You Own Wall Street › Employer plans › Bank of New York Mellon

Bank of New York Mellon 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $303m of the $10.87bn in the Bank of New York Mellon plan votes in secret. Fidelity 500 Index Fund, the most common fund in the plans we track, publishes every vote: answer 3 of its ballots, then see your result.

The question on the ballot

As filed

Bank of New York Mellon 401(k) match and balances, from the filing

Company money in
about $7,500 per active participant
$166m in plan year 2024
Employees saved
about $12,620 each
$279m in plan year 2024
Average balance
$238,900
41,479 people with a balance
In the plan
$9.91bn
at the end of plan year 2024

Company money is the match plus any other employer contributions, averaged over all 22,098 active participants, including anyone who did not contribute. The filing reports dollars, not the match formula; the plan’s summary plan description states the formula.

SourceThe plan’s annual report to the Department of Labor — Form 5500, Schedule H, plan year 2024 · filed by THE BANK OF NEW YORK MELLON CORPORATION as “THE BANK OF NEW YORK MELLON CORPORATION 401(K) SAVINGS PLAN” · EIN 132614959, plan number 004 · search the filings

The Bank of New York Mellon 401(k) holds $10.87bn. Of the $303m we could identify from the plan’s own filing, every dollar sits in a fund that publishes no record of how it voted your shares — collective trusts, which unlike a mutual fund file no Form N-PX and leave no public trace of a single vote.

SourceBank of New York Mellon’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing

What the plan holdsVehicleVoting recordValue
Master Trustlisted as “Common and preferred stock, self-directed accounts, collective trust funds and funds of funds N/A” Brokerage window Whatever the saver buys $10.51bn
Master Trustlisted as “Fully benefit-responsive investment contracts, at contract value N/A” Collective trust or separate account NONE $303m
Notes receivable from participantslisted as “Notes receivable from participants at interest rates ranging from 4.25 % to 9.50 % -” Bonds No shares to vote $50m

The 3 largest holdings in the plan. “Vehicle” is the description the filing itself gives each investment.

Why there is nothing to show

A mutual fund has to file Form N-PX every year listing every vote it cast on your behalf. A collective investment trust does not. It is a bank-run vehicle sold only inside retirement plans, it is cheaper, and it is now where most 401(k) default money sits — including most target-date funds, which is where savers who never chose anything are put.

So the shares bought with Bank of New York Mellon employees’ retirement savings are voted every proxy season — on executive pay, on board seats, on climate and workforce proposals — and there is no public document anywhere recording how. This is not an oversight by Bank of New York Mellon; it is what the disclosure rules currently require, which is to say: nothing.

What you can do

Check whether your plan offers any registered fund as an alternative — those publish their records, and you can read them here. If it does not, the menu itself is the thing that has to change, and that is a decision made by the plan’s fiduciary committee, not by you alone.

See how funds that do publish voted →

CoverageWe classified 100% of this plan’s assets from the filing. The figure above is the share of the money we could classify; anything we could not identify is excluded from it rather than assumed either way.

Other employer plans

The largest employer plans on the site, and a few more. Each page shows what the plan’s funds did with the shares its savers paid for.

Microsoft 401(k)$64.92bn in the planBank of America 401(k)248,103 savers · $62.90bnJPMorgan Chase 401(k)297,359 savers · $52.91bnGoogle 401(k)154,637 savers · $48.74bnWells Fargo 401(k)$43.80bn in the planAmazon 401(k)943,213 savers · $34.59bnInternational Business Machines 401(k)$28.25bn in the planIntel 401(k)$26.91bn in the planHexagon 401(k)7,698 savers · $1.65bnMotus 401(k)1,220 savers · $49mSNF 401(k)1,850 savers · $183mGraham Packaging Company, L.p. 401(k)4,489 savers · $481mMunich Re 401(k)6,162 savers · $1.79bnCoca Cola 401(k)$53m in the plan