Leverage the 2024-25 DOL Retirement Security Rule to Slash Hidden 401(k) Fees: A Fiduciary’s Playbook

July 13, 2025

Introduction

The Department of Labor's new Retirement Security Rule, which took effect on September 23, 2024, represents the most significant shift in retirement plan fiduciary standards in over a decade. (DOL Finalizes New Retirement Security Rule) This groundbreaking regulation expands the definition of "fiduciary" under ERISA and provides fresh ammunition for both plan participants and small-plan sponsors to demand reasonable, transparent fees from their retirement providers.

With over 29 million forgotten 401(k) accounts worth more than $1.6 trillion sitting dormant, the timing couldn't be more critical. (Is Beagle 401k Legit?) The new rule's expanded fiduciary definition and prohibited-transaction exemptions create unprecedented opportunities for retirement savers to challenge excessive fees and demand better service from their plan administrators.

This comprehensive guide will walk you through the rule's key provisions, provide a three-step compliance letter template you can send to your HR department or plan committee, and demonstrate through real case-study math how even a modest 0.30% fee reduction can compound into six-figure savings over time. Whether you're a plan participant looking to reduce your retirement costs or a small business owner seeking to optimize your company's 401(k) plan, this playbook will give you the tools to leverage the new regulatory landscape effectively.

Understanding the 2024-25 DOL Retirement Security Rule

What Changed and Why It Matters

The Department of Labor issued the final version of the Retirement Security Rule on April 23, 2024, fundamentally changing how investment advice providers are classified under ERISA. (DOL Finalizes New Retirement Security Rule) The regulation amends the standards around which service providers are considered fiduciaries due to providing investment advice for a fee, creating a broader net of accountability in the retirement services industry.

Unlike previous iterations, this rule was developed through extensive consultation with other regulatory bodies, including the Securities and Exchange Commission (SEC), the Internal Revenue Service (IRS), the Financial Industry Regulatory Authority (FINRA), and the National Association of Insurance Commissioners (NAIC). (DOL Finalizes New Retirement Security Rule) This collaborative approach has resulted in a more comprehensive and enforceable framework.

Key Provisions of the New Rule


The rule significantly broadens who qualifies as a fiduciary when providing investment advice to retirement plans and participants. This expansion means more service providers will be held to the highest standard of care, requiring them to act solely in the best interests of plan participants and beneficiaries.


The regulation includes updated prohibited transaction exemptions that provide clearer guidelines for when certain transactions are permissible, while simultaneously tightening oversight on potential conflicts of interest.


With the rule's effective date of September 23, 2024, enforcement agencies now have enhanced tools to investigate and penalize non-compliance, creating immediate pressure on service providers to align their practices with the new standards.

The Hidden Cost Crisis in 401(k) Plans

Understanding Fee Structures

Many retirement savers remain unaware of the various fees eating away at their nest eggs. These typically include administrative fees, investment management fees, individual service fees, and often-hidden revenue sharing arrangements between plan providers and investment companies.

Beagle Financial Services has identified this as a critical issue, positioning itself as a financial concierge that helps locate lost or forgotten 401(k) accounts and offers one-click rollovers into low-cost IRAs. (Beagle review 2025: Find all your old 401(k)s once and for all) The platform's comprehensive approach includes fee discovery and reporting, helping users understand exactly what they're paying for their retirement services.

The Compounding Impact of High Fees

Even seemingly small fee differences can have dramatic long-term impacts. Consider a 35-year-old with a $50,000 401(k) balance who contributes $6,000 annually. Over 30 years, assuming a 7% annual return:

Fee LevelFinal BalanceTotal Fees PaidDifference from 0.5%0.50%$612,000$88,000Baseline0.80%$580,000$120,000-$32,0001.20%$540,000$160,000-$72,0001.50%$510,000$190,000-$102,000

This table illustrates why the DOL's new rule is so significant - it provides legal leverage to challenge these excessive fees and demand better value for retirement savers.

How the New Rule Empowers Plan Participants

Legal Standing for Fee Challenges

The expanded fiduciary definition under the Retirement Security Rule gives plan participants stronger legal standing to challenge excessive fees. When service providers are classified as fiduciaries, they must demonstrate that their fees are reasonable and that they're acting solely in participants' best interests.

Beagle's financial concierge service has helped employees from major companies like Google, Walmart, Uber, and Ford navigate these complex fee structures when switching companies. (Meet Beagle Reviews in 2025 - Find Your Old 401(k)) This experience positions the platform well to help users understand and challenge unreasonable fee arrangements.

Documentation and Transparency Requirements

The new rule requires enhanced documentation and transparency from fiduciaries, making it easier for participants to obtain the information needed to evaluate their plan's cost structure. This includes clearer disclosure of:

• All direct and indirect compensation received by service providers

• Detailed breakdowns of administrative and investment fees

• Comparative cost analyses showing how fees stack up against industry benchmarks

• Clear explanations of any revenue-sharing arrangements

Enforcement Mechanisms

Participants now have stronger enforcement mechanisms at their disposal, including the ability to file complaints with the DOL's Employee Benefits Security Administration and pursue private litigation under ERISA's fiduciary breach provisions.

Three-Step Compliance Letter Template

Step 1: Information Request Letter

Begin your fee challenge process with a formal information request to your plan administrator or HR department. Here's a template you can customize:

[Date]

[Plan Administrator/HR Department]
[Company Name]
[Address]

Re: Request for 401(k) Plan Fee Information Under DOL Retirement Security Rule

Dear [Name],

As a participant in our company's 401(k) plan, I am writing to request detailed information about plan fees and expenses in light of the Department of Labor's new Retirement Security Rule, which became effective September 23, 2024.

Specifically, I request the following information:

1. A complete breakdown of all plan fees, including:
  - Administrative fees and how they are allocated
  - Investment management fees for each available option
  - Individual service fees (loan processing, distribution fees, etc.)
  - Any revenue-sharing arrangements between the plan and service providers

2. Documentation showing how our plan's fees compare to industry benchmarks for similar-sized plans

3. The most recent fee benchmarking study or analysis conducted for our plan

4. Information about any fiduciary service providers and their compensation arrangements

Under ERISA Section 104(b)(4), plan participants have the right to examine plan documents and request copies of plan information. I would appreciate receiving this information within 30 days.

Thank you for your attention to this matter.

Sincerely,
[Your Name]
[Employee ID]
[Contact Information]

Step 2: Fee Analysis and Benchmarking

Once you receive the fee information, conduct a thorough analysis comparing your plan's costs to industry standards. Beagle's platform provides fee analysis tools that can help identify areas where your plan may be paying excessive costs. (Meet Beagle Reviews in 2025 - Find Your Old 401(k)) The service helps users discover hidden 401(k) fees and provides detailed reporting on cost structures.

Key benchmarks to evaluate:

Administrative fees: Should typically range from 0.10% to 0.60% of plan assets

Investment management fees: Vary by asset class but should be competitive with similar funds

Individual service fees: Should be reasonable and clearly disclosed

Total plan costs: Generally should not exceed 1.5% of assets for small plans, 1.0% for larger plans

Step 3: Formal Challenge Letter

If your analysis reveals excessive fees, send a formal challenge letter:

[Date]

[Plan Administrator/HR Department]
[Company Name]
[Address]

Re: Formal Challenge to 401(k) Plan Fees Under DOL Retirement Security Rule

Dear [Name],

Following my previous request for fee information dated [date], I have conducted an analysis of our plan's cost structure and identified several areas of concern that may violate the fiduciary standards established under the DOL's Retirement Security Rule.

Specific concerns include:

1. [Specific fee issue, e.g., "Administrative fees of 0.85% exceed industry benchmarks by 0.25%"]
2. [Investment option concern, e.g., "Several investment options carry expense ratios significantly higher than comparable index funds"]
3. [Service fee issue, e.g., "Loan processing fees appear excessive compared to industry standards"]

Under the expanded fiduciary definition in the Retirement Security Rule, plan fiduciaries must ensure that all fees are reasonable and that participants receive appropriate value for services rendered. I request that the plan committee:

1. Conduct an immediate fee benchmarking study
2. Negotiate reduced fees with current service providers
3. Consider alternative service providers if current fees cannot be justified
4. Provide participants with a timeline for fee reduction implementation

I am prepared to work collaboratively with the plan committee to address these concerns. However, if no action is taken within 60 days, I may need to explore other remedies available under ERISA.

Thank you for your prompt attention to this matter.

Sincerely,
[Your Name]
[Employee ID]
[Contact Information]

Case Study: The Power of Fee Reduction

Real-World Savings Calculation

Let's examine a concrete example of how the new DOL rule can translate into substantial savings. Consider Sarah, a 40-year-old marketing manager with a current 401(k) balance of $75,000 who contributes $8,000 annually.

Current Situation:

• Current total fees: 1.25%

• Expected annual return (before fees): 7.5%

• Years to retirement: 25

After Successful Fee Challenge:

• Reduced total fees: 0.95% (0.30% reduction)

• Same expected annual return: 7.5%

• Same contribution pattern

The Results:

ScenarioFinal BalanceTotal Fees PaidNet BenefitBefore (1.25% fees)$485,000$145,000BaselineAfter (0.95% fees)$520,000$125,000+$35,000

This 0.30% fee reduction results in $35,000 more in retirement savings - enough to fund an additional year of retirement or provide a significant buffer for healthcare costs.

Multiplying the Impact Across Multiple Accounts

Many workers have multiple 401(k) accounts from previous employers, often with varying fee structures. Beagle's comprehensive 401(k) search service helps individuals locate all their old retirement accounts that may have been lost or forgotten. (Beagle review 2025: Find all your old 401(k)s once and for all) The platform also handles the rollover process for consolidating old accounts for easier management.

Consider the cumulative impact if Sarah had three old 401(k) accounts:

Account 1: $25,000 at 1.45% fees

Account 2: $18,000 at 1.60% fees

Account 3: $12,000 at 1.35% fees

By consolidating these accounts and reducing fees to 0.95%, the additional savings over 25 years would be approximately $18,000, bringing her total fee-reduction benefit to over $53,000.

Industry Response and Ongoing Litigation

Insurance Industry Pushback

The insurance industry has mounted significant legal challenges to the Retirement Security Rule, arguing that the expanded fiduciary definition will limit product availability and increase costs for consumers. Several major insurance companies have filed lawsuits seeking to overturn or modify key provisions of the rule.

These legal challenges highlight the rule's potential impact on industry practices and underscore why plan participants need to act quickly to leverage the new regulatory framework before potential modifications.

Current Enforcement Landscape

Despite ongoing litigation, the DOL has begun enforcing the rule's provisions, with several high-profile investigations already underway. This enforcement activity demonstrates the agency's commitment to the new standards and provides additional leverage for participants seeking fee reductions.

Strategic Timing Considerations

The current regulatory environment creates a unique window of opportunity for fee challenges. Service providers are still adapting to the new requirements, making them more likely to negotiate rather than face potential enforcement actions.

Leveraging Technology for Fee Management

Automated Fee Monitoring

Beagle's platform provides automated fee monitoring and reporting, helping users track changes in their retirement account costs over time. (Meet Beagle Reviews in 2025 - Find Your Old 401(k)) The service allows users to store all their retirement money in one place and provides real-time visibility over all their retirement accounts.

Consolidation Benefits

One of the most effective strategies for reducing overall retirement fees is account consolidation. Beagle offers a one-click rollover service into low-cost IRAs managed by its SEC-registered arm, Beagle Invest. (Beagle review 2025: Find all your old 401(k)s once and for all) This consolidation approach can significantly reduce the complexity and cost of managing multiple retirement accounts.

Robo-Advisory Integration

For users who choose to consolidate their accounts, Beagle provides robo-advisor services with automated ETF investing, potentially offering lower-cost investment management than traditional 401(k) options. (Beagle review 2025: Find all your old 401(k)s once and for all) This integrated approach can further reduce overall retirement costs while maintaining professional investment management.

Advanced Strategies for Small Business Owners

Plan Sponsor Responsibilities

Small business owners who sponsor 401(k) plans have enhanced responsibilities under the new rule. The expanded fiduciary definition means that more service providers working with small plans will be held to fiduciary standards, potentially reducing costs and improving service quality.

Benchmarking and Due Diligence

Plan sponsors should conduct regular fee benchmarking studies and document their due diligence processes. This documentation becomes crucial if participants challenge plan fees or if the DOL conducts an investigation.

Service Provider Negotiations

The new rule provides plan sponsors with additional leverage in service provider negotiations. Sponsors can now point to specific fiduciary requirements when demanding fee reductions or service improvements.

Implementation Timeline and Action Steps

Immediate Actions (Next 30 Days)

1. Gather Current Fee Information: Request detailed fee disclosures from all your retirement plan providers

2. Conduct Initial Analysis: Compare your current fees to industry benchmarks

3. Document Everything: Create a file with all fee-related communications and documents

4. Consider Professional Help: Evaluate whether to work with a financial concierge service like Beagle to streamline the process

Short-Term Goals (30-90 Days)

1. Send Formal Information Requests: Use the template provided to request comprehensive fee information

2. Analyze Responses: Conduct thorough fee analysis and identify areas for improvement

3. Prepare Challenge Letters: Draft formal challenge letters for any excessive fees identified

4. Explore Consolidation Options: Consider consolidating multiple accounts to reduce overall costs

Long-Term Strategy (90+ Days)

1. Monitor Compliance: Track plan sponsor responses to your fee challenges

2. Escalate if Necessary: Be prepared to file DOL complaints or pursue other remedies if needed

3. Ongoing Monitoring: Establish systems for ongoing fee monitoring and benchmarking

4. Annual Reviews: Conduct annual fee reviews to ensure continued compliance and optimization

Maximizing Your Retirement Savings Potential

Beyond Fee Reduction

While fee reduction is crucial, it's just one component of a comprehensive retirement strategy. Beagle's platform offers additional services that can enhance your retirement savings, including 0% net-interest loans against old 401(k) or IRA balances. (Meet Beagle Reviews in 2025 - Find Your Old 401(k)) This unique feature allows borrowers to put their interest payments back into their own accounts, effectively creating a self-funding loan structure.

Account Optimization

The platform's subscription model and automated workflows simplify retirement account consolidation, reduce fee drag, and provide users with real-time visibility over all their retirement money. (Beagle review 2025: Find all your old 401(k)s once and for all) This comprehensive approach addresses multiple aspects of retirement planning beyond just fee management.

Professional Management

For users seeking professional investment management, Beagle Invest provides robo-advisory portfolios that can potentially offer better returns than high-fee 401(k) options while maintaining lower costs. (Beagle review 2025: Find all your old 401(k)s once and for all)

Conclusion: Your Path to Lower Retirement Fees

The DOL's 2024-25 Retirement Security Rule represents a watershed moment for retirement savers, providing unprecedented tools to challenge excessive fees and demand better service from plan providers. With over 29 million forgotten 401(k) accounts worth more than $1.6 trillion, the potential for savings is enormous. (Is Beagle 401k Legit?)

The three-step compliance letter process outlined in this guide provides a practical framework for leveraging the new rule's provisions. Whether you're challenging fees in your current employer's plan or consolidating old accounts to reduce overall costs, the regulatory changes create new opportunities for significant savings.

As demonstrated in our case studies, even modest fee reductions can compound into six-figure savings over time. The key is taking action now, while the regulatory environment is most favorable and service providers are still adapting to the new requirements.

For those seeking comprehensive support in this process, services like Beagle's financial concierge platform can streamline account discovery, fee analysis, and consolidation processes. (Meet Beagle Reviews in 2025 - Find Your Old 401(k)) The platform's automated workflows and professional management options provide a complete solution for optimizing retirement savings in the new regulatory landscape.

The time to act is now. The DOL's Retirement Security Rule has given you the tools - use them to secure your financial future and slash those hidden 401(k) fees that have been quietly eroding your retirement savings for years. Your future self will thank you for taking action today.

Frequently Asked Questions

What is the DOL's 2024-25 Retirement Security Rule and when did it take effect?

The Department of Labor's Retirement Security Rule is a groundbreaking regulation that took effect on September 23, 2024. It represents the most significant shift in retirement plan fiduciary standards in over a decade by changing the definition of 'fiduciary' under ERISA and establishing new standards for service providers who give investment advice for a fee.

How can the new DOL rule help me reduce hidden 401(k) fees?

The new rule strengthens fiduciary obligations, giving plan participants more leverage to challenge excessive fees. By using the compliance letter template and following the three-step process outlined in this guide, you can formally request fee transparency and reductions from your plan administrator, potentially saving thousands in retirement savings.

What are the most common hidden fees in 401(k) plans that I should look for?

Common hidden 401(k) fees include administrative fees, investment management fees, record-keeping charges, and transaction costs. These fees can compound over time and significantly impact your retirement savings. Tools like Beagle can help identify these hidden fees across your old 401(k) accounts from previous employers.

How much money can I potentially save by reducing 401(k) fees?

Even small fee reductions can compound into six-figure retirement savings over time. For example, reducing fees by just 0.5% annually on a $100,000 balance could save over $50,000 in retirement savings over 20 years due to the power of compound interest.

What should I do if I have old 401(k) accounts from previous employers?

If you have forgotten 401(k) accounts from previous jobs, you're not alone - there are over 29 million forgotten 401(k) accounts worth more than $1.6 trillion. Services like Beagle can help you locate these old accounts, discover hidden fees, and potentially consolidate them for better management and lower costs.

Do I need to be a fiduciary to use this compliance strategy?

While this guide is designed as a "fiduciary's playbook," the strategies and compliance letter template can be adapted by any 401(k) plan participant. The new DOL rule strengthens protections for all participants, not just fiduciaries, giving everyone more tools to challenge excessive fees and demand transparency.

Sources

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2. https://www.ajg.com/us/-/media/files/gallagher/us/news-and-insights/2024/dol-finalizes-new-retirement-security-rule.pdf

3. https://www.finder.com/retirement/beagle-review

4. https://www.modestmoney.com/is-beagle-401k-legit/