Who’s Advising Your Advisor?
White Paper
Who’s Advising Your Advisor?
How Private Equity Is Reshaping Retirement Plan Advisory and Raising New Questions About Transparency
Nate Moody, CPFA | Senior Financial Advisor & Partner | April 2026
Your Advisor Might Not Work for Who You Think
Here’s a question most plan sponsors have never thought to ask: who owns your retirement plan advisor?
Not who shows up to your committee meetings. Who actually owns the firm. Who sets revenue targets. Who decides whether your advisor’s team gets bigger or smaller. Who profits when the investment lineup shifts toward alternatives.
If your advisor was acquired by a private equity firm in the last few years, those answers have changed. Odds are, nobody told your committee.
I’ve been advising plan sponsors my entire career. I watched this industry transform after the 2012 fee disclosure rules forced hidden compensation into the open. Fees fell. Conflicts got exposed. Sponsors finally had the tools to hold service providers accountable.
This consolidation may change how transparency is experienced, once again.
How We Got Here
Before 2012: Your Plan Was Not Free
I can’t count how many times I’ve sat across from a plan sponsor who told me their 401(k) was free. No invoice. No line item. So it must be free.
It was never free. Costs were buried in inflated expense ratios, 12b‑1 fees kicked back to brokers, and sub-transfer agent payments flowing between providers in ways that would make your head spin. Participants were paying for everything. They just couldn’t see it.
2012: Disclosure Changed Everything
On July 1, 2012, the DOL’s ERISA Section 408(b)(2) regulation took effect. For the first time, every covered service provider had to disclose exactly what they were paid, how they were paid, and what conflicts that compensation created.1
The market responded. Advisors who’d relied on embedded compensation had to justify their value or cut their fees. Competition picked up. Costs started falling.
| Year | Avg Equity Fund Expense Ratio (401k) | Total Plan Cost (Participant-Wtd) |
|---|---|---|
| 2000 | 0.76% | N/A |
| 2009 | 0.63% | 0.65% |
| 2012 | 0.54% | 0.58% |
| 2015 | 0.46% | 0.51% |
| 2022 | 0.29% | 0.52% |
| 2024 | 0.26% | N/A |
Equity fund expense ratios fell 66% from 2000 to 2024. That’s real money back in participants’ accounts.2,3
Fee Litigation Gave Disclosure Its Teeth
Starting with Tibble v. Edison (2015) and accelerating through Hughes v. Northwestern (2022), courts made clear that fiduciaries have an ongoing duty to monitor fees. Excessive fee suits hit 43 in 2023, 47 in 2024, and 51 in 2025. Committees started benchmarking annually because the cost of not doing so got too high.4
The Fiduciary Rule: Four Tries, Zero Sticking
| Year | Action | Outcome |
|---|---|---|
| 2010 | DOL proposes expanded fiduciary definition | Withdrawn 2011 |
| 2016 | Obama DOL finalizes fiduciary rule | Vacated by 5th Circuit, 2018 |
| 2024 | Biden DOL finalizes Retirement Security Rule | Blocked by two TX courts |
| 2026 | Trump DOL declines to defend | Vacated March 2026 |
Four attempts. Sixteen years. As of today, there’s no enforceable DOL fiduciary rule governing rollover advice. The SEC’s Reg BI applies to broker-dealers and is an improvement over the old suitability standard, but it’s not a fiduciary obligation.5
The Consolidation Wave
RIA M&A Transactions by Year6
181
203
205
242
264
231
272
322
322 transactions in 2025. 18% over the prior record. PE-backed aggregators accounted for 51% of all deals. The ten most active acquirers completed 100+ transactions representing $880 billion in assets.7
Here’s the number that matters: 18% more sellers, 19% fewer buyers. The industry is concentrating into fewer hands, fast.
| Platform | PE Sponsor | Notable Activity |
|---|---|---|
| Creative Planning | General Atlantic | Acquired SageView Advisory |
| Cerity Partners | Genstar Capital | Merged with Verus ($1.2T) |
| Hightower | Thomas H. Lee | Acquired NEPC ($1.8T AUA) |
| Mariner Wealth | Leonard Green | Acquired AndCo Consulting |
| Wealth Enhancement | TA Associates | 17 deals in 2025 |
| Merit Financial | Bain Capital | 13 deals in 2025 |
Nearly all top acquirers are PE-backed. The playbook is consistent: acquire a platform, execute roll-ups, centralize the investment function under a CIO, push affiliated products across the client base, grow EBITDA, and exit in three to seven years.8
The advisor in your committee meeting may still be the same person. But they’re now operating inside a structure designed to generate returns for PE investors on a defined timeline.
What Happens After the Acquisition
A Scenario Playing Out Across the Country
A mid-sized manufacturer works with the same advisor for eight years. Strong relationship. Then the committee chair gets a letter: the firm has been acquired by a national platform. Nothing will change, it says.
Over 18 months, a colleague gets reassigned. Investment reviews come from a centralized team the committee has never met. A new alternatives allocation appears. The committee asks about it and is told it’s the platform’s house view. In some cases, committees may not have full visibility into ownership-related economic interests.
The 408(b)(2) disclosure still shows the same fee. But the advice behind it has changed.
A fair point before I go further: PE involvement isn’t automatically bad. Private equity can bring capital, technology, and succession solutions to firms that need them. Some PE-backed platforms maintain strong fiduciary cultures.
The issue is that PE ownership introduces structural incentives and potential conflicts that didn’t exist before, and most plan sponsors aren’t aware of them.
What Research Shows in Other Industries
Healthcare: A 2023 BMJ review of 55 studies found PE ownership most closely associated with cost increases to patients and payers (up to 32%) and mixed-to-harmful effects on quality. A JAMA study of 578 PE-acquired practices found charges rose 20% and allowed amounts rose 11%.9,10
Nursing homes: An NBER study of 7+ million Medicare patients found 10% higher mortality at PE-owned facilities, an estimated 20,150 excess deaths over 12 years. Frontline staff fell 3%. Medicare spending per stay was 11% higher.11
Veterinary medicine: PE firms invested $51 billion in vet services from 2017–2024. Consolidators now control 30–50% of U.S. clinics. Vet prices rose 32% from 2020 to 2024. Vets report pressure to upsell and meet revenue quotas.12
These patterns don’t guarantee the same outcomes in retirement plan advisory. But they’re worth considering when evaluating whether a change in advisor ownership warrants closer scrutiny.
How Consolidation Undercuts Transparency
The 408(b)(2) disclosure tells you what your advisor charges. It doesn’t tell you who profits after those charges flow through a PE-backed platform’s corporate structure. It won’t show you:
- Management fees the advisory firm pays to its PE sponsor
- Debt service on the leveraged buyout that financed the acquisition
- Revenue the PE sponsor earns from affiliated alternative investments your advisor now recommends
- Whether your advisor’s compensation is tied to platform revenue targets rather than your plan’s outcomes
408(b)(2) was built for a world of disclosed, direct compensation. It wasn’t built for a world where the real economics sit two or three ownership layers above the advisor.
As the industry consolidates, sponsors in smaller markets may find that every advisor in their RFP pool is owned by the same handful of PE firms. That looks like competition on paper. In practice, the range of truly independent options is narrowing.
Chicago Teachers’ Pension Fund, April 2026
The Chicago Teachers’ Pension Fund backed out of hiring Cerity Partners as its investment consultant after Cerity’s acquisition of Verus Advisory raised concerns about PE ownership conflicts (Genstar Capital). The trustees concluded the ownership change materially altered the firm they’d evaluated.13
A $14 billion pension fund caught this. Would your committee?
Where This Is Heading
Fewer independent firms. About 37–38% of advisors plan to retire in the next decade, representing roughly 40% of industry assets. Most don’t have succession plans. PE platforms are the best-capitalized buyers.14
Advisory firms as distribution channels. The Cerity/Verus and Hightower/NEPC deals signal the endgame: platforms that combine advisory relationships with proprietary investment product distribution. When your advisor’s parent company earns revenue from the alternatives allocation they’re recommending, the nature of the advice has changed.15
A heavier burden on plan sponsors. Without effective regulation, the work of identifying and managing advisor conflicts falls on your committee. ERISA has always required this. What’s changed is the complexity.
Potential litigation exposure. As PE-backed platforms push affiliated products into plan lineups, the same litigation infrastructure that drove costs down after 2012 may reach these new conflicts. Committees that haven’t evaluated their advisor’s ownership could face questions about whether their process was as thorough as it should have been.
Conclusion
Our industry spent a decade earning transparency. Fee disclosures forced hidden compensation into the open. Competition drove costs down. Litigation gave accountability consequences.
Now, PE consolidation is concentrating advisory power into fewer hands and reintroducing the kinds of conflicts those reforms were designed to eliminate. It’s happening at the exact moment when regulatory oversight is at its weakest in a generation.
Understanding who owns your advisor, and what that ownership means for the advice you receive, should be part of every committee’s governance process. It’s a question worth asking. And the answer matters.
About Lebel & Harriman Retirement Advisors
Lebel & Harriman has served as a fiduciary advisor to retirement plan sponsors for over 45 years. We’re not owned by a private equity firm, a bank, or an insurance company. We don’t earn revenue from affiliated investment products. We advise 250+ ERISA retirement plans representing over $6 billion in assets.
If your committee has questions about how industry consolidation affects your plan, we’d welcome the conversation.
Nate Moody, CPFA | Senior Financial Advisor & Partner | Lebel & Harriman Retirement Advisors | nmoody@lebelharriman.com
1 DOL Final Rule, ERISA Section 408(b)(2), 77 FR 5632, February 3, 2012.
2 ICI, The Economics of Providing 401(k) Plans: Services, Fees, and Expenses, 2024. July 2025.
3 BrightScope/ICI, Defined Contribution Plan Profile: A Close Look at 401(k) Plans. 2019, 2025 editions.
4 Mayer Brown, Excessive Fee Litigation Tracker, 2023–2025.
5 Federal Register; CNBC, March 30, 2026; 401k Specialist, March 2026.
6 DeVoe & Company, RIA M&A Deal Books, 2018–2025.
7 ECHELON Partners, RIA M&A Deal Report, Q3 2025; Dakota, The State of the RIA Market: 2025 Year-End Review.
8 Dakota; InvestmentNews; PLANADVISER; public filings.
9 Borsa, A., et al. Evaluating trends in PE ownership and impacts on health outcomes, costs, and quality: systematic review. The BMJ, 2023.
10 Singh, Y., et al. Association of Private Equity Acquisition of Physician Practices With Changes in Health Care Spending and Utilization. JAMA Health Forum, 2022.
11 Gupta, A., et al. Does Private Equity Investment in Healthcare Benefit Patients? Evidence from Nursing Homes. NBER Working Paper 28474, 2021.
12 PitchBook; BLS Consumer Price Index; U.S. Senators Warren and Blumenthal, Letter to JAB Holding Company, August 2024.
13 Pensions & Investments, “Chicago Teachers rejects Cerity Partners over Verus merger, PE concerns.” April 9, 2026.
14 McKinsey & Company; Cerulli Associates. As cited in multiple 2025 industry reports.
15 Dakota, The State of the RIA Market: 2025 Year-End Review. December 2025.
This white paper is provided for informational and educational purposes only and should not be construed as legal, tax, or investment advice. The observations and data presented reflect publicly available information and third-party research as of the date of publication. Plan sponsors should consult with their ERISA counsel and other professional advisors regarding their specific fiduciary obligations.
Securities offered through Valmark Securities, Inc. Member FINRA/SIPC. Advisory services offered through Valmark Advisers, Inc., a SEC-registered investment advisor. Lebel & Harriman Retirement Advisors is a separately owned entity from Valmark Securities, Inc. and Valmark Advisers, Inc.
