401(k) Provider vs. TPA vs. Investment Adviser: Who Does What?

Start with the plan sponsor

The employer sponsoring the plan is responsible for establishing a prudent process, selecting and monitoring providers, following the plan documents, and paying only reasonable plan expenses. Hiring outside professionals helps perform the work, but it does not make the sponsor's oversight responsibility disappear.

Recordkeeper and retirement plan provider

The recordkeeper tracks participant accounts, contributions, investment elections, distributions, loans, and other plan activity. The term provider is broader and may describe a company that bundles recordkeeping with administration, custody, technology, communication, or other services.

Third-party administrator (TPA)

A TPA commonly supports plan documents, compliance testing, eligibility, contribution calculations, government filings, and other administrative work. The exact scope varies, so sponsors should read the service agreement rather than relying on the title alone.

Custodian or trustee

The custodial or trust arrangement holds plan assets separately from the advisory firm and maintains the applicable asset records. The provider performing this role should be clearly identified in the plan documents and agreements.

Investment adviser

The investment adviser may help evaluate investment options, review fees and services, support sponsor meetings, and educate participants. Qmulate provides these retirement plan services on a non-discretionary basis under ERISA 3(21) and serves in a limited-scope fiduciary capacity. The sponsor retains final authority.

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