FMB Retirement Services

Based on industry-standard nomenclature for firms of this type, FMB likely provides third-party administration (TPA) services including plan design consulting, annual compliance testing (ADP/ACP, top-heavy, and 415 limit tests), Form 5500 preparation and electronic filing, participant statements, and plan-document drafting and amendments. For defined-benefit plans, this would extend to actuarial certification and funding-calculation schedules. The firm does not appear to offer bundled recordkeeping with proprietary investment products, which distinguishes it from insurance-company platforms.

Typically, a third-party administrator performing ministerial compliance testing and document services does not act as a functional fiduciary under ERISA Section 3(21). FMB's role is executing the plan sponsor's instructions for compliance purposes. The plan sponsor retains fiduciary responsibility for plan administration decisions, though the TPA can assume limited co-fiduciary duties if the service agreement explicitly designates such a relationship. Plan sponsors should confirm the specific scope in their administrative-services agreement.

Independent TPA firms generally charge on a per-eligible-participant basis or a flat annual retainer, with separate fees for non-routine services such as plan amendments, correction filings under the IRS Employee Plans Compliance Resolution System, or plan-termination processing. FMB's independence from any recordkeeping or investment platform means its fees are typically paid directly from corporate assets or deducted from participant accounts only with explicit sponsor authorization, avoiding the revenue-sharing opacity that complicates bundled provider arrangements.

While the firm's exact scope is not publicly detailed, independent TPA shops serving the small-to-midsize market commonly administer 401(k) plans (including safe-harbor designs), profit-sharing plans, cash-balance hybrid pension plans, and sometimes 403(b) plans for non-profit employers. Defined-benefit administration requires in-house actuarial credentials, and whether FMB maintains those in-house versus subcontracting actuarial work would determine its defined-benefit capacity.

No asset-management or recordkeeping affiliation is evident. Independent TPA firms like FMB typically select no investment lineup themselves—the plan sponsor or its investment advisor maintains full discretion over fund selection, while the TPA processes compliance data agnostically across recordkeeping platforms. This unbundled architecture removes the structural conflict present when an administrator also earns revenue-based compensation from affiliated funds appearing in the plan lineup, an arrangement subject to heightened disclosure scrutiny under ERISA Section 408(b)(2).

The American Society of Pension Professionals & Actuaries estimates there are approximately 3,500 independent TPA firms in the United States, heavily concentrated among sub-50-employee operations that rarely attract institutional capital. Consolidation has accelerated through acquirers like OneDigital and Hub International rolling up regional TPAs, but the long-tail fragmentation persists because plan-sponsor relationships are sticky and built on local trust. FMB appears to operate as one such independent shop in a market without a dominant national TPA brand.

The SECURE Act and SECURE 2.0 have materially expanded TPA-client workflows by mandating new plan-eligibility rules for part-time employees and introducing complex Roth catch-up contribution requirements for high earners starting in 2026. Every regulatory expansion increases compliance-testing complexity and amendment volume, which directly drives demand for outsourced administration. Additionally, IRS pre-audit pilot programs and Department of Labor cybersecurity guidance have added new service dimensions that independent TPAs must staff against.