Can a Plan Have a TPA, a Plan Administrator AND a 3(16)?
Yes — all three can serve the same plan at the same time. They do not perform the same role or accept the same level of responsibility. Here is how the roles differ, and how to tell what your company is still responsible for.
Can a Plan Have a TPA, a Plan Administrator AND a 3(16)?
Yes. A retirement plan can have all three involved at the same time. They may work together, but they do not necessarily perform the same role or accept the same level of responsibility.
TPA — Technical & Administrative Services
The Third-Party Administrator (TPA) may perform technical services such as compliance testing, calculations, plan document support and Form 5500 preparation.
The TPA can do significant work for the plan without becoming the party legally responsible for administering it.
Plan Administrator — The ERISA Role
Every ERISA plan has a Plan Administrator as defined under the plan and ERISA. The Plan Administrator is the person or entity designated to hold the administrative role and its associated responsibilities.
Depending on how the plan is structured, that may be the employer or an outside professional appointed to serve in that capacity.
3(16) Fiduciary — Accepts Delegated Administrative Fiduciary Responsibilities
A provider offering 3(16) fiduciary services may accept specifically delegated administrative fiduciary duties. However, not every 3(16) engagement is the same.
A limited-scope 3(16) may accept responsibility for only certain functions, while another provider may be appointed as the Plan Administrator and accept a much broader scope of administrative fiduciary responsibility.
That's Why You Can See All Three on the Same Plan
For example, a plan could have:
TPA
Performs testing, calculations and technical administration.
Plan Administrator
Holds the formal Plan Administrator role under the plan.
3(16) Fiduciary Provider
Accepts specifically delegated administrative fiduciary responsibilities under its agreement.
These roles can work together. But here's what matters:
Having more providers does not automatically mean the employer has less responsibility. The answer is found in the plan documents, fiduciary appointments and service agreements.
The Admin316 Difference
Admin316's model is designed to simplify that structure.
We Don't Just Help Your Plan Administrator. We Can Become Your Professional Plan Administrator.
When properly appointed, Admin316 can serve as the Professional Plan Administrator and accept the administrative fiduciary responsibilities delegated to us.
Other specialists can continue serving the plan.
| The specialist | What they keep doing |
|---|---|
| Your TPA | Performs the technical work. |
| Your recordkeeper | Maintains the records. |
| Your advisor or 3(38) | Oversees the investments. |
| Your payroll company | Processes payroll. |
| Your auditor | Audits the plan. |
| Admin316 | Manages the administrative fiduciary responsibilities assigned to us. |
The goal is not to add another vendor. The goal is to clearly establish responsibility.
Don't Count Providers. Follow the Responsibility.
A plan could have:
- A TPA.
- A Plan Administrator.
- A 3(16) provider.
- A recordkeeper.
- An advisor.
- A payroll company.
- An auditor.
And the employer could still retain significant responsibilities.
“After I sign all of these agreements, what am I still responsible for?”
Don't assume. Read the agreements. Follow the responsibility.
You Focus on Your Business. We'll Manage Your 401(k).
Our goal is to make the structure clear. You retain three core areas:
Settlor Responsibilities
You make the employer's business decisions regarding the plan.
Timeliness of Contributions
You make the required funds available timely.
Accuracy of Census & Payroll Data
You provide complete and accurate information.
Admin316
We accept and manage the administrative fiduciary responsibilities delegated to us under our agreement.
We coordinate with the other specialists serving your plan and can provide monthly, quarterly, semi-annual or annual Plan Health Checks so you remain informed without having to manage the plan every day.
You focus on your core business. We'll manage your 401(k).
Transfer the Responsibility. Not Just the Work.
Common Questions
Does hiring a TPA make the TPA legally responsible for administering my plan?
Not by itself. A TPA can perform substantial technical work — testing, calculations, document support, Form 5500 preparation — without becoming the party legally responsible for administering the plan. Responsibility follows the plan document, the fiduciary appointments and the service agreement.
Can my company still be the Plan Administrator if we hire a 3(16)?
Yes. Many 3(16) engagements are limited in scope, and the employer remains the Plan Administrator under the plan. Another structure appoints an outside professional as Plan Administrator with a much broader scope of accepted responsibility.
Are all 3(16) services the same?
No. A 3(16) title does not tell you how much responsibility a provider has actually accepted. The scope is defined in the agreement, not by the label.
Do we have to replace our current providers to work with Admin316?
No. Your TPA, recordkeeper, advisor or 3(38), payroll company and auditor can continue serving the plan. Admin316 manages the administrative fiduciary responsibilities delegated to us and coordinates with them.
What does the employer still keep?
Settlor (business) decisions about the plan, making required funds available timely, and providing complete and accurate census and payroll data.
How do we find out what we're still responsible for today?
Have your current service agreements reviewed. We'll compare what your agreements say against what a delegated administrative fiduciary structure would look like, and show you the difference in writing.
This page is educational and is not legal, tax or investment advice. Fiduciary roles, scope and responsibility depend on your plan document, fiduciary appointments and service agreements. Admin316's responsibilities are those specifically delegated to and accepted by Admin316 in writing.
Find Out What Your Retirement Plan May Be Missing
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Compare My Current Service Agreement
Send us your current TPA, recordkeeper and 3(16) agreements and we'll come back with a plain-English read on what has actually been delegated — and what your company is still responsible for after every agreement is signed.
Schedule a 15-Minute Fiduciary ReviewFifteen minutes, no cost. We'll walk through who holds each role on your plan today — TPA, Plan Administrator, 3(16) — and where the responsibility actually sits.
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