaluation is due.
Who Should Be Involved
Advisor evaluations work best when the right people are at the table. That usually includes committee members from HR and finance, someone who understands the plan's participant population, and, where appropriate, ERISA counsel to review the process.
The current advisor has a role, too: answering questions, providing data, and responding to the RFP if the committee invites it. What the current advisor shouldn't do is run the evaluation of itself.
A Practical Starting Point
If you're not sure when your plan was last evaluated, start there. Pull the minutes. Find the date. Note what was compared and who ran the process.
That simple exercise usually answers the question of whether it's time — and gives the committee a clear place to begin.
Culpepper RFP conducts independent retirement plan advisor and provider evaluations with no financial ties to the firms being evaluated. If your committee is due for a closer look, we're glad to talk through the process.
