01
Low accountability
Brokers leverage commissions with little structural oversight.
Independent.
Accountable.
Aligned to you.
A benefit performance partner for self-funded employers, working with your advisors to make your plan to work harder.
The commissions problem
The stubborn challenge with broker commissions.
Commission-based compensation creates structural conflicts that quietly erode plan value year after year. These six patterns recur across nearly every plan we audit.
02
Hidden cross-product money
Compensation flows quietly across products and carriers.
03
Year-end forfeiture
Excess payments expire at year-end rather than returning to the plan.
04
Restricted spending
Funds locked into broker-controlled choices (think Kohl’s cash).
05
Inflated house pricing
Markups on in-house products go undetected without audit.
06
Fiduciary exposure
Incorrect Form 5500s create unflagged compliance risk.
Significant incentive misalignments. The broker’s pay grows when your plan’s costs grow.
The blind spot · Voluntary benefits
The real question:
How much are your vendors actually being paid?
Voluntary benefits are the most under-policed line in your plan. Accident, critical illness, hospital indemnity, pet, ID-theft, they show up as “no employer cost,” so finance never looks. Brokers know that. It’s where the richest commissions, overrides, and third-party payments hide.
Uncommon surfaces all of it. Every backend deal, persistency bonus, and rebate flowing to your broker, carrier, or enrollment vendor. So you can answer the tough questions confidently at renewal.
Voluntary benefits compensation map
Anonymized · Fortune 500 retail employer · Q1 2026
Product lineCommissionOverride / bonusFlag
Accident & critical illness40–60%$ undisclosedHigh
Hospital indemnity35–55%$ undisclosedHigh
Identity theft / legal25–40%rebateMed
Pet insurance15–30%rebateMed
Voluntary life / AD&D10–25%persistency bonusHigh
5 voluntary lines audited · accident, critical illness, hospital indemnity, ID-theft / legal, pet, voluntary life / AD&D
Total broker comp · voluntary lines
Disclosed in Form 5500: $94,000
Actually paid
$612,000
Fiduciary risk
Your broker isn’t a fiduciary. You are.
The exposure has always been there. What is changing is how visible it is, and how often plan sponsors are being asked to prove their fiduciary process. Most don’t realize that until they have to defend it.
01
Broker engagement letter
Almost every modern broker engagement letter explicitly disclaims fiduciary status. The language is usually in the first paragraph. Brokers aren’t fiduciaries because they’ve written themselves out of that responsibility on the page you signed.
02
ERISA
Names the plan sponsor, not the broker, as the responsible fiduciary. Your signature is on the 5500. The defense is yours to mount if the compensation flowing through the plan ever gets challenged.
03
DOL audits
The Department of Labor has expanded its audit focus on health and welfare plans following the Consolidated Appropriations Act. Plan sponsors are increasingly asked to produce documentation showing that broker and consultant compensation is reasonable. The standard hasn’t changed. The enforcement and the expected paper trail have.
What this looks like in court · December 2025
Schlichter Bogard came for the H&W side.
Schlichter Bogard, the firm that built 401(k) excessive-fee litigation, filed multiple ERISA class actions in December 2025. They named 4 Fortune 500 sponsors alongside the largest benefit consultnats. The complaints allege participants paid 30 to 600 percent above market on voluntary products such as accident, critical illness, and hospital indemnity lines. The plan sponsor as the fiduciaries had a duty to monitor that gap, but they didn't.
Alleged premium overpayment
30–600%
Premium overpayment alleged on voluntary benefit lines
For too long, your priorities have been secondary.
What we do
BAM, continuous fiduciary support, audit-first.
Benefit Asset Management
BAM is the engagement model. It exists to give the named plan fiduciary the visibility, documentation, and ongoing review the role actually requires. It is the part of the program your broker can’t structurally do for you.
01
3-week CTR
Pre-engagement audit. A per-vendor map of disclosed and undisclosed compensation, delivered before any longer-term commitment.
02
Quarterly oversight
Continuous monitoring of plan performance and vendor compensation. Quarterly reports your fiduciary committee can act on.
03
Plan optimization
Optimize commission flow, sharpen vendor scope, and improve the value each partner delivers.
04
AI-empowered
Form 5500 ingestion, PEPM industry benchmarking, anomaly surfacing across carrier statements. A human reviews every step.
For benefits leaders, CFOs, and General Counsel evaluating advisor risk
How BAM works →After the CTR
Two tiers, depending on the size of the commission footprint.
Tier 01 · BAM
Benefit Asset Management
Quarterly oversight. Continuous monitoring of plan performance and vendor compensation. Renewal preparation with no carrier overrides muddying the room. Documentation your fiduciary committee can act on.
Tier 02 · CMP
Commission Management Program
A right-sized alternative based on the size of your challenge. Same transparency, lighter scope. Offered after the CTR if a full BAM engagement isn’t the right fit.
How an engagement unfolds
From contract to clarity in under 30 days.
The Commission Transparency Report (CTR) typically lands within the first month, before you’ve signed any long-term contract.
Step 01
Document review
Plan documents, carrier contracts, broker engagement letter, 5500 filings, Schedule A and C disclosures.
Step 02
Carrier outreach
Formal information requests to each carrier asking for compensation disclosure.
Step 03
Reconstruction
AI-augmented reconstruction of disclosed numbers, reconciliation gaps, override agreements, and contingent commission triggers. Structured analysis, so no data points are missed. A human reviews every figure.
Step 04
Findings report
What we know. What we’ve estimated. What’s still opaque and why. The math, the source for each number, the methodology footnoted.
Independent thought leadership
The voice of truth in benefits.
Most consulting firms tell their clients the story they want to hear. We publish the one the math actually supports, even when the conclusion is inconvenient. Here’s what a single Commission Transparency Report actually catalogs.
Vendor relationships traced
On average, per CTR
12+
Brokers, consultants, carriers, and third-party vendors mapped in one report. Every entity that touches a dollar of plan compensation.
Forms of compensation surfaced
On average, per CTR
5+
Direct commissions, override agreements, contingent payments, persistency bonuses, and revenue splits. All reconstructed and footnoted.
Every fee, every commission, every third-party payment, surfaced, sourced, and footnoted. The audit trail your fiduciary committee can defend.
Case studies
Findings from past engagements.
Client identities withheld per NDA. All figures from audited engagements.
Industrial · Fortune 500
NDA$1.8M
Indirect overrides surfaced
Reconstructed the full economics of a multi-broker plan.
Audit covered five brokers and consultants and mapped total compensation flowing through the plan. About $1.8M of that was indirect overrides not visible on the surface, plus $3M+ in additional advisor value the client could potentially redirect through better-structured partnerships.
Oil & Gas · Fortune 500
NDA~$150K
Reporting discrepancy caught
Caught a six-figure gap between broker and carrier disclosures.
Reconciled what the broker reported receiving from a single carrier against what the carrier reported paying. The mismatch, and the multi-year escalation pattern that followed, reframed the client’s view of its partnerships' scope cost.
Private operator
NDA95%
PEPM premium over peer median
Found a plan paying nearly double the peer benchmark.
Total third-party compensation mapped across multiple carriers and the broker of record. Plan was running 95% above the industry median PEPM. This surfaced a renegotiation opportunity leadership hadn’t seen.
Who we are
The Uncommon Team.
Boston, MA · Founded 2024
Founder & CEO
Neil Larson
Two decades in benefits, from every seat that touches the dollar. MIT Sloan MBA. Former CSO at Benefit Science (acquired). Credentialed actuary at Aon and Gallagher. Former Head of Benefits at JBS. Founded Uncommon on the conviction the industry needs transparency.
ActuaryIndustry InsiderMIT Innovator
Analyst · Founding team
Jack Dickson
Leads the CTR carrier and vendor outreach. Cross-functional analyst across client engagements, healthcare data, plan optimization, benchmarking and the AI tooling that powers every Commission Transparency Report.
Analyst