Where on my 401(k) fee disclosure do I find what I'm actually paying?
Summary
In two documents, because neither shows the whole amount. The annual participant fee disclosure lists each investment's yearly cost as a percentage and as a dollar amount per $1,000 invested. The quarterly statement shows the dollars actually taken from your account for administrative and individual services. Multiply the per-$1,000 figure by your balance in each fund, add the quarterly charges for four quarters, and you have what the plan costs you in a year.
What the annual disclosure has to contain
The rule behind it is the Labor Department's regulation at 29 CFR 2550.404a-5, often called the 404(a)(5) disclosure. Your plan has to send it before you first direct your investments and "at least annually thereafter," which the regulation defines as "at least once in any 14-month period." It comes in two parts.
The plan-related part explains how general administrative fees are charged and on what basis they're split among participants, plus any individual fees, such as for a loan.
The investment-related part is the one with the numbers. For each fund on the menu, the plan must show "The total annual operating expenses of the investment expressed as a percentage" and the same expense "expressed as a dollar amount for a $1,000 investment" over one year. It also lists shareholder-type fees, returns over 1, 5 and 10 calendar years, a benchmark index for comparison, a website address and a glossary. All of it has to be "in a chart or similar format" built for comparison, so look for a table with one row per fund.
Turning the chart into dollars
An example, not a typical account. Someone holds three funds in an $84,000 balance.
| Fund | Your balance | Cost per $1,000 (from the chart) | Yearly cost |
|---|---|---|---|
| Target-date 2050 fund | $60,000 | $4.20 | $252.00 |
| S&P 500 index fund | $20,000 | $0.50 | $10.00 |
| Stable value fund | $4,000 | $3.50 | $14.00 |
| Investment costs | $84,000 | $276.00 |
The arithmetic is your balance divided by 1,000, times the chart figure: $60,000 ÷ 1,000 × $4.20 = $252. Then open the quarterly statement. If it shows an $18 recordkeeping charge each quarter, that adds $72 a year. Together that is $348 a year, or about 0.41% of the $84,000 balance ($348 ÷ $84,000).
Three lines people misread
The quarterly statement looks complete and isn't. It must show "The dollar amount of the fees and expenses" actually charged to your account in the quarter. The DOL's guide to 401(k) fees is plain about the gap: anything charged indirectly through your investments is left off. The fund expenses in the table above never appear there.
Some plans pay the recordkeeper out of fund expenses. When that happens, the quarterly statement has to say that some plan administrative expenses were paid from the funds' operating expenses. In that case there is no separate admin charge to add: that cost is already inside the per-$1,000 figures, and counting it again would overstate the total.
Shareholder-type fees are charged when you move, not every year. These are things like sales loads and redemption fees, listed separately from operating expenses. A rollover usually means selling every holding, so a redemption fee listed in this column is charged during the rollover itself, on top of that year's operating expenses.
What to do with the total
Put the yearly figure next to what you'd pay elsewhere. What a rollover IRA costs compared with your old 401(k) lists the IRA-side charges to collect, and the fee calculator takes both percentage and flat fees for three accounts at once. If the per-$1,000 figures are your main cost, the expense ratio comparison on $100,000 shows how a gap of $5.00 against $0.30 per $1,000 (0.50% against 0.03%) grows over 25 years.
If you can't find the disclosure, ask the plan administrator for the current 404(a)(5) participant fee disclosure and the last four quarterly statements. The regulation requires both, so the request is routine.
Sources
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-F/part-2550/section-2550.404a-5
- https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/a-look-at-401k-plan-fees.pdf
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