Mutual Fund Fees in 401(k)s Show Multi-Decade Decline

Fees for mutual funds in defined contribution plans have declined about 60% this century, according to a new ICI report, though CITs loom as an even-cheaper competitor.

Mutual fund fees have fallen by more than half so far this century across both equity and bond funds, as the most popular 401(k) investment tool has met with increased competition and plan fiduciary scrutiny, according to a report released Tuesday by the Investment Company Institute.

The ICI, an association representing regulated funds, including mutual funds and exchange-traded funds, released research showing a steady, multi-decade decline in 401(k) plan equity mutual fund fees resulting in a 60% drop since 2000 to an average of 0.31%. Meanwhile, fees for 401(k) plan bond mutual funds fell 63% to 0.22% and fees for a hybrid of both equity and bonds fell 42% to 0.42%.

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The association noted the fee compression happened even as the cost of many other things in the life of the average American rose—such as school tuition, tax preparation services and rent.

“This is great news for American workers looking to invest for the long term and drive growth in their 401(k) plan nest eggs,” said Sarah Holden, ICI senior director of retirement and investor research, in a statement. “Our study shows that retirement savers continue to see high value investing in mutual funds, which are diversified, professionally managed, and cost-effective.”

Mutual Fund Expenses From 2000 to 2023


Source: ICI


Holden cited competition in the marketplace, clear disclosures, the rise of index funds and plan participants’ investment choices as reasons for the continued fee compression. The report also noted the pressure from plan fiduciaries to keep fees low, with regular reviews and increased shopping for the best options as factors.

Mutual Funds vs. CITs

As of year-end 2023, defined contribution plans held $7.4 trillion in assets, with mutual funds making up $4.8 trillion, or 65%, of the total, according to the ICI. The other $2.6 trillion are in other assets and investment structures, including collective investment trusts and guaranteed investment contracts such as stable value funds.

The ICI report is a counter to the narrative of the rise of CITs, which generally offer even lower fees, as they are only available to 401(k) plans and do not have to manage SEC security regulations. As of March, Morningstar put CITs at 49% of the in-plan target-date market, making them on track to overtake mutual funds by the end of this year.

Meanwhile, an analysis of all long-term mutual fund flows by business intelligence firm Simfund shows net monthly outflows for every month except two since the beginning of 2022. In 2024, Simfund data show total net outflows from mutual funds of about $38 billion, with April seeing the largest asset loss for mutual funds at $41.9 billion. Simfund, like PLANSPONSOR, is owned by ISS STOXX.

Of the ICI-tracked mutual funds, 58% are equity mutual funds, 28% are a mix of equity and bonds known as hybrid, 11% are solely bonds and 3% are money market funds.

The data did show that target-date mutual funds have become more popular among 401(k) plan providers. At year-end 2023, $1.8 trillion of the mutual fund asset pool was in TDF mutual funds, usually held in a fund-of-funds structure, meaning they are invested in other mutual funds or exchange traded funds.

Fee Structures

Equity mutual fund fees tend to fall as 401(k) plan size increases, according to the research. Retirement plans with less than $1 million in assets have average fees of 0.53% for equity mutual funds, a figure that declines by plan size until hitting a low of 0.34% for plans with more than $1 billion in assets.

In the report, the ICI broke down the fee structure for investment funds in a 401(k) plan. It noted that fees for investments within the accounts can be paid either fully by participants, by a combination of participants and the plan sponsor, or by just the sponsor.

Investors in mutual funds generally pay two types of fees, according to the ICI: ongoing expenses, which cover management and other operating costs, and sales loads, which are paid at purchase, redemption or at specific points in time if held. Those sales loads are often waived for 401(k) plans and, in fact, 96% of mutual funds in 401(k) plans were being held in institutional and retail “no-load” share classes as of the end of 2023, according to the ICI, partly resulting in the lower fees when compared to retail mutual funds.

“The Economics of Providing 401(k) Plans: Services, Fees, and Expenses, 2023” is done in conjunction between the ICI and data and analysis firm Brightscope, which, like PLANSPONSOR, is owned by ISS STOXX.

Fiduciary Law Center is New Name of Retirement Law Group

Matthew Eickman joins as chief legal officer as Jason Roberts’ ERISA legal practice aims to represent the broader footprint of its services.

The Retirement Law Group Inc., founded in 2011 by ERISA expert Jason Roberts, is now the Fiduciary Law Center, a rebranding that includes bringing on a chief legal officer and specialist attorneys to meet what the firm calls a broader range of services.

Matthew Eickman will take the role of chief legal officer, bringing more than 12 years of experience as a fiduciary plan adviser and consultant, including as a retirement practice leader for Prime Retirement (recently also renamed from Qualified Plan Advisors).

“The rebrand was primarily driven by the fact that, over the past decade, we began serving clients on a broader range of issues that, in many cases, have nothing to do with retirement laws or regulations,” said Roberts said in a statement. “We have steadily enhanced our capabilities to include general securities and banking compliance matters, information and cybersecurity, and mergers and acquisitions, to name a few, and we believe our new name will resonate better with our expanded clientele.”

Jason Roberts

Eickman, who has practiced law for more than 20 years and is active in the American Bar Association’s Tax Section, calls it “an exciting time to work as an ERISA attorney,” as the industry evolves amid changes that include the new fiduciary rule, formerly known as the retirement security rule.

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“I’m excited to bring the experience of working directly with plan sponsors and also having [a registered investment adviser] to craft participant solutions for the past decade to bring into a law firm and work with one of the industry’s greatest thought leaders in Jason Roberts,” says Eickman. “To pair my experience with his leadership is a tremendous opportunity.”

Eickman says the firm has also built out its roster of attorneys to meet three more specialized areas of ERISA law in particular.

One is to assist firms in managing the “less-defined separation” between qualified retirement plans and private wealth management, with attorneys who understand the intersection of those businesses, as firms can “no longer work in a silo and address only traditional plan fiduciary issues.”

Matthew Eickman

A second area is the need to plan sponsor clients with IRS self-correction of retirement plan errors, which was expanded in SECURE Act 2.0 of 2022 legislation and requires more “vigilance” for sponsors to identify and quickly report, Eickman says.

Third, the firm will be focused on understanding and guiding retirement plan fiduciaries on technological advancements regarding the use and protection of confidential information, particularly cybersecurity needs.

New attorneys include Paula Flaherty, who joins after more than 30 years at third-party administrator and recordkeeper firms, including John Hancock Retirement Plan Services LLC, and Michael Haya, previously president of Actuarial Consulting Services, a third-party administrator focused on small businesses.

Fiduciary Law Center’s Roberts is also the founder and CEO of the Pension Resource Institute, an ERISA consulting firm. Among its services is a compliance solutions program for banks, broker/dealers and registered investment advisers.

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