# 401(k) Prospecting for TPAs and Recordkeepers: What the Filings Show Your Seat

*FiduciarySignal — updated 2026-10-05. Canonical: https://www.fiduciarysignal.com/guides/401k-prospecting-for-tpas-and-recordkeepers*

401k prospecting software for TPAs and recordkeepers reads the same public record advisors use, the Form 5500, for a different seat. On 401(k) plans that file as large plans, generally 100 or more participants, Schedule C lists the service providers paid $5,000 or more from the plan: recordkeeper, administrator, advisor, auditor. Small plans file no Schedule C, so for most plans the filing shows size, design, and compliance answers but not the incumbent provider. FiduciarySignal adds a ranking of the plans in a territory most likely to make a winnable provider change, including the recordkeeper or administrator.

Source: [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), General Instructions and Schedule C instructions (read 2026-10-05).

A TPA does not sell the same seat as a plan advisor. A third-party administrator wants the administration: design, testing, compliance, the annual filing. A recordkeeper's sales and distribution team sells mostly through advisors, so its prospect list is half plans and half advisors. An audit firm wants the plans that must attach an accountant's report. All of them start from the same filing, and most prospect lists read it for the advisor's seat. This guide reads it for yours.

## What each seat needs from a 401(k) prospect list

| Your seat | What the filing shows you | Where it lives |
|---|---|---|
| Third-party administrator (TPA) | Plan type and feature codes, participant counts, assets, compliance answers; the provider roster on larger plans | Form 5500 line 8a; Schedule H, Schedule I, or the 5500-SF; Schedule C |
| Recordkeeper sales and distribution (wholesalers) | Which recordkeeper and which advisor a larger plan pays, side by side | Schedule C service codes |
| Plan auditor (IQPA) | Which plans file Schedule H, last year's opinion type, and the accountant's name and EIN | Schedule H, Part III |
| Actuary or DB-capable TPA | Defined benefit and cash balance plans, and the actuary-signed funding schedule | Line 8a codes 1A through 1I; Schedule SB |

## What Schedule C shows, and where it stops

Schedule C is the closest thing the industry has to a public provider roster. Per the [Form 5500 instructions](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), large plans file it when, among other triggers, any service provider received $5,000 or more, directly or indirectly, from the plan, with codes for the service and how it was paid. A plan files as large when it covered 100 or more participants at the start of the plan year; a defined contribution plan counts participants with account balances, and a plan between 80 and 120 may keep last year's category.

Two exceptions matter to a TPA. Payments made directly by the plan sponsor and not reimbursed by the plan are not reported, so an administrator the employer pays out of its own pocket will not appear. And a provider paid only through insurance fees and commissions listed on Schedule A is left off Schedule C. Source: [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), Schedule C, Who Must File (read 2026-10-05).

| Schedule C code | What the instructions call it | What it tells your seat |
|---|---|---|
| 10 | Accounting (including auditing) | The audit firm on a large plan |
| 11 | Actuarial | The actuary on a DB or cash balance plan |
| 13 and 14 | Contract Administrator; Plan Administrator | Where an administration firm can appear; read the name, not just the code |
| 15 and 64 | Recordkeeping and information management; Recordkeeping fees | The recordkeeping relationship and how it was paid |
| 26 and 27 | Investment advisory (participants); Investment advisory (plan) | The advisor relationship a wholesaler wants to see |

Now the limit, stated plainly. Small plans do not file Schedule C at all, and most plans are small. In the DOL's [Private Pension Plan Bulletin for 2023](https://www.dol.gov/sites/dolgov/files/ebsa/researchers/statistics/retirement-bulletins/private-pension-plan-bulletins-abstract-2023.pdf), about 734,900 of the roughly 836,800 private pension plans that filed had fewer than 100 participants, close to nine in ten. Their filings show size, design, and compliance answers. They usually do not show who administers the plan or keeps its records.

Per the [DOL's Private Pension Plan Bulletin for 2023](https://www.dol.gov/sites/dolgov/files/ebsa/researchers/statistics/retirement-bulletins/private-pension-plan-bulletins-abstract-2023.pdf), Tables A1 and A1(a), the roughly 102,000 plans with 100 or more participants held about $11.3 trillion of the $12.4 trillion in private pension plan assets.

So the market splits in two. On larger plans you can see the incumbent and plan around it. On smaller plans you qualify on size, design, and compliance, and learn who the incumbent is on the first call.

## A 5500 search process for TPAs

- **Draw the territory first.** The states or ZIPs you can serve, then the plan sizes your team prices well. A firm built for 30-life plans and one built for 2,000-life plans should not work the same list.
- **Qualify the design work on line 8a.** The plan characteristics codes describe the plan in the sponsor's own filing: 2J for a 401(k) feature, 2A for age/service-weighted or new comparability allocations, 2S for automatic enrollment, 1C for a cash balance formula. If you specialize in cross-tested or cash balance designs, start there.
- **Read the roster on larger plans.** Find the administration and recordkeeping codes on Schedule C and the names beside them: the incumbent you would replace, or the recordkeeper you would work alongside.
- **Read compliance answers as a conversation, not a verdict.** Late participant contributions and corrective distributions, which include refunds of excess contributions under the 401(k) and 401(m) nondiscrimination rules, sit on the sponsor's own filing. They tell you what to ask. They do not tell you who caused them, or that the sponsor is ready to move.
- **Read more than one year,** then bring a specific, checkable reason to the first call: a testing refund on last year's filing, a design worth revisiting, an answer worth a second look.

Source: plan characteristics codes (line 8a) and Schedule H line 2f, [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf) (read 2026-10-05). Pulling filings one plan at a time is covered in [Form 5500 search](https://www.fiduciarysignal.com/tools/form-5500-search).

## 5500 search for recordkeepers and their sales teams

For a recordkeeper's sales and distribution team, the advisor is as much a prospect as the plan. On larger plans, Schedule C shows both sides of that relationship, the recordkeeping provider and the investment advisory provider, paid by the same plan in the same year. Read across a territory and you can answer the questions a wholesaler's week turns on: which advisors here serve plans in our size band, and which platforms they already use.

Two cautions. Provider names change as firms merge and rebrand, so map names before you count. And a filing describes a past plan year, so treat every roster as a lead to confirm, not a fact to quote back to the sponsor.

## If you run a plan audit practice

The 401(k) audit requirement is written into the filing. A plan that files Schedule H, as large plans do, generally must engage an independent qualified public accountant and attach the report. Schedule H Part III records the opinion type (unmodified, qualified, disclaimer, or adverse), whether it was an ERISA section 103(a)(3)(C) audit, and the accountant's name and EIN. The 5500-SF can only be filed by a small plan exempt from the audit requirement. For an audit firm, that makes Schedule H a market map: the large plans in your region and who signed each one's last opinion. Source: [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), Schedule H Part III and Who May File Form 5500-SF (read 2026-10-05).

## Where FiduciarySignal fits for TPAs and recordkeepers

FiduciarySignal's own FAQ lists TPAs and recordkeeper wholesalers alongside financial advisors among the people it is built for. The **401(k) Report Card** grades any plan from its own Form 5500: administrative cost against genuinely comparable peers, participation, red flags, and the provider roster. The **Change Predictor** ranks the plans in a territory, by ZIP, radius, or state, by the odds of a winnable provider change — trustee, custodian, recordkeeper or administrator — back-tested against the next year's Form 5500 filings. For a TPA or a recordkeeper, that ranked list is about the seat you sell.

The limits: it is a work-the-top-of-the-list tool, strongest at the top of the ranking, with calibrated likelihoods rather than certainty about any single plan. It reads the same filings, so on small plans it shares their blind spot on the incumbent. And it is priced for a person, not a department: FiduciarySignal publishes $90 a month after a 7-day free trial or $900 a year, with up to two extra seats at $19.99 a month each, and CSV exports on the annual plan only. No enterprise plan is published, so a data feed for a whole sales organization is a different purchase. Terms are on [our pricing page](https://www.fiduciarysignal.com/pricing). Built on public DOL EFAST2 data; not affiliated with the Department of Labor.

## Related guides

- [Form 5500 Schedule C, Explained for Advisors: Service Codes, Indirect Compensation, and Who Has to File](https://www.fiduciarysignal.com/guides/form-5500-schedule-c)
- [How to Find the Advisor and Recordkeeper on a 401(k) Plan (Free, From the Form 5500)](https://www.fiduciarysignal.com/guides/find-401k-plan-recordkeeper-and-advisor)
- [Retirement Plan Prospecting Software: The Advisor-Side Category, Explained](https://www.fiduciarysignal.com/tools/retirement-plan-prospecting-software)

## Frequently asked questions

### What is the best 401(k) prospecting software for TPAs and recordkeepers?

The one that reads the filing for your seat: design codes and compliance answers for a TPA, the recordkeeper and advisor on each plan for a recordkeeper's sales team, Schedule H for an audit firm. Ask any vendor how it handles small plans, which file no Schedule C, and whether it ranks plans by likelihood of change or only lists them. A sourced side-by-side is in our [tools comparison](https://www.fiduciarysignal.com/tools/best-401k-prospecting-tools).

### How do TPAs get retirement plan leads?

Referrals from advisors and CPAs are one source; outbound built from public Form 5500 data is the other. The filing gives a TPA each plan's size, design codes, and compliance answers, plus the current administrator and recordkeeper on larger plans. TPA leads built that way cost nothing to assemble but take hours to qualify, which is where a ranking of plans likely to change administrators saves time.

### Can you see a plan's TPA or recordkeeper on its Form 5500?

On larger plans, often: Schedule C lists providers paid $5,000 or more from the plan, coded by service. Fees the employer pays directly, without reimbursement from the plan, are not reported, so an employer-paid TPA can be missing. On small plans, generally no: Schedule C is required only of large plans, and the 5500-SF has none.

Source: [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), Schedule C, Who Must File (read 2026-10-05).

### Which plans need a 401(k) audit?

Generally, plans that file as large plans: a plan filing Schedule H must generally engage an independent qualified public accountant and attach the report. Large-plan status generally means 100 or more participants at the start of the plan year, with defined contribution plans counting participants who have account balances and an election for plans between 80 and 120. The 5500-SF is only for small plans exempt from the audit.

Source: [Instructions for the 2024 Form 5500](https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf), General Instructions and Schedule H Part III (read 2026-10-05).

### Does FiduciarySignal work for TPAs and recordkeepers?

Its FAQ lists TPAs and recordkeeper wholesalers among the people it is built for. The Change Predictor ranks the plans in a territory by the odds of a winnable provider change, including the recordkeeper or administrator, back-tested against the next year's Form 5500 filings and strongest at the top of the list. FiduciarySignal is priced per person at $90 a month after a 7-day free trial or $900 a year, with up to two extra seats at $19.99 a month each.

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