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For a church retirement plan, every dollar paid in fees is a dollar that stops compounding for the very people the plan was built to serve. Over a working lifetime, seemingly small differences in plan costs can translate into meaningfully different retirement outcomes.
That is precisely why fee reasonableness sits at the very heart of fiduciary duty — and why excessive-fee litigation has become a persistent feature of the modern retirement plan landscape.
Reasonable Fees Are a Duty — Not an Option — for Church Retirement Plans
It is worth emphasizing that non-ERISA church plans are not exempt from the logic here. Fiduciary responsibility still applies, and the prudent standard referenced under trust law and the Uniform Prudent Investor Act (UPIA) is generally understood to mirror ERISA in the areas that matter most. Benchmarking the fees of all of your plan's service providers is generally considered a best practice — and strong support for demonstrating that fees are reasonable for the services provided.
Reasonableness, not Cheapness is the Fiduciary Standard
It is not necessary to use the lowest-cost provider — but rather to make sure that fees are appropriate for the services delivered. A rock-bottom fee attached to poor service, weak education, and sloppy administration is no bargain for participants. What a fiduciary must be able to demonstrate is that the plan understands what it pays, understands what it receives, and has verified — against the market — that the two are in reasonable balance. Benchmarking is one way that balance can be demonstrated rather than assumed.
Why Benchmarking Is a Fiduciary Imperative
Fee benchmarking is commonly viewed as one of the clearer and more defensible expressions of fiduciary prudence a plan committee can point to. Think about what a periodic, documented benchmarking process can actually accomplish (both for your plan participants—and for you as plan fiduciary).
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What Benchmarking Delivers |
Why It Matters to a Fiduciary |
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Protects participant outcomes |
Can help keep more of each dollar compounding for the people the plan serves, rather than leaking to unjustified costs |
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Demonstrates prudence |
Creates documented evidence that the committee reviewed fees against the market and acted deliberately — the question courts and regulators typically ask |
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Reduces litigation exposure |
Excessive-fee claims often turn on process; a repeatable benchmarking record is widely regarded as among the strongest defenses a plan can build |
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Aligns fees with value |
Confirms that what the plan pays is reasonable for the quality and quantity of services actually delivered |
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Strengthens negotiating position |
Objective, peer-based data gives the committee leverage to renegotiate or replace providers with confidence |
A fee-benchmarking review is widely viewed as a best practice and a documentable element of fiduciary prudence — a small, repeatable discipline that protects everything else the plan is trying to do.
How to Perform Fee Benchmarking
A sound benchmarking process doesn't need to be complicated, but it does need to be complete. In practice, it comes down to five disciplined steps:
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Step |
What It Looks Like |
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1. Identify every provider and every fee |
Gather current fee disclosures from all service providers — consultants, advisors, recordkeepers, and investment managers — including asset-based fees, per-participant charges, fund expense ratios, and any revenue sharing |
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2. Inventory the services received |
Fees mean nothing in a vacuum; list what each provider actually delivers — fiduciary status, education, administration, investment management, participant support |
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3. Compare against truly similar plans |
Benchmark each provider against an apples-to-apples group of plans of similar size, type, and complexity — not broad industry averages that obscure more than they reveal |
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4. Weigh value against fees |
Assess whether the fees are reasonable in light of the quality and quantity of services delivered — the balanced question the law actually asks |
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5. Document and act |
Record the analysis, the committee's discussion, and any resulting actions — renegotiation, service changes, or a decision that fees are reasonable as-is — in the fiduciary file |
It is a best practice to benchmark fees periodically — a good pace would be every three years as part of an annual plan review, or whenever a significant plan change occurs. Fees are generally driven by asset levels and participant counts; unless either changes significantly in a given year, a three-year cadence works well.
How Investing for Catholics Approaches Fee Benchmarking
At Investing for Catholics, we believe benchmarking should be independent, data-driven, and genuinely comparable. To accomplish this, IFC contracts with Fiduciary Decisions, an independent provider of retirement plan fee benchmarking, to benchmark the service providers for the plans we serve.
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Element of the Process |
How It Works |
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Source-direct data |
All data is obtained directly from the source — the recordkeepers, TPAs, and advisor/consultants that charge the fees and provide the services — rather than from surveys or stale databases |
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Fresh and screened |
Data is 90 days old or less when obtained and is rigorously reviewed and standardized for accuracy, consistency, and fair comparison |
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Apples-to-apples benchmark groups |
The patented method builds benchmark groups of truly similar plans, by service provider, so a plan is compared against its real peers — not a meaningless national average |
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Value and fees together |
The dataset is comprehensive — quality, service, value, extra-credit items, and fees — producing a balanced assessment of the relationship between what a plan pays and what it receives |
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The FEEPOINT® calculation |
Rather than fixating on average fees, Fiduciary Decisions' proprietary FEEPOINT® estimates the value of the services, work, and fiduciary status each provider delivers for that specific plan — the benchmark Fiduciary Decisions uses to assess whether the fee is reasonable |
The result is a report that is simple, transparent, and practical — concise information and actionable intelligence a plan committee can genuinely use, and a documented analysis that supports the prudent review of fee reasonableness that fiduciary duty requires. You want something like this in your files.
Sample page from a Fiduciary Decisions benchmarking report, comparing a plan's total fees — investment, service, and credits — against the FEEPOINT® benchmark for the services received. Source: Fiduciary Decisions (fiduciarydecisions.com). Sample shown for illustrative purposes only.
A Complimentary Fee Benchmarking Study for Your PlanIf you haven't benchmarked your plan fees in the last three years—or if you've NEVER benchmarked your plan fees, let IFC help you out with that — at no cost or obligation. I will personally facilitate an independent fee benchmarking analysis of your retirement plan fees service providers, using the source-direct data and methodology described above. You'll receive a clear, documented report you can bring straight to your committee and place in your fiduciary file. To request your complimentary study, just contact me: mary@ifa.com or call 949-428-0432. |
The Bottom Line
Fee benchmarking is not a box to check. It is one of the important ways a church plan committee can prove it is acting prudently, protect participant outcomes, and honor the trust placed in it. You may delegate the work of benchmarking — but never the responsibility to see that it is done. Reviewed faithfully, documented carefully, and acted upon honestly, it becomes the quiet discipline that protects everything else — and serves the mission every church plan shares:
To care for those who have faithfully served.
About the Author
Mary Brunson – Co-Founder, Senior Vice President, Wealth Advisor, Investing for Catholics.
Mary Brunson is the Co-founder of Investing for Catholics (IFC), a division of Index Fund Advisors, Inc. (IFA). Since 2009, she has focused her advisory efforts on Catholic faith-consistent investing, applying financial science to support fiduciary advice and institutional wealth services aligned with Catholic values. She works closely with religious orders and Catholic organizations—including diocesan plans, endowments, and foundations—as well as public trusts, pension plans, and individuals.
Disclosures
Advisory services are offered through Index Fund Advisors, Inc., a registered investment adviser. Readers should consult their own legal, tax, or financial professionals regarding their specific situation before taking any action.
This article is provided for informational and educational purposes only and is not intended to constitute legal, tax, or investment advice. The discussion of laws, regulations, court decisions, fiduciary standards, and governance practices is general in nature and may not apply to all plans or circumstances. Outcomes and interpretations may vary based on specific facts, plan design, governance practices, and applicable law. No assurance can be given that any approach, strategy, or practice will achieve a specific result or reduce risk.
Investing involves risk, including the possible loss of principal. Past performance is not indicative of future results.
Certain statements herein reflect the author's opinions and are subject to change without notice. Forward-looking statements are not guarantees of future outcomes.
About the Author
Mary Brunson - Vice President, Wealth Advisor Investing for Catholics
Mary Brunson is the Co-founder of Investing for Catholics (IFC), a division of Index Fund Advisors, Inc. (IFA). Since 2009, she has focused her advisory efforts on Catholic faith-consistent investing, applying financial science to support fiduciary advice and institutional wealth services aligned with Catholic values. She works closely with religious orders and Catholic organizations—including diocesan plans, endowments, and foundations—as well as public trusts, pension plans, and individuals.
