When monitoring investment and recordkeeping fees, a plan sponsor would be smart to remember the recurring themes of recent 401(k) participant fee lawsuits.

“If you haven’t paid any attention to these issues as a sponsor, you’re a little behind the game. But it’s never too late,” says Sam Henson, director, legislative and regulatory affairs at adviser Lockton Retirement Services in Kansas City, Missouri.

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Most 401(k) fee lawsuits so far have targeted large, well-known companies. “But there are only so many mega plans in the country, and so these suits are starting to move down-market,” he says. “It doesn’t matter whether you have $10 billion in your plan or $10 million: Everybody has the same fiduciary obligations.”

The settlements in some recent fee litigations “have been pretty astronomical,” says Emily Seymour Costin, a partner at law firm Alston & Bird LLP in Washington, D.C. “We have recently seen settlements ranging from $15 million to upward of $60 million. It is definitely worth your time to understand these issues—and to adjust, if necessary, your processes to monitor fees.”