Strategy Five — Trust, but Verify: Monitor, Benchmark, and Document

The Plan Is Built. Now Comes the Part Most Committees Skip.

We've come a long way together. In Strategy One, we established strong fiduciary governance. In Strategy Two, we delegated the right responsibilities to trusted, qualified partners. In Strategy Three, we designed the plan on purpose. And in Strategy Four, we turned to the participants themselves — education, income planning, and the discipline to stay the course.

Which brings us to the final strategy, and in some ways the most important one — because it's the strategy that keeps all the others honest: oversee, monitor, and benchmark all service providers for fees and services. And document everything.

A fiduciary's responsibility is continuous, not a "set it and forget it" task.

Hiring good partners was never the finish line. The plan that was well-governed, well-served, and well-designed three years ago may quietly be none of those things today — providers change, fees drift, services erode, markets move. One of the most effective ways to assess this is to conduct regular reviews. Regularly. On purpose. With a paper trail.

Monitoring Services and Fees: The Ongoing Duties

So what does continuous oversight actually involve? For most plans, key ongoing duties come down to these:

Ongoing Duty	What It Involves
Monitoring service providers	Regularly reviewing the performance and fees of fund managers, third-party administrators, recordkeepers, and investment advisors
Timely contributions	Ensuring employee salary deferrals are deposited into the plan as soon as reasonably possible
Required Communications for ERISA or non-ERISA Plans	Providing required reports and periodic disclosures to participants, such as Summary Plan Descriptions (SPDs) and fee disclosure statements
Cybersecurity oversight	As of 2026, fiduciaries are increasingly expected to ensure that service providers maintain robust data protection protocols to safeguard participant information and plan assets

 

Each of these matters. But if there's one oversight practice that deserves special attention — because it's the one regulators, courts, and participants care about most — it's fee benchmarking.

Fee Benchmarking: Why It Matters So Much

Every dollar paid in fees is a dollar that stops compounding for a participant. Over a working lifetime, seemingly small differences in plan costs translate into meaningfully different retirement outcomes — which is exactly why fee reasonableness sits at the heart of fiduciary duty, and why excessive-fee litigation has become such a persistent feature of the retirement plan landscape.

A third-party fee benchmarking of all of your retirement plan service providers is generally considered a "best practice" and solid support for helping to ensure fees are reasonable for the services provided.

One point deserves emphasis, because committees often get it backwards:

It is not necessary to use the lowest-cost provider — but rather to make sure that fees are appropriate for the services delivered.

The fiduciary standard is reasonableness, not cheapness. A rock-bottom fee attached to poor service, weak education, and sloppy administration is no bargain for participants. What the 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.

How to Perform a Fee Benchmarking

In our view, a sound benchmarking process doesn't need to be complicated, but it does need to be complete. Here's what it looks like in practice:

Step	What It Looks Like
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
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
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
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
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 — many plans do so every three years as part of the plan review, or whenever a significant plan change occurs. Fees are generally driven by number of assets and participant counts. Unless either of those changes significantly in any given year, the three year schedule likely works well.

How IFC Approaches Fee Benchmarking

At Investing for Catholics, we believe benchmarking should be independent, data-driven, and designed to provide meaningful comparisons. To accomplish this, IFC currently contracts with Fiduciary Decisions, an independent provider of retirement plan benchmarking, to benchmark service providers for the plans we serve.

 

Element of the Process	How It Works
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
Fresh and screened	Data is 90 days old or less when obtained and is rigorously reviewed and standardized for accuracy, consistency, and fair comparison
Apples-to-apples benchmark groups	The patented method builds benchmark groups of similar plans, by service provider, so a plan may be compared against peer plans rather than broad national averages
Value and fees together	The dataset includes quality, service, value, extra-credit items, and fees — producing an assessment of the relationship between what a plan pays and what it receives
The FEEPOINT® calculation	Rather than focusing solely on average fees, Fiduciary Decisions' proprietary FEEPOINT® estimates the value of the services, work, and fiduciary status each provider delivers for that specific plan — a benchmark against which fees may be evaluated

 

The process is designed to produce 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.

A snapshot of a sample Fee Benchmarking analysis is shown below. If you would like IFC to facilitate a complimentary fee benchmarking analysis for your plan(s), please contact me at mary@ifa.com. 

 

Monitoring Investment Performance

Fees are only half the oversight picture. The plan's investments themselves must be monitored on an ongoing basis against appropriate benchmarks — not to chase performance or react to every quarter's noise, but to verify that each fund continues to do the job it was hired to do.

At IFC, monitoring is conducted quarterly against a defined, documented scoring system — prudent monitoring factors, each with an explicit weight, applied consistently across equity and fixed income funds. Funds that achieve a satisfactory score are considered viable and are kept. That last part matters: a disciplined process defines in advance what "good" looks like, so decisions are driven by criteria, not headlines.

Alongside the scoring system, the annual review examines each fund's performance against appropriate benchmarks over multiple periods — because context, not any single year, is what a fiduciary needs. These would typically include: 1 year, 3-year, 5-year, 10-year, and since inception. Performance differences relative to benchmarks are typically explained through variances in asset class exposure compared to benchmark. Knowing this, it is important to establish an understanding of how a fund differs from its benchmark and if that difference reasonably supports expectations regarding future performance relative to the benchmark. One reason many fiduciaries consider index funds is that they are designed to track benchmarks closely and may reduce certain monitoring considerations relative to more actively managed strategies that come with funds that stray from their index. 

A Catholic Distinction: Monitoring Values Screening and the IPS

For Catholic church plans, monitoring carries one more dimension that secular plans never face. There is likely a preference — an expectation — for utilizing funds that are screened for Catholic values as outlined by the United States Conference of Catholic Bishops (USCCB) in its Socially Responsible Investment Guidelines. Selecting screened funds at the outset, however, is only the beginning of the commitment.

The process of ensuring that this values screening is properly executed — and kept up to date — should itself be monitored. Corporate activities change, portfolio holdings turn over, and the USCCB guidelines themselves are periodically revised. The plan review should therefore confirm who performs the screening, what methodology is applied, how frequently holdings are re-screened, and when the screen was last updated against the current USCCB guidelines. A values screen that was accurate at the time a fund was selected can quietly drift out of alignment if no one is watching.

Values alignment is not a feature to be selected once — it is a commitment to be monitored continuously.

Closely related is the plan's Investment Policy Statement. The plan's investments need to reflect what is outlined in the IPS — the asset classes, selection criteria, monitoring standards, and any values-screening requirements the committee has adopted. If the IPS calls for USCCB-aligned investments, the lineup should demonstrably deliver them; if the lineup has evolved, the IPS should say so. And the IPS itself needs to be reviewed — at least annually, as part of the plan review — and updated whenever plan objectives, the investment menu, or the applicable guidelines change. An IPS that no longer matches the plan it governs is not a safe harbor; it is a liability.

Both of these reviews — the values-screening confirmation and the IPS review — belong in writing, in the fiduciary file. Which brings us to the file itself.

Due Diligence and the Fiduciary File

Here is the uncomfortable truth about all the good work described above: if it isn't documented, then — in the eyes of a regulator, a court, or a future committee — it may as well not have happened. Due diligence and documentation are how a plan proves, years later, that it acted prudently at the time.

The fiduciary file is your plan's institutional memory.

The good news is that maintaining a fiduciary file isn't burdensome. It's a short, but important, list:

• Plan Document, Plan Adoption Agreement, and Plan Amendments
• All Service Agreements
• Annual Plan Review Minutes, Documents, Data, Reports, and Action Items
• Investment Policy Statement
• Investment Performance, Monitoring, and Benchmarking Reports
• Periodic Fee Benchmarking for All Services Obtained — Consultants, Advisors, Recordkeepers, and Investment Managers

 

Keep it current, keep it organized, and keep it in one place. A well-maintained fiduciary file turns oversight from something the committee vaguely remembers doing into something the committee can prove it did.

The Annual Plan Review: Where It All Comes Together

If ongoing oversight is the engine of a healthy plan, the annual plan review meeting is where the engine gets serviced. Annual plan review meetings are essential to ongoing plan success — they are the standing, structured occasion where the committee and its partners step back and examine the whole plan, on purpose.

A strong annual review agenda covers:

Agenda Item	What the Committee Examines
Plan health and demographics	Participation rates, deferral rates, account balances, and progress toward income-replacement goals
Investment performance	Each fund or portfolio versus its appropriate benchmark and the plan's monitoring criteria, over multiple time periods
Fees and benchmarking	The latest fee benchmarking results and whether fees remain reasonable for services received
Service provider performance	Whether each partner is delivering the services promised
Compliance and disclosures	Timely contributions, required participant disclosures, and any plan document or regulatory updates
Action items — documented	Decisions made, follow-ups assigned, and everything recorded in the fiduciary file

 

Held annually, this meeting can help create documentation that supports a prudent fiduciary process.

A Summary of Critical Plan Elements and Actions

Pulling the whole series together, a healthy church retirement plan is a plan run by you — with vetted and trusted partners who:

• Accept a fiduciary standard of care, by contract
• Are knowledgeable and utilize best practices
• Proactively and regularly meet to ensure the plan remains on track
• Facilitate fee benchmarking and plan demographic studies
• Provide communications and education to your employees
• Understand ERISA, but speak and implement non-ERISA
• Don't upsell through proprietary funds or managed accounts
• Help you build and maintain your fiduciary file
• Care about your plan as much as you do — and show it!

 

A Fiduciary Reminder

As always, even in non-ERISA church plans, fiduciary responsibility still applies. Monitoring providers, benchmarking fees, and documenting the process aren't regulatory box-checking — they are part of acting prudently and caring well for those the plan serves.

You may delegate functions — but not responsibility. And nowhere is that truer than in oversight: the duty to monitor the very partners you've delegated to.

Bottom Line

A healthy church retirement plan is never finished. It is governed well, partnered wisely, designed on purpose, and communicated clearly — and then it is watched: services monitored, fees benchmarked, investments measured, and every bit of it documented in a living fiduciary file, refreshed at an annual review that keeps the whole plan honest.

Do that, year after year, and oversight can become a consistent process that helps support the plan's broader objectives.

And it serves the same mission this entire series has come back to, again and again:

To care for those who have faithfully served.

 

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Disclosure: This material is provided for informational and educational purposes only and reflects the opinions of the author as of the date of publication. It is not intended as investment, legal, or tax advice.

Forward-looking statements and assumptions are based on current expectations and are subject to change; actual outcomes may differ. There can be no assurance that any plan design features discussed will achieve their intended results or that participants will experience improved outcomes. Plan sponsors should evaluate all decisions based on their specific circumstances and consult appropriate professionals. Content is AI-assisted. Index Fund Advisors, Inc. is a registered investment adviser. For additional information, please visit adviserinfo.sec.gov or www.ifa.com.