Content courtesy of Ary Rosenbaum, Esq., of The Rosenbaum Law Firm P.C. Learn more at therosenbaumlawfirm.com.
Plan sponsors love the idea of simplicity. One provider, one platform, one point of contact. The recordkeeper says they can “handle the TPA work,” and suddenly it feels like you’ve eliminated a layer. Cleaner, cheaper, easier. Until it isn’t.
The problem is that recordkeepers aren’t built to be TPAs, they’re built to process. They take data in, push data out, and rely on how the system is configured. That works great when everything is standard. It falls apart when your plan isn’t. Eligibility nuances, compensation definitions, allocation conditions, these aren’t just data points, they require interpretation. That’s where a real TPA lives.
What I see all the time is sponsors assuming the recordkeeper will catch issues. They won’t. If the payroll feed is wrong, if eligibility is coded incorrectly, if a provision is misunderstood, the system will process it wrong every single time. There’s no second set of eyes reviewing it because the same entity is running everything. Integration doesn’t eliminate risk, it concentrates it.
And here’s the part that gets missed. When something goes wrong, the sponsor owns it. Not the recordkeeper. Not the bundled provider. The sponsor. That means corrective contributions, notices, and time spent fixing something that could have been caught early by independent review.
There’s nothing wrong with bundled services if you understand what you’re getting. But thinking your recordkeeper is acting as a true TPA is where sponsors get into trouble. Processing is not the same as oversight. And in this business, oversight is everything.
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