How to read Schedule C fees

Plans with 100 or more participants attach Schedule C to report who was paid for services to the plan. It is the only place in the public record where a plan's providers and their compensation appear by name, and it is easy to misread.

Who is listed

Part I line 2 lists each person or organisation that received $5,000 or more in the plan year, directly or indirectly, for services to the plan. Providers below $5,000 are absent. So are providers whose only compensation was "eligible indirect compensation" (see below): those appear on line 1 by name with no amount. This site shows organisations from line 2 and leaves out every individual.

Direct and indirect compensation

• Direct compensation is paid from plan assets: a recordkeeping invoice charged to the trust, a per-participant fee deducted from accounts, an audit fee paid by the plan.
• Indirect compensation comes from someone other than the plan or the employer because of the provider's position with the plan: revenue sharing from a mutual fund to the recordkeeper, 12b-1 fees, float, finders' fees.
• Eligible indirect compensation is indirect compensation of common kinds (fees charged against fund assets, soft dollars, float) for which the plan received written disclosure of the amount or the formula. It may be reported without a dollar figure. Much of what recordkeepers and fund managers earn falls here, which is the main reason Schedule C totals run below true cost.

What is never on Schedule C

• Fund expense ratios, which reduce returns inside the fund.
• Fees the employer pays from its own money and does not charge back to the plan.
• Anything paid to a provider that received less than $5,000.

Two plans with identical true costs can therefore report very different Schedule C totals: one pays its recordkeeper by invoice from plan assets (all visible), the other through fund revenue sharing disclosed by formula (mostly invisible). A plan high on this site's fee percentile may simply have moved its costs into the open.

The reference figures

For plan year 2024, among defined contribution plans with 100 or more participants that reported any Schedule C amount, the median was $123 per participant and 0.26% of net assets; the middle half of plans ran from $54.08 to $226 per participant. Per-participant amounts fall steeply with plan size, so each plan page uses its own size band. See plans by size.

Administrative expenses on Schedule H

Schedule H reports administrative expenses charged to the plan, by type. It overlaps with Schedule C direct compensation but is not the same list: it includes payees under $5,000 and excludes all indirect compensation. Plan pages show both.

Service codes

Each provider row carries codes from the official list. Codes 10 to 49 say what the provider does:

Codes 50 to 99 say how it was paid:

Codes 20, 30 and 35 (individual trustee, plan employee, sponsor employee) identify natural persons. Rows carrying them are dropped from this site.