Fiduciary Forensic Audit System

5-Year Broker Compensation Auditor

Calculate, trace, and audit the hidden revenue, carrier overrides, and volume bonuses your broker received behind your plan's back from 2022 to 2026.

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Plan Parameters
Step 1: Input your general plan specifications to estimate standard broker margins and hidden override commissions.
Ready for legal document generation
Covered Employees (Lives)
350 lives
Small group - limited override data
Annual Premium/Spend
$3,500,000
$10,000/employee - Industry standard
Audit Readiness
67%
Employer Name
Ready
Covered Lives
Edge
Annual Premium
Standard
Nearly complete. Adjust remaining parameters for optimal forensic accuracy.

ERISA Fiduciary Liability Warning

Fiduciaries are personally liable for plan assets. Allowing unmonitored indirect broker commissions is a Class-I breach under ERISA Section 408(b)(2).

Total Direct Disclosed
$811,146
Standard PEPM/commission stated in service agreements.
Estimated Hidden Overrides
$2,158,296
Indirect overrides, persistency pools, and coalition spreads.
5-Year Aggregate Comp
$2,969,442
Cumulative direct & indirect compensation steered.
5-Year Ledger Projection (2022 - 2026)
Yearly trace of direct disclosed consulting fees vs indirect carrier bonus programs.
YearLivesDirect DisclosedIndirect OverridesHidden SpreadsTotal Yearly
2022350$147,000$243,600$121,800$512,400
2023357$154,438$268,350$129,205$551,993
2024364$162,053$293,879$136,806$592,738
2025371$169,844$320,188$144,601$634,633
2026378$177,811$347,276$152,591$677,678

Year Audit Spotlight: 2026

At 378 lives, standard disclosed broker fees are expected at $177,811, while hidden back-end revenue from carriers and prescription contracts represents another $499,867 in indirect steering.

Broker Override database
Search major consulting conglomerates to see typical indirect override contracts.
Preloaded Corporate Multipliers:
CAA Disclosure Request Draft
Copy or download a compliant legal request under ERISA Section 408(b)(2).
Date: June 15, 2026 To: [Broker/Consultant Representative Name] Brokerage House: [Brokerage Firm Name] RE: Formal Tri-Annual Request for Comprehensive Broker/Consultant Compensation Disclosure Pursuant to Section 202 of the Consolidated Appropriations Act (CAA) of 2021 Dear Broker Team, As the Plan Sponsor and Fiduciary of the Acme Enterprises Health & Welfare Plan, we are writing to formally request a complete, itemized, and certified disclosure of all direct and indirect compensation received, or expected to be received, in connection with services provided to our Plan over the last five (5) plan years (Plan Years 2022, 2023, 2024, 2025, and 2026). Under Section 202 of the CAA (amending ERISA Section 408(b)(2)(B)), covered service providers (brokers and consultants expecting more than $1,000 in direct or indirect compensation) are required by federal law to disclose all direct and indirect compensation to plan fiduciaries. Failure to provide this disclosure constitutes a prohibited transaction under ERISA, threatening our plan's qualified status and exposing our fiduciaries to personal liability. Please provide a detailed report within fifteen (15) business days containing: 1. All direct fees or commissions paid by the Plan or directly from employer premiums. 2. All indirect compensation received from insurance carriers, PBMs, stop-loss underwriters, or technology partners (including, but not limited to, override commissions, persistency bonuses, contingency bonuses, and volume tier payouts). 3. Any soft-dollar compensation, consulting agreements, or affiliate payouts received from any vendor steered to or currently serving our health plan. Please direct this certified response to the undersigned plan fiduciary. Sincerely, Plan Sponsor Fiduciary For the Acme Enterprises Health & Welfare Plan

Section 202 mandates that service providers must disclose direct/indirect broker commissions prior to contracts being executed or renewed. Send this certified document to initiate formal disclosures.

Suspect Secret Spreads or Carrier Kickbacks?

Most broker override commissions are never fully disclosed on standard Schedule A forms. Work directly with SiriusB iQ Data Sciences to perform an algorithmic Fiduciary Audit on every invoice and claim.

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