Fiduciary
How to Run a Smarter 401(k) Adviser Search: Start With the Right RFI
Last Updated: March 02, 2026
Most retirement plan committees approach an adviser search the same way: they jump straight into a formal Request for Proposal (RFP), distribute a lengthy questionnaire, and wait for polished responses to come back.
On the surface, this process appears thorough and objective. In practice, however, it often produces the opposite result.
Traditional RFPs tend to reward marketing sophistication rather than fiduciary discipline. They generate large volumes of information but provide very little clarity about how an adviser will actually improve participant outcomes, manage risk, or strengthen governance over time. The issue is not effort — it is structure.
When committees move directly to an RFP, they skip the most important phase of the search: diagnosis. A well-run search begins with a focused Request for Information (RFI). Unlike an RFP, the purpose of an RFI is not to collect credentials or compare surface-level capabilities. It is designed to determine which firms have the processes, systems, and accountability mechanisms necessary to deliver measurable results for participants while protecting fiduciaries in the long term.
Most RFIs Fail for Three Particular Reasons
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They prioritize form over substance. Standardized templates emphasize firm history, assets under management, and service menus, which do not reliably predict participant outcomes.
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They obscure incentives. Compensation structures, indirect revenue, and platform relationships are often buried in technical disclosures that are difficult to interpret.
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They underweight execution risk. Committees learn what a firm claims it can do, not how it actually operates day to day.
The result is a selection process that feels comprehensive but leaves critical risks unresolved.
A smarter process reverses this dynamic. It uses an RFI to surface how advisers think, how they operate, and how they manage fiduciary responsibility before anyone submits a formal proposal.
The RFI as a Performance Filter
- A strong RFI is not a shortened RFP. It serves a bigger purpose.
- Its function is to filter the market based on four questions:
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- – Does this firm have a disciplined, defensible investment oversight process?
- – Does this firm actively control cost and fee risk?
- – Can this firm measurably improve participant retirement outcomes?
- – Will this firm help the committee demonstrate a prudent fiduciary process?
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If an adviser cannot answer these questions clearly and consistently, it should not advance to the RFP stage.
The sections below outline the core areas an effective RFI should focus on.
1. Investment Selection & Monitoring Process
The quality of a retirement plan’s investment lineup is not determined by individual fund choices. It is determined by the framework used to select, evaluate, and replace those funds over time. An effective RFI should require advisers to explain their process in detail.
Key areas to examine include:
• How initial investment screening is conducted
• The quantitative and qualitative criteria used in selection
• How risk is defined and evaluated
• The structure of any watchlist system
• Escalation and replacement procedures
• Documentation standards for due diligence
Committees should be looking for evidence of a repeatable, rules-based system rather than ad hoc judgment.
Vague descriptions such as “we continuously monitor” or “we use a proprietary approach” provide little protection in practice. What matters is whether the adviser can demonstrate consistent application of defined standards and timely action when issues arise. A disciplined monitoring process reduces both investment risk and fiduciary exposure.
2. Fee Monitoring & Benchmarking
Fees are one of the few variables committees can directly influence, and they have a measurable impact on long-term participant outcomes. Yet many advisers treat fee reviews as a compliance exercise rather than an ongoing governance responsibility.
A strong RFI should address:
• How plan fees are benchmarked
• How often benchmarking occurs
• What data sources are used
• How indirect compensation is monitored
• What triggers renegotiation or vendor review
One-time benchmarking provides limited value. Effective oversight requires continuous monitoring as plan demographics, asset levels, and service needs to evolve.
Committees should be wary of advisers who rely solely on periodic surveys or generic industry comparisons. Robust fee oversight requires structured analysis and active negotiation. Managing cost risk is a core fiduciary function, not an administrative task.
3. Participant Outcomes & Retirement Readiness
Education, meetings, and communications are inputs. Retirement readiness is the output. An adviser’s value is ultimately reflected in whether participants are progressing toward sustainable retirement income. An effective RFI should focus on how outcomes are defined, measured, and improved.
Key areas include:
• How retirement readiness is calculated
• How income replacement is projected
• How progress is tracked at the plan level
• How plan design supports better outcomes
• How engagement initiatives are evaluated
Committees should look for firms that use data to drive results, not just activity.
What matters is whether participants’ savings rates, investment behavior, and projected income improve over time. Advisers who cannot measure readiness cannot manage it.
4. Fiduciary Documentation & Risk Management
A prudent fiduciary process must be demonstrable. In regulatory reviews and litigation, outcomes matter—but documentation matters just as much. Committees are evaluated on whether they followed a reasonable, well-documented decision framework. An RFI should clarify how advisers support this responsibility.
Areas to examine include:
• How committee decisions are documented
• What materials support fiduciary files
• How recommendations are substantiated
• How regulatory changes are incorporated
• How governance continuity is maintained
High-quality fiduciary support is structural, not personal. It is embedded in systems, templates, review cycles, and records. Strong service relationships are valuable, but they do not substitute for defensible governance infrastructure.
How to Interpret RFI Responses
- Collecting responses is only half the process. Committees must also know how to evaluate them.
Several patterns are worth noting.
- • Overly long answers often signal obfuscation. When a process is clear, it can usually be explained concisely.
• Generic language suggests templated responses. Phrases such as “industry standard” or “best-in-class” without specifics provide little insight.
• Avoidance of metrics is a warning sign. Firms that cannot quantify outcomes rarely manage them systematically. - • Excessive customization claims may indicate a lack of framework. True customization builds on structure, not the absence of it.
The goal is not to find perfect answers, but to identify consistent, transparent operating models.
Let the Process Protect the Committee
Running an adviser search is not a procurement exercise. It is a fiduciary responsibility governed by ERISA’s requirement to act prudently and solely in the interest of participants.
A well-designed RFI helps committees identify partners who can demonstrate:
• Clear alignment with committee objectives
• Disciplined investment oversight
• Active fee management
• Outcome-driven participant strategies
• Defensible governance systems
The result is a process that improves participant results and reduces long-term risk. For committees that want a structured starting point, we have developed an RFI template built around this framework. It is designed to help committees ask the right questions, evaluate responses consistently, and move into an RFP with confidence.
A well-structured RFI can strengthen fiduciary documentation, clarify adviser accountability, and improve long-term plan outcomes.
