401(k) Plan Framework Options

There are a few different ways we can framework your retirement plan depending on needs and cost – Participant-Directed Account Plans, Pooled-Asset Plans, and Self-Directed Brokerage Accounts (SDBA) Plans.

Participant-Directed Account (PDA) Plans

This is our most popular retirement plan framework. PDA Plans are generally used for businesses with greater than five participants with an average account balance higher $50,000 or higher.

This structure streamlines the contributions and investments management processes in participant accounts. Investing contributions becomes an automated process with rebalancing being available on a monthly, quarterly, semi-annual, and an annual basis. PDA Plans reside on a dedicated Recordkeeper platform like Vanguard Retirement Plan Access (VRPA) who will also perform Custodian services. A Third-Party Administrator is also required, which will be Farmer & Betts (or TPA of your choice). While most small business start-up plans may not fit the ideal profile for a PDA Plan initially, this will change eventually as plan needs and assets grow with participant enrollments, new contributions, and positive investment returns.

FPLCM Fees (For plans with fewer than 100 participants)

  • Annual Fee – $2,500 + $200 per participant (0.70% of assets for plans with less than $357,000 in assets).
  • One-Time Setup Fee – $2,500 + $100 per participant.


  • Annual Fee – $2,900 includes up to 15 participants.

Pooled-Asset Plans

Designed for smaller businesses with fewer than five participants with a one or two high-income earners.

For this type of plan structure to pass compliance, all participants must have similar risk profiles, as this will be a single brokerage account with one asset allocation. We will collaborate with the plan trustee(s) to design an Investment Policy Statement that is suitable for the plan based on it’s demographics. The plan account can be established as either Schwab or Fidelity. Contributing, investing, and rebalancing must be done manually by FPLCM. Unlike the PDA Plan framework, contributions have the possibility of being in cash for a brief period, prior to being invested. Pooled-Asset Plans do not require a dedicated Recordkeeper, eliminating the need for VRPA. A TPA is required and will also function as the plan’s Recordkeeper.


  • Annual Fee – 0.70% of plan assets with minimum annual fee of $2,500 and a maximum annual fee of $5,000.
  • One-Time Setup Fee – $2,500.

Self-Directed Brokerage Accounts (SDBA) Plans

The most robust plan framework, catering to the needs of multiple high-income earners.

All participants have their own SDBA. FPLCM, working with each participant, designs a suitable asset allocation. SDBAs can be held at Schwab or Fidelity. Private funds can be made accessible (restrictions apply). Contributions, investing, and rebalancing must be done by FPLCM. A TPA is required and will also function as the plan’s Recordkeeper.


  • Annual Fee (Advisor-Managed) – 0.50% of participant SDBA assets with a minimum annual fee of $1,000. Annual fee will be capped based on the level of service required.
  • Annual Fee (Self-Managed) – $1,000 per participant.
  • One-Time Setup Fee – $2,500 + $500 per participant.