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Tompkins Financial 401(k) retirement plan: the investment options
Does your 401(k) vote the way you would? Essentially all of the $207m in the Tompkins Financial 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
Tompkins Financial 401(k) match and balances, from the filing
- Company money in
- about $7,410 per active participant
- $7m in plan year 2024
- Employees saved
- about $7,850 each
- $8m in plan year 2024
- Average balance
- $169,400
- 1,303 people with a balance
- In the plan
- $221m
- at the end of plan year 2024
Company money is the match plus any other employer contributions, averaged over all 988 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 TOMPKINS FINANCIAL CORPORATION as “TOMPKINS RETIREMENT SAVINGS PLAN” · EIN 150470650, plan number 002 · search the filings
The Tompkins Financial 401(k) holds $207m. Of the $207m 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.
SourceTompkins Financial’s own annual retirement-plan filing with the SEC (Form 11-K, Schedule of Assets) · open the filing
| What the plan holds | Vehicle | Voting record | Value |
|---|---|---|---|
| American Funds Service Co.listed as “1,861,704.5126 Units” | Collective trust or separate account | NONE | $39m |
| American Funds Service Co.listed as “1,693,332.2430 Units” | Collective trust or separate account | NONE | $32m |
| American Funds Service Co.listed as “1,043,416.7208 Units” | Collective trust or separate account | NONE | $24m |
| American Funds Service Co.listed as “964,945.3224 Units” | Collective trust or separate account | NONE | $23m |
| American Funds Service Co.listed as “1,324,503.2389 Units” | Collective trust or separate account | NONE | $21m |
| American Funds Service Co.listed as “548,913.1449 Units” | Collective trust or separate account | NONE | $13m |
| BlackRock Advisors, LLClisted as “282,011.0274 Units” | Collective trust or separate account | NONE | $12m |
| American Funds Service Co.listed as “580,579.3619 Units” | Collective trust or separate account | NONE | $8m |
| American Funds Service Co.listed as “210,499.0382 Units” | Collective trust or separate account | NONE | $6m |
| Fidelity Investmentslisted as “130,391.8615 Units” | Collective trust or separate account | NONE | $6m |
| Great Gray Trust Companylisted as “378,696.0838 Units” | Collective trust or separate account | NONE | $4m |
| JP Morgan Investment Mgmt Inc.listed as “174,403.7418 Units” | Collective trust or separate account | NONE | $4m |
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 Tompkins Financial 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 Tompkins Financial; 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.