COMPENSATION FORENSICS

The one line item you were never allowed to audit

What your broker actually earns — every dollar, every source, benchmarked against national norms and laid bare in black and white.

THE PROBLEM

49% of broker compensation is undisclosed

The direct commission you see on your invoice is only half the story. PBM overrides, carrier contingent bonuses, volume incentives, vendor referral fees — broker earnings have multiple revenue streams, most of them hidden from the plan sponsor.

The Broker Compensation Study documents every dollar, maps it to its source, benchmarks it against industry norms, and identifies conflicts of interest created by undisclosed payment structures.

Compensation Breakdown
Direct Commission (visible)$455K (51%)
PBM Override Commission$268K (30%)
Carrier Contingent Bonus$125K (14%)
Platform/Vendor Referrals$44K (5%)
Total Compensation$892K
Hidden (undisclosed)$437K (49%)

Based on actual Form 5500 filing: McKinsey & Company Inc. (18,423 participants)

FORENSIC ANALYSIS

Conflicts of interest documented

Every payment structure creates incentives. Some align with your interests. Most don't. We map them all.

PBM Commission Incentives

High

Overrides paid on pharmacy spend create pressure to preserve high costs rather than reduce them.

Carrier Loss Ratio Bonuses

High

Contingent bonuses tied to medical loss ratios disincentivize aggressive cost management.

Volume-Based Compensation

Medium

Tiered commission structures reward maintaining high premium levels over cost reduction.

Vendor Referral Fees

Medium

Undisclosed payments from recommended vendors create bias in procurement advice.

Platform Lock-in Revenue

Medium

Technology platform fees create incentive to preserve status quo rather than optimize.

Disclosure Gaps

High

49% of compensation undisclosed violates ERISA 408(b)(2) transparency requirements.

THE DELIVERABLE

What you receive

Total Compensation Breakdown

Every revenue stream documented: direct commission, PBM overrides, carrier bonuses, vendor fees, platform charges.

Conflict Identification

Material conflicts mapped to compensation structures — where broker incentives diverge from plan interests.

Market Benchmarking

Your broker's total compensation scored against DOL EFAST2 database — by participant count, plan type, industry.

Fiduciary Compliance Review

ERISA 408(b)(2) disclosure analysis — what was required, what was disclosed, what gaps remain.

Fee-Only Transition Plan

Roadmap to fee-only model with RFP language, cost projections, and expected savings timeline.

PDF + Excel Deliverables

Full report with executive summary, data workbook with all calculations and sources exposed.

Ready to Audit Your Broker Compensation?

Get forensic-grade compensation archaeology — direct fees, indirect comp, and Form 5500 cross-validation.