Where this starts
What we know
We find employers whose 401(k) plan shows a problem on its own public filing, write to the owner, the CFO and HR about that problem, and book the meeting, the same way the pension and Section 125 systems do. The data, the emails, the booking and the follow-up are ours and work the same as the other two offers.
What is new
What is new is the service at the end of the funnel: advising an employer on its 401(k) is regulated investment advice, so the person who runs the meeting and takes over the plan has to be a licensed adviser (Series 65) working under a registered advisory firm, which is the one fact we did not have on the call. That means every option runs through a licensed advisor: under our own registered firm (option 1), under a host firm's registration (option 1.5), or under the advisor's own firm (option 2). The plan then pays that firm a yearly fee on its assets, and the three options below are three ways of splitting that fee; the map that finds the employers is the same in all of them.
The machine, end to end
- Pull the filingsThe DOL publishes every 401(k) plan's Form 5500: participants, assets, fees paid, who services the plan (Schedule C), late deposits and corrective distributions.
- ClassifyEvery employer lands in one campaign by size, fee level and pain flags. A score orders the list so the best prospects are written to first.
- Write to three peopleCEO, CFO and HR. Day 1, day 8, day 15, in one thread. Then a 60 day gap and a new reason to write. Three passes a year at most.
- BookReplies go to a calendar. The meeting is a review of their own plan, built from their own filing: fees against the benchmark, fund lineup, fiduciary setup.
- A licensed advisor closesThe advisor runs the meeting, proposes the fix, and signs on as the plan's advisor of record (an ERISA 3(21) co-fiduciary or 3(38) manager).
- Fees flowThe plan pays the advisor's registered firm a fee on assets, every year the plan stays. That firm splits the fee according to whichever option below is in force.
The market, counted
From the DOL's 2025 plan-year files, dated 25 October 2026 and counted on 5 November: the same files and the same filters the campaign map uses, so the two pages agree. Plan year beginning in 2025, single employer, not union, not a final filing, US address, one plan per company.
| Plan size (participants with a balance) | Employers | What it means |
|---|---|---|
| Under 50 | 627,498 | Most are too small to pay an advisor $30,000 a year. Not the market for this offer. |
| 50 to 99 | 54,715 | Mostly short-form filers. Less detail, but still assets, late deposits and corrective distributions. |
| 100 to 249 | 29,983 | Full Form 5500 with Schedule C, so fees and every service provider are visible. The core of the map. |
| 250 to 499 | 11,404 | Same detail, bigger fees. A CFO is usually in the room. |
| 500 to 999 | 6,200 | Same detail. A benefits manager owns the decision and a consolidator is often already the advisor. |
| 1,000 and above | 6,793 | Committee buying, formal RFPs, two year cycles. Out of scope for cold email. |
The working market is the 50 to 999 band: 102,302 employers, the number the campaign map works from, of which 44,310 file the full Form 5500 with fee and provider detail (the rest file the short form). 98.6% run a calendar plan year, so their filings are due 31 July or 15 October on extension; the July and October filing waves are the natural clock. 12.9% of the market reported a late deposit of employee money on the 2025 filing, and 22.3% of full-form filers reported corrective distributions, which is what a failed nondiscrimination test looks like on paper.
What a year looks like, on Morgan's numbers
The illustration every option below uses20,000 companies emailed once, one pass each. A 1% reply rate gives about 200 replies. About 30% of those book, about 60 meetings. One in three signs, about 20 plans. Each plan pays the advisor's firm about $30,000 a year, so year one's plans are worth about $600,000 a year in fees, and they keep paying each year they stay. In year two the first year's plans renew and a second 20 arrive.
That $600,000 is an annual rate, not first-year cash. The 20 plans sign through the year, so a plan signed in December pays almost nothing in year one. If the average plan is on the books for six months of year one, cash received is roughly $300,000 before costs and splits, and the exact figure depends on billing dates. Every option below shows both numbers, and every figure for our share is revenue before operating costs: sending domains and inboxes, enrichment, sequencer seats, compliance, and the people reading the replies. Keeping 80% of the fee is not 80% profit.
The 1% reply rate is a deliberate placeholder, the same one the pension and Section 125 maps use, to be replaced once the campaign has 20 of its own events behind it. $30,000 a year is roughly what a $10 million plan pays: the 2025 Fi360 benchmark puts median advisor fees at 35 basis points on a $5 million plan and 17 on a $25 million plan.
The moving parts
| Part | What it is | Same in every option? |
|---|---|---|
| Data and map | The Form 5500 pull, the segments, the flags, the score and the copy. | Yes. Finding the companies is identical in all three. |
| Sending brand | Whose name is on the email, the signature and the website. | No. Ours in options 1 and 1.5, the advisor's in option 2. |
| License holder | The registered investment adviser (RIA) that is legally responsible for the advice. | No. This is the real difference between the three options. |
| The advisor | The Series 65 person who runs the meeting and services the plan. | Same role, different employer. New advisors in 1 and 1.5, established ones in 2. |
| Booking | The calendar the reply templates point to, and the site behind it. | Ours in 1 and 1.5, the advisor's in 2. |
| Money flow | Who invoices the plan and how the fee is split. | No. 80%, about 65%, or fixed fees plus a 20% share. |
| Contracts and data | Who owns the clients, and who owns the response data the campaigns produce. | No. Every contract should keep the data rights with us. |
The three options at a glance
| 1: Own RIA | 1.5: Under a host RIA | 2: Fees plus share | |
|---|---|---|---|
| Our share of the fees | 80% | about 65% | 20% share plus fixed fees |
| Cash in month one | $0 | $0 | $50,000 per advisor |
| Revenue rate from year one's plans, before operating costs | about $480,000 | about $390,000 | about $230,000 per advisor (fixed fees plus the share) |
| Cash received in year one, before operating costs | about $240,000 | about $195,000 | about $170,000 per advisor |
| Year two, annual rate | about $960,000 | about $780,000 | $60,000 fixed plus a growing share |
| Who owns the clients | Us | Us, if the contract says so | The advisor |
| Time to launch | One to three months | Weeks | Weeks |
| Setup effort | Moderate | Light | Light |
| Main risk | Compliance and legal exposure sit with us | Depending on the host | Building the advisor's asset, not ours |
The options are not rivals. They stack. Start with option 2 and one advisor: the cash pays for the system and proves the conversion rates on real replies. Add option 1.5 once the numbers are real, so our own brand starts collecting its own client book without the setup load. Move to option 1 when the book is big enough that the host's cut costs more than running the firm ourselves; the clients come across under the portability clause. In every contract, the data rights stay with us.
Option 1: We own the advisory firm and keep 80%
We set up and own a registered investment adviser under our own brand. We run the whole system: the Form 5500 data, the emails, the website and the booking. Licensed advisors work under our firm and do the regulated 401(k) work for 20% of the fees. We keep 80%, and we own the client book, which is the most valuable long-term asset in any of the three options.
- Revenue rate, year one's plans
- about $480,000 a year, before operating costs
- Cash received in year one
- about $240,000
- Year two
- about $960,000 a year; about $720,000 cash
- Cash up front
- None
20 plans at $30,000 is $600,000 a year in fees; 80% of that is $480,000. Plans sign through the year, so year-one cash is about half the rate. Year two collects a full year from the first 20 and about half a year from the next 20. All of it is revenue before operating costs.
What it takes
- Texas registration. Filed through the IARD system with Form ADV Parts 1 and 2 (the brochure), a fee schedule, the advisory contract, a balance sheet and the formation documents. The state fee is $75 for the firm and $35 per representative. Texas requires no bond and no capital minimum; the firm has to be solvent. Confirm the current figures with the State Securities Board before filing.
- One person with a Series 65. Texas wants a designated officer who has passed it. That can be the advisor or one of us.
- A compliance consultant. A few thousand dollars to set up the ADV, the policies and the code of ethics, then monthly support. Errors-and-omissions insurance is standard for a firm advising retirement plans.
- One to three months from filing to approval, with the website and copy reviewed as advertising before anything is sent.
- The firm carries the legal responsibility for every plan it advises. That is the price of the 80%.
Who the advisor is. Newer licensed advisors with time and few clients. For them, 20% of fees on clients they did not have to find is a good deal, and they do not bring a book that complicates ownership.
Best for the long game, once we know the conversion numbers.
Option 1.5: Our brand under a host firm, keeping about 65%
We own the brand and the client pipeline but do not build an RIA. We work under an existing registered firm, or a platform that lends out its registration and compliance team. The host provides the license, the compliance review, the insurance and the back office. Our advisors, and at least one person on our side, register under the host. The host keeps a cut of the fees, commonly 10 to 20%, and it is negotiated.
- Revenue rate, year one's plans
- about $390,000 a year, before operating costs
- Cash received in year one
- about $195,000
- Year two
- about $780,000 a year; about $585,000 cash
- Cash up front
- None, and almost no setup cost
Assumes the host takes 15% and the advisors take 20%, leaving us about 65% of $600,000 a year. Year-one cash is about half the rate because plans sign through the year. Revenue before operating costs.
What it takes
- The right host. It needs to understand 401(k) plans and be open to an outside brand sending under its registration. Not every RIA platform is.
- Someone on our side with a Series 65, registered under the host, so our share can be paid as advisory compensation rather than as a referral fee.
- A portability clause. The contract has to say, in plain words, that the clients move with us if we later start our own firm. This is the most important sentence in the deal.
- The host's compliance desk approves the emails and the website, because under its registration they are its advertising.
Who the advisor is. The same profile as option 1: newer, licensed, hungry, happy with 20% of fees on clients handed to them.
Best for getting option 1's model live in weeks instead of months, without carrying the compliance load ourselves.
Option 2: The engine behind an advisor's own firm
We build and run the system under an established advisor's firm and brand. The advisor pays $50,000 to set it up, $5,000 a month to run it, and a share of the fees on the plans we bring in. The advisor owns the clients. We are the engine behind the scenes, and nothing changes in the map except the name on the email and the calendar the replies point to.
- Fixed fees, year one
- $110,000 per advisor
- Share, annual rate at year end
- about $120,000 per advisor
- Cash received in year one
- about $170,000 per advisor, before operating costs
- With two or three advisors
- about $350,000 to $500,000 cash in year one
$50,000 setup plus twelve months at $5,000 is $110,000 in fixed fees, paid as billed. A 20% share of $600,000 a year is about $120,000 a year once all 20 plans are on the books; in year one about half of it arrives, so about $170,000 in total, before operating costs. Each extra advisor gets a separate territory so two advisors are never emailing the same company.
What it takes
- A marketing services agreement covering the build fee, the retainer, the share, the territory and the data rights.
- A compliance check on the revenue share. Paying for referrals to an adviser is a paid endorsement under the SEC Marketing Rule: a written agreement, disclosure to the prospect, and oversight by the advisor's firm. In most states, anyone who solicits advisory clients for a share of the fee also has to register as a representative of that firm, which is the Series 65 again. The fixed fees are the clean part; the share is the part the lawyer has to design.
- Separate territories, cut from the master list by state or metro, so each advisor's map is a filtered slice of the same whole.
- The advisor's compliance approves the copy, since the emails go out under their name.
Who the advisor is. Established 401(k) advisors with money, a book of plans and a reason to grow faster. $50,000 up front is above the going rate for appointment setting, so the pitch is the data: a list built from their own prospects' filings, not a bought list.
Best for cash from day one and proof that the system converts, before we put our own name on it.
Potential prospects
Eight small retirement-plan advisory firms that could be the licensed partner: the advisor whose firm the emails go out under in option 2, or the first advisors to sit under our own or a host firm in options 1 and 1.5. The list came from a research pass scored against Morgan's framework of 30 October: what one deal is worth, what it costs to deliver, how fast it closes, whether the firm is already growing, whether delivery can scale past the founder, what sales process exists today, whether the client can pay our fee and still make money, and what the biggest unknowns are. Every figure below was then checked against public records on 4 and 5 November, and the first pass was corrected where the records disagreed. Nobody has been contacted.
| # | Firm | Size, from the latest public filing | What a plan pays them | Growth evidence | Capacity | Fit with the model | Can afford $50K plus $5K a month |
|---|---|---|---|---|---|---|---|
| 1 | Freedom Fiduciaries Boise, Idaho | About $585M, 124 accounts, so about $4.7M a plan. SEC-registered April 2024. Two to five people depending on the source; six at launch. | Asset-based and fixed fees, negotiable; no schedule published. At $4.7M a plan, roughly $10,000 to $25,000 a year. | The strongest on the list, and the only hard evidence of it: launched August 2023 with about $200M, $585M two years later, plus a pooled employer plan (Fiduciary Freedom, with Empower) and a "Bac(k) Office" service that takes 401(k) work from generalist advisors. | Built to absorb volume through partner advisors rather than the founder. | Already runs a partner model, so our system is one more channel into it. Owner-run: Shane Hanson holds over 75%. | Yes. |
| 2 | Legacy 401k Partners Grapevine, Texas | Texas state-registered since 2015. Three people: Patrick Stuhr (founder), Brad Grist (partner, compliance), Cesar Tovar. Reports no discretionary assets, which is normal for a consulting-only plan advisor; plan count and revenue are not public. | Not disclosed anywhere public. | None shown. The "registered its own RIA to control all aspects of the business" item is from 2015, not recent. | Unknown; three people and no stated plan count. | The textbook profile Morgan described: small, owner-run, 401(k) only, probably referral-driven, and in the Dallas area, so it can be met in person. Ambition is inferred, not shown. | Unknown. The first pass estimated about $1M in revenue; nothing public supports a figure. Better suited to a lower upfront fee. |
| 3 | Fiduciary Pension Partners Westfield, New Jersey | The firm says over $1.5B advised for more than 100 plan sponsors; aggregators put it near $2B. About six employees, two or three advising. NAPA Top DC Advisor Team six years running (2021 to 2026). | Asset-based. At $15M or more a plan on average, a typical plan is worth $40,000 a year or more to them: the best deal economics on the list. | Steven Puckett was a PLANADVISER 2025 Top Retirement Plan Adviser; the firm runs a participant video channel and a monthly newsletter. The "AI tooling" claim could not be verified. | Six people delivering a high-touch service; a limit on how many new plans a year. | Puckett is the clear face. Ownership is not disclosed, so whether it is owner-run is an open question. | Yes. |
| 4 | Retirement Planology Alexandria, Virginia | $266M in 63 accounts, about $4.2M a plan; $204M discretionary at the end of 2024. Three people. Founded 2014 by Courtenay Shipley, who also chairs the Retirement Advisor Council's board. | The only published schedule on the list: flat $5,000 to $250,000 a year, or 0.05% to 0.55% of assets, $3,500 minimum, hourly available. Most plans pay $10,000 to $20,000; the larger ones $25,000 and up. | Steady, not fast: twelve years to $266M. One standing job posting for a planologist (sales and service, DC area); the "two roles" in the first pass is not supported. | Three people serving 63 plans: close to full. | Owner-led and 401(k) only, with a published fee that makes the economics easy to model. | No, on an estimated $0.6M to $0.9M of revenue. Revenue share only. |
| 5 | RPS Retirement Plan Advisors Austin, Texas | $336M, three to five people, SEC-registered 2022. A wholly owned subsidiary of Richard P. Slaughter Holdings, sister to a 1991 wealth firm; the plan division dates to 2010. | Asset-based, fixed, and some commission and insurance brokerage on the filing, although the website says fee-only. A conflict to ask about. | Launched its own pooled employer plan in 2022; nothing public since. | Small team, and decisions run through the family holding company. | Own RIA, all retirement plans, Texas. Family-run rather than founder-run. | Marginal. |
| 6 | Fi401k Advisors Centennial, Colorado | Corrected from the first pass: $915M in 305 accounts (about $3.0M a plan) on a January 2026 filing, up from $787M in 491 accounts in the older figure the first pass used. Two advisers: Mark Gutrich (founder, who co-founded ePlan Services in 1999) and Hannah Gutrich. | A one-time implementation fee for small plans plus an annual percentage of assets billed quarterly; a 0.30% tier and a $2,500 minimum appear on the filing. | Assets are growing while the account count falls, so the book is consolidating into larger plans. | Two people with 305 plans: no room without hiring. Fails Morgan's "can delivery scale" test as it stands. | A strong payer that could not use the volume. | Yes, but cannot use it yet. |
| 7 | Smooth 401(k) Strongsville, Ohio | Not its own RIA: advice runs through LPL Financial's retirement plan program, with the team also appearing under Stratos Wealth Partners. Four advisers listed at the address; the "eight-person" figure could not be verified. Founder Brent Teague. | Not disclosed. Start-up and pooled plans, so fees start small and grow slowly; deal size below $25,000 for years. | Real: 19 plans in its first year with Vestwell, and a NAPA Top DC Advisor Team listing in May 2026. | Part of a larger wealth practice. | LPL compliance approves everything, and Stratos bought eleven partner firms in May 2026, so who decides is unclear. | Unlikely. |
| 8 | Southbridge Advisors Marietta and Duluth, Georgia | $353M, six employees, SEC-registered 2019. Retirement plans are about a third of its clients; the first pass's $113M in plan assets is a derived estimate, not a disclosed figure. | Asset-based, scaling down with size; flat planning fees for individuals. | None public on the plan side. | Five partners, two offices. | A wealth firm first. George Richerson leads the plan side; no single owner (Jerold Sniderman is managing partner among five). | Yes, but a low priority for them. |
Why this order
Morgan's framework prefers businesses already showing meaningful growth, and Freedom is the only one with hard evidence of it, plus a delivery model that scales without the founder doing every plan; it stays first. Legacy fits the profile Morgan described better than anyone (a few capable people, a founder, referral-based, no outbound system) but everything beyond that is inferred, and the framework's rule is to verify ambition directly with the owner; it stays second as the one to sit across a table from. Fiduciary Pension Partners is third on deal economics: at its plan sizes, one or two wins pay for the whole system. Retirement Planology is fourth because its own published fees show most plans paying under $25,000 and three people already serving 63 of them, which argues for a revenue share rather than $50,000 up front. The verification did not change the order; it changed three numbers (Freedom's account count, Fi401k's size, Southbridge's plan assets) and removed two claims (Planology's second hire, FPP's AI tooling).
One caution on the top pick
Shane Hanson also founded a separate software company, Viserly, in 2025, which was acquired by PlanSync AI in April 2026. That is evidence of the ambition Morgan looks for and also a claim on the founder's attention. He has said publicly he wants the right clients rather than more of them. Both points belong in the first conversation.
What only a conversation can settle
Three things the public record cannot show, which are exactly what Morgan's framework says to confirm in a discovery call rather than from research: the actual plan count and fee schedule (public for Planology and partly for Fi401k, not for the rest); whether the firm already runs outbound email or LinkedIn (no sign of it at any of the eight, which is an absence of evidence, not proof); and the owner's ambition (shown by growth at Freedom and by a standing job posting at Planology, inferred everywhere else). Two more that this brief adds: whether the firm's compliance desk, or LPL's in Smooth's case, will approve outside-written copy and a promoter agreement under the Marketing Rule, and who actually signs at RPS and Southbridge, where the owner is a holding company or a partnership. For the top two, the next step is a short discovery script built around those five items.
Twenty-two more, found in the filings
The eight above came from awards lists and press. These came from the data. Every full-form Form 5500 names the plan's investment adviser on Schedule C, so the market file itself says which firms already advise plans of 50 to 999 participants and how many. We took every firm named on 5 or more such plans that our classifier called independent (66 firms at 8 or more, 62 more at 5 to 7), dropped the broker-dealer platforms, banks and wirehouses, and sent the 56 best to a verification pass on 5 November. Twenty-seven turned out to be owned by someone else: CAPTRUST under another name, four Alera, Marsh McLennan, OneDigital, Focus Financial and U.S. Retirement Partners subsidiaries, five insurance-agency arms, a CPA-firm arm, a bank's adviser, three wealth platforms of $4B to $22B, and a managed-account fintech. Seven more were too large or too opaque. These 22 are what is left, ranked within this list by the same framework as the eight above: plan focus, ownership, size, growth, and whether the fee is realistic. "In our market" is our own count from the 2025 filings; the rest is from public records and is to be confirmed in the first call.
| # | Firm | What they are | In our market (2025 filings) | Why they fit | Watch | Can afford $50K plus $5K a month |
|---|---|---|---|---|---|---|
| 1 | Deschutes Investment Consulting Portland and Bend, Oregon | Founded 1997 by Mac Hall; about 12 people; a dedicated retirement plan services arm under Katrina Bell; 100-plus plans, median plan about $5M; a 2024 PLANADVISER award for participant service. | 13 plans, $323M, median $22.5M | The best profile on the list: founder-led, plan-core, in our exact market, and expanding (a Bend office opened May 2026). | Nothing material found. | Yes |
| 2 | Faircourt Partners Lake Bluff and Chicago, Illinois | Four people, registered 2018, employer plans only; about $3.1B of plan assets, up from $2.1B; a 2024 deal to give participants an AI texting assistant. | 25 plans, $517M, median $16.2M | Tiny, independent, 100% plans, growing fast. | Owners not confirmed in filings; confirm appetite for the fee. | Likely |
| 3 | PCA Investment Advisory Services Cincinnati and Dayton, Ohio | Advisory arm of Pension Corporation of America, a 1977 recordkeeper and TPA; partner-run (Zachary Burns, Mark Janszen, Seth Priestle); about $4.3B; hiring a CIO in 2025. | 27 plans, $632M, median $17.9M | Plan-centric, regional density in Ohio and Kentucky, clearly able to pay. | Recordkeeper affiliation; firm-wide headcount above 15. | Yes |
| 4 | First Light Retirement Del Mar, California | Father and son (Thomas and Tyler Wolfson), SEC-registered 2021, plan-only consulting, about 23 plan clients and $700M to $850M, no disclosures. | 6 plans, $149M, median $22.9M | Plan-pure, owner-run, growing about 25% between filings, with the fee base to fund the program. | Two people; capacity for new plans is the question. | Yes |
| 5 | Comperio Retirement Consulting Cary, North Carolina | Four or five people, retirement-only consulting, about $1.9B across roughly 38 institutional plans; an independent S-corporation led by Jim Sotell. | 5 plans, $112M, median $23.3M | Owner-run, plan-pure, right size, adequate fee base. | Its clients skew larger than our 50-to-999 band (about $50M a plan on average). | Yes |
| 6 | Fund Direct Advisors Greensboro, North Carolina | Stanley family firm (William and Charles Stanley), four or five people, about 70 plans and $560M, with a sister TPA, Stanley Benefit Services. | 10 plans, $201M, median $12.1M | Plans are the whole business; independent; in-band. | Budget likely a revenue share plus a modest retainer rather than $50K up front. | Marginal |
| 7 | Veery Capital Wilmington, Delaware | About 12 people, $740M to $800M, retirement plan services and financial wellness as the stated specialty; NAPA Top DC Team 2022; two senior hires in 2023. | 3 plans, $37M, median $13.2M | In-band, plan-focused, growing. | Founder and ownership not confirmed. | Yes |
| 8 | Abbey Street Eden Prairie, Minnesota | Started 2018, 12 or 13 people, eight advisers; two stated lines, corporate retirement plans and family wealth; $245M to $375M regulatory assets. | 10 plans, $381M, median $36.8M | Right size, young and growing, plans one of two core lines. | Owners not named in the filings searched; confirm budget. | Likely |
| 9 | Wellington Consulting Services Chantilly, Virginia | About 13 people, $1.2B to $1.7B across many small accounts, with an in-house recordkeeper (Wellington Retirement Solutions / Perfect401k); the Greers have run it 30 years. | 12 plans, $342M, median $12.8M | In-band, plan-centric, independent, revenue to pay. | Bundled product; confirm they want outside lead generation and who owns the firm. | Yes |
| 10 | Everhart Advisors Dublin, Ohio | Founder-led since 1995 (Scott Everhart), about 48 people, roughly 280 plans, $1.4B to $1.9B; bought a Dayton firm and signed a 2024 deal to grow to 75 staff by 2028. | 59 plans, $1.37B, median $16.8M | Exactly the profile except the size: plan-core, growing, owner-run, the largest footprint in our market of any independent here. | Three times the headcount band; a firm this size may want to own the system rather than rent it. | Yes |
| 11 | Accelerate Retirement Aliso Viejo, California | Spun out of NFP as an independent RIA; plan consulting only; CEFEX-certified; 31 to 36 advisers across about 13 offices; on the 2025 NAPA and PLANADVISER lists; hiring. | 30 plans, $864M, median $21.5M | Independent, plan-pure, growing fast, California-heavy, where our market is largest. | A multi-office adviser network, not a boutique; decision path unclear. | Yes |
| 12 | Newport Capital Group Red Bank, New Jersey | Founded 2004 by Domenic DiPiero and still principally his; 17 or 18 people; about $16B of plan assets across roughly 137 plans; PLANADVISER finalist three years running. | 12 plans, $975M, median $75.2M | An elite independent plan shop with budget to spare. | Its book is large plans (median about $120M); our market is downstream of its sweet spot. | Yes |
| 13 | Spectrum Investment Advisors Mequon, Wisconsin | Founded 1995 by James Marshall; succession to Manuel Rosado done in 2019; 22 to 27 people; plan sponsors (including a pooled plan) and individuals; three hires in 2025. | 33 plans, $911M, median $20.6M | Independent, plan-heavy, growing, the largest Wisconsin footprint in our data. | About 1.5 times the headcount band. | Yes |
| 14 | Human Investing Lake Oswego, Oregon | Founded 2004 by Peter Fisher; partner-owned; about 28 people and $2.2B; a dedicated workplace advisory division under Eve Bell. | 16 plans, $409M, median $20.1M | Independent, plan-literate, a strong brand in the Northwest. | Wealth is at least half the business; twice the headcount band. | Yes |
| 15 | Hays Financial Group Edina, Minnesota | Four registered advisers, 7 to 12 people, hybrid with LPL; pension consulting listed as a core service; a plan-heavy book. | 30 plans, $675M, median $19.1M | In-band size and one of the larger plan footprints in our data. | Thin public footprint; confirm ownership and how much LPL's economics bind it. | Likely |
| 16 | Twelve Points Wealth Management Concord, Massachusetts | Founded 2014 by Dave Clayman and partners; 25 to 29 people; $1.7B to $2.2B, roughly doubled; dedicated retirement plan analysts. | 20 plans, $598M, median $18.9M | Founder-run, growing, with plan staff in place. | Wealth-first; about twice the headcount band. | Yes |
| 17 | Stone Hill Fiduciary Management Great Neck, New York | Founded 2012 by Sheldon Geller; two or three people; plan-only 3(38) and named-fiduciary work across about 93 plans and $2.2B. | 15 plans, $339M, median $13.9M | Plan-pure, independent, with revenue to pay. | A very small team, and the founder's earlier firm drew a DOL inquiry in the 2000s; diligence first. | Yes |
| 18 | 401K Investment Professionals Waunakee, Wisconsin | Founded 2016 by Jason Marty; four advisers; plan-only, small and mid-market; 107 to 137 plan accounts, $215M to $311M. | 7 plans, $90M, median $15.7M | Exactly the focus and independence we want. | Fee base too small for $50K plus $5K a month; a revenue-share candidate. | No; revenue share |
| 19 | American Northwest Advisory Services Federal Way, Washington | Three to five advisers (Thomas Oakes and partners), fee-only, with an affiliated TPA of about 20 years; hiring a plan administrator in 2026. | 9 plans, $171M, median $14.2M | Perfect size and focus, with the TPA that makes implementation easy. | Revenue base looks too small for the upfront fee. | No; revenue share |
| 20 | Ballew Advisors Jackson, Mississippi | Founded 1991; about 11 people, six advisers, about $1B; family-owned through a holding company; Robert Rives leads the plan work. | 10 plans, $231M, median $13.5M | In-band size, independent, revenue to pay. | Wealth and plans mixed; no growth signal; a smaller home market. | Yes |
| 21 | Embree Financial Group Chicago, Illinois | Founded by Paul Embree; 18 or 19 people; $2.0B to $2.6B, up about 30% in a year; wealth plus plan consulting. | 11 plans, $319M, median $26.5M | Founder-run and growing, in the third-largest state in our market. | Wealth-first; slightly over the size band. | Yes |
| 22 | Venture Visionary Partners Sylvania (Toledo), Ohio | A 2019 UBS breakaway led by Craig Findley; about $4.3B; a retirement plan consulting team inside a wealth firm; acquisitive. | 16 plans, $431M, median $24.6M | Independent, growing, with a named plan team and a large median plan. | Wealth-first and 16 to 24 advisers; the plan team is not the decision maker. | Yes |
Three alternates cleared the ownership test but ranked below the 22: Kathmere Capital Management (Wayne, Pennsylvania; minority capital from Merchant), Stokes Family Office (New Orleans; family-owned, NAPA 2026 team, wealth-first) and Steele Capital Management (Dubuque, Iowa; fee-only, plans a side line). Two names from the filings could not be identified in any register and should be resolved from the CRD on the Schedule C line before any outreach: "401 K Advisors Inc" (California) and "Vision Wealth Partners" (Maryland).
What the two lists say together: the first eight are the firms other people have already noticed; these 22 are the firms already doing this work in our market, several of them in states where it is largest (Ohio, California, Illinois, Wisconsin, North Carolina). Deschutes, Faircourt, PCA and First Light would be the first four calls from this list; Freedom and Legacy stay the first two overall.
Figures for all thirty firms are from Form ADV aggregators and trade press, undated unless stated, and the aggregators disagree with each other on asset snapshots, so ranges are used. Plan counts "in our market" are from the 2025 Form 5500 Schedule C as counted by build.py. Revenue figures are estimates. Nobody at any of these firms has been contacted.