What compliance teams use Calliope for

Three jobs. One evidence layer.

01
Document

Reasonableness, documented

Benchmark every broker and service-provider compensation arrangement by segment size and service code — so a "reasonable" determination is backed by the market itself, not a gut call. Build the 408(b)(2) file ahead of renewal, so the documentation is ready before anyone needs it.

  • Direct and indirect compensation benchmarked across 113 segments
  • Per-account reasonableness narrative, sourced to the filing
  • Your own firm's compensation, benchmarked before you disclose it
03
Prepare

Review-ready

Walk into any fiduciary review with the work already done. Reproducible, sourced analysis that documents a prudent process — ready for a DOL inquiry, an internal audit, or a benefits-committee meeting.

  • Reproducible methodology traceable to the filing record
  • Documented fee-reasonableness benchmarks by segment and service code
  • Audit-ready exports for the fiduciary file
The shift

The standard moved from disclosed to defensible.

"Disclosure used to be the finish line. Under the 2026 enforcement posture, fiduciaries are measured on whether the process behind a decision was prudent — and whether they can prove it." — The "show your work" standard, DOL FAB 2026-01
Why now

Five years of regulation, all pointing one way.

More disclosure. More documentation. More accountability. Every major move since 2021 has raised the bar for what a defensible fiduciary process looks like — and what compliance teams are expected to have on file.

Effective now

CAA 2021

Brokers and consultants must disclose all direct and indirect compensation to plan fiduciaries under ERISA 408(b)(2). Reasonableness becomes the test.

Signed Feb 2026

CAA 2026

Disclosure expands to all service providers; PBMs are explicitly classified as covered service providers. The label limitation is gone.

Proposed · 2026

DOL PBM fee rule

Detailed PBM and affiliate fee disclosure to fiduciaries of self-insured group health plans, including spread and rebate flows.

Precedent

Oregon Potato v. Marsh

Exercise discretion over plan assets and you are a fiduciary, regardless of how you label yourself. Motion to dismiss denied.

April 2026

DOL FAB 2026-01

A documented, prudent process is the enforcement standard. The expectation is simple: show your work.

The filing record is the evidence. Calliope is what turns it into documentation.

Built for compliance & fiduciary teams

The fee-reasonableness infrastructure of a national firm — without the analyst bench.

Calliope reads five years of the entire benefits market and benchmarks it from its own dataset. The data is the benchmark — which is exactly what makes a determination defensible.

Fee-reasonableness benchmarks

113 segments by service code and group size, computed from the filing record itself. Determine "reasonable" against the market, not a placeholder survey.

Disclosure-gap detection

Negative space is a signal. A missing Schedule C on a large self-funded plan, a dropped welfare filing — Calliope flags the under-disclosure so you can correct it as part of your review.

Reproducible & sourced

Every benchmark and signal traces back to the underlying filing. Audit-ready by construction — it survives a show-your-work review.

Book-wide exposure view

Entity-resolved across five years. See every account above the segment P90 on service-provider compensation in one view — not one filing at a time.

Your own 408(b)(2) file

Benchmark the firm's own direct and indirect compensation by segment before you disclose it. Walk into the conversation already knowing the answer.

Ask-anything research tier

CalliopeResearch answers fiduciary questions in plain English — "Is our broker comp on the Acme plan reasonable for its segment?" — sourced, in seconds.

The client-facing deliverable

Hand every client plan a documented fiduciary attention report.

Run Calliope's AI fiduciary analysis on any plan in your book and produce a plan-sponsor-ready report: a 0–100 fiduciary attention score across the four domains that draw the most scrutiny — PBM, broker fees, Schedule A, and Schedule C. Each score signals how much documented committee review an area warrants — not a legal verdict — grounded in ERISA case law, with the benchmarks and citations behind it.

  • 0–100 attention score across PBM, broker fees, Schedule A, and Schedule C
  • Severity-ranked findings — each with "why it matters" and the benchmark behind it
  • Print-ready, branded report for the client's benefits committee
  • "Attention," not a verdict — defensible framing that fits a technology provider
Fiduciary Attention Report Illustrative
82/ 100
Review warranted
Overall fiduciary attention · sample plan
Schedule AUrgent
Broker feesPriority
PBMPriority
Schedule CMonitor
Grounded in ERISA case law · Print-ready for the benefits committee
By the numbers

From a week of analyst time to a defensible file in minutes.

days → minutes
Fee-reasonableness file prep
113
Benchmark segments behind every call
5 yrs
Reproducible, sourced history

Know the weak spots. Document the review. Be ready.

See how Calliope turns five years of the filing record into documented, defensible fiduciary review — across your book and your own disclosures. Thirty minutes. No slides.

Calliope is a benefits intelligence platform and technology provider. It supports fiduciary documentation and prudent process; it is not a law firm and does not provide legal advice.