Whoever serves as a plan's 3(16) administrator needs records that show what happened, when, and who reviewed it. KinetiPlan's pilot build keeps payroll validation history, ledger discrepancies with resolution notes, compliance deadlines and Form 5500 readiness in one connected record that supports the people who carry the fiduciary role.
ERISA section 3(16)(A) defines the plan administrator: the person or entity named in the plan document, or the plan sponsor if no one is named. The plan administrator is a fiduciary and is responsible for running the plan day to day in line with the plan document and ERISA. Many sponsors keep this role. Others appoint an outside firm, often called a 3(16) administrator, to take on some or all of it under a written agreement.
The exact duties depend on the plan and the service agreement, but responsibilities commonly include:
Across all of these, the common thread is documentation. When a regulator, auditor or participant asks a question, the administrator needs to show the steps taken and the decisions made.
Fiduciary exposure often comes from small breaks in process: a payroll update that changes deferral data without anyone checking it against the census, a ledger difference that was fixed but never explained, or a filing deadline tracked in one person's calendar. Each is manageable alone. Spread across many plans and many payroll cycles, they become hard to evidence after the fact.
Sponsors and the TPAs who serve them want three things: fewer unexplained exceptions, a record of how each one was resolved, and a clear view of what is due next. That is what KinetiPlan is designed to support.
Every uploaded payroll file is validated against the plan census before it posts. Batch history records the file, source, pay date, received date, record count, exception count, total and status (received, validated, exception, posted or rejected), filterable by plan.
The pooled trust ledger lists each transaction with timestamp, plan, type, amount, allocations and status, filterable by status, type, plan and date, with CSV export. Manual adjustments are recorded as their own transactions.
Out-of-balance items open in an exception resolution center linked to the plan, sponsor, participant, payroll batch and ledger transaction. Staff document the corrective action in resolution notes, then approve or dismiss.
Deadlines for every plan across prior, current and next plan years, in filing, testing, contribution, notice and data categories. Overdue, due-in-30 and due-in-90 counts, filters by consultant, and an .ics subscription.
The compliance screen shows how many annual administration projects have Form 5500 prepared. Each project checklist includes tasks to prepare Form 5500 and schedules and to file through EFAST2, with assignee, due date and completion date.
Standard reports, including book of business, project pipeline, staff workload, recordkeeper mix and participant demographics, each export to CSV. Sponsor pages also hold dated interaction notes by category, including compliance.
Exceptions found at intake or in the ledger are the core of any audit trail. The 401(k) exception tracking guide walks through how they move from detection to documented resolution.
| Common 3(16) responsibility | What the pilot build supports today | What stays outside the software |
|---|---|---|
| Form 5500 filing and signing | Readiness tracking on the compliance screen; prepare and file tasks on each annual project; filing deadlines on the calendar. KinetiPlan generates Form 5500 and its schedules, routes the filing for signature and transmits it directly to EFAST2 after approval. | Review and approval stay with the TPA, and the plan administrator signs with its own EFAST2 credentials and remains responsible for the filing. |
| Participant disclosures and notices | Notice deadlines can be tracked on the compliance calendar. | KinetiPlan does not generate or send participant notices. |
| Timely deposit of contributions | Payroll batches record pay date and received date, and validated batches post to the ledger with pending ACH settlement shown. | KinetiPlan does not monitor or certify deposit timing against regulatory standards. |
| Distribution and loan oversight | Distributions and loan repayments are recorded as ledger transaction types. | Approval of distributions and loans stays with the plan administrator. |
| Plan records | Plan, participant, ledger, payroll, project and note records in one place, with CSV export. | Record retention policy and production hosting are agreed with each customer. |
KinetiPlan does not act as a plan administrator, does not take on a 3(16), 3(21), 3(38) or any other fiduciary role, and does not make fiduciary decisions. Fiduciary responsibility stays with the plan administrator and any fiduciaries appointed under the plan. The software is designed to help those people keep organized records and see what needs attention.
The pilot build runs on synthetic demo data and is not a generally available or certified production system. There are no live payroll or custodian connections today; payroll files are uploaded as CSV exports in ADP, Paychex, Gusto or generic layouts. AI features are planned only.
Under ERISA section 3(16)(A), the plan administrator is the person or entity named in the plan document, or the plan sponsor if none is named. It is a fiduciary role responsible for operating the plan. Sponsors can appoint an outside firm to take on some or all of these duties.
No. KinetiPlan is software. It does not take on 3(16) or any other fiduciary role, and fiduciary responsibility stays with the plan administrator.
Yes, under human approval gates. KinetiPlan generates Form 5500 and its schedules, and after TPA review and approval routes the filing to the plan administrator, who signs with its own EFAST2 credentials, before transmitting it directly to EFAST2. Responsibility for the filing stays with the plan administrator.
Payroll batches keep a validation history with statuses and exception counts, ledger transactions are filterable and exportable, and discrepancies are resolved with notes linked to the related plan, participant, batch and transaction.
The pilot build is designed for TPA staff, with team roles such as consultant, analyst, reviewer and administrator. A sponsor-facing view is not part of the pilot build shown today; sponsor access requirements can be discussed during a pilot.
General information only, not legal, tax or ERISA advice. Confirm plan-specific duties with qualified ERISA counsel.
We will show how a batch is validated, how a ledger discrepancy is documented, and where deadlines and Form 5500 readiness are tracked in the pilot build.