Plan Fee Review

Notes about the rating. The plan's administrative cost for 2024 is $40 per participant. Among 38 plans of similar size and type in the same industry, that figure sits at the 14th percentile, which is band A. No reviewer adjustment was applied. A second route, the plan's cost as a multiple of a documented benchmark, is not yet available for this report.

What this report is. This is a tier 1 review. It rebuilds what the plan pays to be administered, states that figure for each person in the plan, and rates it against what plans of similar size pay. The rating covers fee level only. Data confidence and compliance are reported beside the letter and are not folded into it.

What this report is not. This is not a finding that the fees are imprudent. That is a different review and it needs evidence this one does not have. The recordkeeping agreement, the committee minutes and the fee disclosure notice are not public and were not read.

What it is built from. The plan's own Form 5500 filings, which are public, together with the filings of comparable plans. Every figure traces to a filing. The filings used are listed by acknowledgment number at the end of this report.

How to read the rating. The rating runs A through E. A means the plan pays about what similar plans pay, or less. E means it pays far more. The full scale, and what a plan must satisfy to be rated A, are set out on the Rating Parameters page.

Plan costs outlined

Schedule H renumbered and redefined the administrative expense sub-lines for 2023. The history compares only the total this review rates. The plan reported no investment management fees paid from plan assets on Schedule H for 2024.

Recordkeeper on Schedule C: EMPOWER LIFE & ANNUITY INSURANCE CO (service code 64 or 15, filing 20251015210731NAL0003008051001).

[OPEN: exclusions. The template says "These numbers exclude services a participant chooses and buys for themselves, which means managed accounts and the brokerage window." This snapshot takes the Schedule H total as filed and the public filing does not separate those services, so nothing is excluded and the sentence is held until the basis ruling.] In 2024 the plan had 4,854 participants. At $40 per participant against a median of $99 among comparable plans, the plan's cost was $59 per participant below the median that year.

Where the plan sits, 2024

The rating uses the business code 541110, 2.5K-5K participants, DC-401k set because it is the narrowest set with at least 30 plans. A plan with large average balances can be expensive per participant and inexpensive as a share of assets at the same time. Both figures are reported because both are true.

Compliance checks

Fields: 4a (FAIL_TRANSMIT_CONTRIB_IND), 4b (LOANS_IN_DEFAULT_IND), 4d (PARTY_IN_INT_NOT_RPTD_IND), 4e (PLAN_INS_FDLTY_BOND_IND), 4f (LOSS_DISCV_DUR_YEAR_IND), 4g (ASSET_UNDETERM_VAL_IND), 4m (PLAN_BLACKOUT_PERIOD_IND), 3b, any limited-scope box (derived: 1 when 3b or 3b(1) or 3b(2) is checked, 2 when 3b is No or 3b(3) is checked), opinion 3a (ACCTNT_OPINION_TYPE_CD).

Notes about compliance. Three identities have to hold before any figure on the filing can be relied on. All three held in all 6 years. End of year net assets minus start of year equals net income. Total income minus net income equals total expenses. Total expenses minus benefit payments equals administrative expenses plus the small items. The Schedule C direct pay and the Schedule H administrative total agreed to the dollar in all 6 years.

Disclosure. This plan did not elect the Schedule C option that reports revenue sharing as rates only. The money paid back by the funds is disclosed in dollars and is included in the figures above. Also not available from public filings: the recordkeeping agreement, committee minutes, the fee disclosure notice, and anything at all about a single participant.

Plan documents were not read end to end, and this report is not saying these fees are imprudent. That is a different review and it needs evidence this one does not have.

Alternative explanations and the document that settles each

What a participant may request in writing

Under ERISA section 104(b)(4), a participant may request in writing from the plan administrator copies of the latest updated summary plan description, the latest annual report (Form 5500), any terminal report, the bargaining agreement, the trust agreement, the contract, and other instruments under which the plan is established or operated. The administrator must furnish them within 30 days of a written request and may charge a reasonable copying fee. The plan administrator named in the most recent filing is SKADDEN ARPS SLATE MEAGHER & FLOM, LLP (the filing states the administrator is the plan sponsor).

[COPY: whether the report offers a generated request letter is pending counsel's answer]

Rating parameters explained

This review rates what the plan paid to run itself, taken from the plan's own filings with the Department of Labor, and shows separately what the plan paid its investment managers out of plan assets. The rest of what the funds cost, the part taken out of each fund's returns, is not in those filings. It comes from the fee disclosure you sent us, which lists every fund's expense ratio, and that part describes the menu you were offered, not what you personally paid. Many plans also have money the funds pay to the plan's recordkeeper and other providers, often called revenue sharing. The filings usually do not show that money in dollars, and this review does not estimate it. Where the filings cannot say something, this review says so rather than guessing.

What the letter covers. The letter covers fee level only. It is the plan's administrative cost for each person in the plan, taken on the rated year, the most recent filed year that is not a final return or a short plan year. Data confidence and compliance sit beside the letter as their own results. One letter covering three things hides each of them behind the others, and it hands a defending adviser an argument about which one pulled it down.

What goes into the number. The Schedule H administrative expense total for the year, line 2i(5) on filings through form year 2022 and line 2i(12) from form year 2023, less the investment management fees paid from plan assets, line 2i(3) through 2022 and line 2i(5) from 2023, to the extent Schedule C shows those fees paid directly to the managers of the plan investments, divided by the total number of participants at the end of the plan year, Form 5500 line 6f. [OPEN: the template's sentence "Services a participant chooses and buys for themselves are excluded, which means managed accounts and the brokerage window" is held, nothing is excluded from the Schedule H total in this snapshot] Taken out: investment management fees paid from plan assets, shown on their own line and taken out of the administrative expense only where Schedule C shows them paid directly to the plan investment managers. Every report states what is in the number, because the figure taken straight off the filing is wrong in both directions.

Route one, the plan's place in its peer set. A at or below the 25th percentile. B above the 25th, to the 50th. C above the 50th, to the 75th. D above the 75th, to the 90th. E above the 90th. The peer set is every plan of the same type and size band in the same data snapshot that passes the same filing checks, narrowed to the plan's industry where at least 30 such plans exist. The rule is printed in full at the end of this report.

Route two, a multiple of a documented benchmark. A at or below 1.0 times. B above 1.0, to 1.25 times. C above 1.25, to 1.5 times. D above 1.5, to 2.0 times. E above 2.0 times. Both routes are run and printed when both are available. Where they disagree by more than one band, the peer set is wrong for that plan, and that is the failure a percentile on its own hides best. Route two is not yet available: a benchmark is used only when its source and its edition can be named on the report.

What a plan must satisfy to be rated A. An A is a clearance, not simply the bottom of the same ladder, and it needs evidence the other bands do not. All of the following have to hold. Route one returns A. The total fee is known in dollars. A plan that discloses the money the funds paid back as rates rather than dollars fails this, because the largest part of its cost is not on the filing. Data confidence reads Full. All three identities hold and Schedule C ties to Schedule H. The result holds across the filed years and is not one cheap year. The plan files a Schedule H. Plans with fewer than 100 people file the 5500-SF, which carries neither Schedule H nor Schedule C, and cannot be rated at all.

Why an A is harder to earn than an E. A plan can be called expensive on an incomplete number, because the part already visible is too large and anything missing only makes it worse. A plan cannot be cleared on an incomplete number, because the part that is missing could be the part that sinks it. That is the whole reason the two letters do not need the same evidence. This has a cost worth stating plainly. Roughly two thirds of plans disclose the money the funds paid back as rates rather than dollars, so on those plans this review can find expensive and can never issue an A.

Reviewer adjustment. The reviewer may move a plan one band, either direction, and the reason is printed on the report. A case for moving two bands is a tier 2 question and not an adjustment.

Data confidence. Full: the whole fee is on the filing as dollars and the schedules tie. Partial: part of the fee is disclosed as rates or a formula rather than dollars. Limited: the filing is incomplete or amended, or the schedules do not tie. This report: Full. Because the whole fee is on the filing in dollars, all three identities hold, and Schedule C ties to Schedule H.

Compliance. Reported as a list with a count, never as a grade. A compliance finding is a different kind of failure from an expensive fee, and folding the two together hides both.

Per-year route one, for the record: 2019 A (14th of 33), 2020 A (22nd of 34), 2021 A (15th of 36), 2022 A (7th of 38), 2023 A (12th of 38), 2024 A (14th of 38).

Filings used

2019 (form year 2019): Form 5500 acknowledgment 20201007172217NAL0008277779001, administrative expense line 2i(5), received 2020-10-07. 2020 (form year 2020): Form 5500 acknowledgment 20210930135934NAL0003456755001, administrative expense line 2i(5), received 2021-09-30. 2021 (form year 2021): Form 5500 acknowledgment 20221013141614NAL0048878994001, administrative expense line 2i(5), received 2022-10-13. 2022 (form year 2022): Form 5500 acknowledgment 20231012164940NAL0020865475001, administrative expense line 2i(5), received 2023-10-12. 2023 (form year 2023): Form 5500 acknowledgment 20241015091334NAL0027916241001, administrative expense line 2i(12), received 2024-10-15. 2024 (form year 2024): Form 5500 acknowledgment 20251015210731NAL0003008051001, administrative expense line 2i(12), received 2025-10-15.

Peer rule, from the data snapshot of 2026-09-10-r4: "Peer pool. A filing is in the peer pool when its first two reconciliation checks pass, its administrative expense is greater than zero, its participant count is greater than zero, its average net assets are greater than zero, its plan year and form year agree, it does not cover a short plan year, and the filer is not a direct filing entity. Peer sets. The primary peer set is the pool filings with the same six-digit business code, the same participant size band, the same plan type, and the same plan year. If that set has fewer than thirty plans, the set widens to the same three-digit industry group with the same band, type and year. If that set is also below thirty, the all-industry set with the same band, type and year is used. The all-industry set is always shown alongside. Every report names the set it used, its size, and why. Percentile. A plan's percentile in a set is the share of the set's plans below it, plus half the share equal to it, times one hundred. A plan in the pool is counted in its own set. A plan that is not in the pool is ranked against the set without joining it."

Data: Form 5500 "Latest" datasets per form year, downloaded 2026-09-10, snapshot 2026-09-10-r4 built 2026-10-17T17:44:09+00:00. Report R-EEED885A42 rendered 2026-10-17T19:53:08+00:00 UTC. Template TIER1-TEMPLATE-v1 (strategy 2026-09-18). Reviewer initials ____, date ____.