Independent 401(K) Operations Review for a Transportation Company

A transportation services company sponsored two 401(k) plans: one for union employees and one for non-union employees. Although both plans were supported by an experienced recordkeeper and generally well administered, small discrepancies and unresolved issues prompted leadership to seek a more comprehensive operations review.

The company’s large and mobile workforce introduced administrative complexity, with frequent transfers between union and non-union divisions and extended leaves of absence affecting eligibility and contribution tracking. Over time, additional issues emerged: delays in cashouts, missed enrollment communications, and payroll irregularities tied to unused paid time off. Participant deaths, unclear beneficiary designations, and the inadequate administration of required minimum distributions (RMDs) further complicated operations.

While the plans passed annual Form 5500 audits, leadership sought greater visibility into day-to-day administrative practices and compliance. To gain this operational perspective—and to prepare for any potential regulatory scrutiny—the company engaged SBA to conduct an independent assessment.

SBA performed a detailed operations review across both plans, assessing not only plan provisions but also how administrative procedures were being carried out in practice. The review focused on:

• Data integrity and transaction consistency across payroll, HR systems, and the recordkeeping platform
• Eligibility and enrollment processing, contribution timing, loan and withdrawal handling, and distribution execution
• Administrative treatment of complex scenarios, including military leave, forfeitures, death claims, and delayed cashouts
• Consistency between plan provisions, summary plan descriptions (SPDs), and the procedures used by internal teams and external vendors

Using a systematic review process, SBA efficiently analyzed hundreds of participant records and transactions to identify exceptions and trends. The engagement was conducted in collaboration with the client’s ERISA counsel to maintain confidentiality and ensure alignment with fiduciary requirements.

The assessment provided the company with a clear and actionable view of plan operations. SBA’s review uncovered administrative risks and inconsistencies that had gone undetected in standard audits, and for each issue identified, SBA outlined a corresponding resolution path.

Findings were organized by severity and mapped to specific corrective actions, enabling the company and its legal counsel to prioritize and address issues efficiently. By clarifying roles, documenting gaps, and delivering a structured remediation plan, SBA gave internal teams the tools and direction needed to strengthen compliance and reduce future risk.

The company emerged from the project with a comprehensive operational roadmap grounded in best practices, ensuring strong fiduciary governance and preparedness for any future regulatory review.