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Costco Wholesale 401(k) retirement plan: the investment options

Does your 401(k) vote the way you would? $13.30bn of the $17.62bn in the Costco Wholesale 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

The Costco Wholesale 401(k) holds $17.62bn. Of the $13.30bn 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.

SourceCostco Wholesale’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing

What the plan holdsVehicleVoting recordValue
T. Rowe Pricelisted as “TRP Ret 2045 Active Trust K **” Collective trust or separate account NONE $2.02bn
T. Rowe Pricelisted as “TRP Ret 2040 Active Trust K **” Collective trust or separate account NONE $1.76bn
T. Rowe Pricelisted as “TRP Ret 2055 Active Trust K **” Collective trust or separate account NONE $1.74bn
State Streetlisted as “S&P 500 Index Securities Lending Series Fund Class X **” Not identified from the filing Not counted either way $1.73bn
T. Rowe Pricelisted as “TRP Ret 2035 Active Trust K **” Collective trust or separate account NONE $1.51bn
T. Rowe Pricelisted as “TRP Ret 2050 Active Trust K **” Collective trust or separate account NONE $1.43bn
T. Rowe Pricelisted as “TRP Ret 2030 Active Trust K **” Collective trust or separate account NONE $1.40bn
Wellingtonlisted as “CIF II Growth S5 **” Not identified from the filing Not counted either way $1.33bn
T. Rowe Pricelisted as “TRP Ret 2060 Active Trust K **” Collective trust or separate account NONE $985m
T. Rowe Pricelisted as “TRP Ret 2025 Active Trust K **” Collective trust or separate account NONE $862m
Capital Grouplisted as “New Perspective Trust U3 **” Collective trust or separate account NONE $629m
PIMCOlisted as “Income Institutional **” Not identified from the filing Not counted either way $611m

The 12 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 Costco Wholesale 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 Costco Wholesale; 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 77.3% 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 planRhinebeck Bancorp 401(k)$33m in the planTransdev North America 401(k)4,904 savers · $160mSmithfield Foods 401(k)16,034 savers · $419mLockton 401(k)8,620 savers · $1.40bnMei Rigging & Crating 401(k)1,317 savers · $38mKodak Alaris 401(k)1,080 savers · $168m