Guideline was recently acquired by Gusto, Inc. (“Gusto”). Due to the acquisition, any plans that did not use a Gusto payroll provider were moved to Accrue 401k, Inc. (“Accrue”). As the acquisition technically resulted in an assignment of the 401(k) investment advisor of your plan, Guideline Investments, LLC (“Guideline Investments”), to be under Gusto, plan trustees were sent a notification prior to close requesting the consent for the investment advisor assignment.
However, if you did not consent to the assignment of your investment advisor, Accrue will not be able to continue servicing your plan.
This article addresses the required transition for 401(k) plans that did not consent.
Understanding why your plan is changing
Why was I required to consent?
As part of the acquisition of Guideline, only plans that use a Gusto payroll provider can be serviced by Gusto (formerly Guideline) plans. Because your company uses a different payroll provider, your plan was required to move to Accrue.
As the acquisition technically resulted in an assignment of the 401(k) investment advisor of your plan, Guideline Investments, LLC (“Guideline Investments”), to be under Gusto, before the closing of the acquisition, plan trustees were sent a notification prior to close requesting the consent for the investment advisor assignment.
What were my choices regarding the plan change?
You were presented with two paths:
Consent to assignment: By consenting to the assignment of the investment advisor, your plan will be serviced by Accrue, and you are able to keep your existing payroll provider as well as maintain your current payroll integration service level (whether integrated or synced via third-party connection) in most cases.
Decline to consent: If you chose not to consent, Accrue will be unable to service your plan in the near future. As a result, the investment management services terminated as of November 3, 2025, and your current payroll integration will be disconnected by January 2, 2026. After this date, your plan will transition to a self-service model and you will have to find a new plan provider.
If you did not take action, your plan was considered to have consented to the assignment.
I did not consent. What specifically happens to my plan now?
If you declined consent to the assignment of the investment advisor, Guideline Investments no longer provided investment management services as of November 3, 2025, and Accrue can no longer provide an integrated 401(k) service. Your plan's payroll connection will also be disconnected as of January 2, 2026, your plan will transition to a self-service model, and you will have to find a new provider and initiate a plan transfer.
The self-service model means you as the plan sponsor must take on all primary day-to-day administrative and fiduciary responsibilities for the 401(k) plan.
If you did not take any action to consent or not consent, you were deemed to have provided consent and your plan will continue as it is currently (Accrue serves as the plan recordkeeper and the 3(16) plan administrator, if relevant).
Understanding your self-service plan
What is a self-service plan?
Moving to a self-service plan means that you are fully responsible for the accurate and timely administration and compliance of the 401(k) plan. While the plan remains active, you assume fiduciary and administrative tasks that were previously handled by the 3(16) plan administrator.
We recommend finding a new provider by January 2, 2026, to avoid the additional administrative and compliance tasks for your plan.
What new administrative responsibilities will I be taking on?
As a self-service plan sponsor, you will be responsible for the following critical tasks:
Timely contributions: Manually calculating and submitting payroll journals, including all employee deferrals and employer contributions. This must be done accurately and within legal remittance deadlines. We will send you email notifications when employees make changes to their contribution rate, so you can update your payroll journals accordingly.
Participant data management: Manually entering and updating all participant information on the dashboard, including new hires, terminations, and compensation changes
Annual filings: While Accrue will complete the Form 5500 on your behalf, you will be required to review and sign the form before it will be submitted.
It’s important to note: Failure to accurately and timely execute your new administrative duties, especially concerning contribution remittances, can lead to IRS penalties and potentially result in the disqualification of your 401(k) plan.
Learn more about self-service plans and responsibilities.
What are the fiduciary and investment management changes?
As of November 3, 2025, significant changes have occurred regarding your plan’s investment oversight and plan administration:
Termination of 3(38) investment management services:
There is now no investment adviser selecting, monitoring, or updating the plan investment options.
No investment recommendations are being made to 401(k) plan participants.
3(16) plan administrator fiduciary role:
Accrue 401k, Inc. does not serve as the 3(16) plan administrator fiduciary for your self-service plan. You can find out more about your responsibilities as a plan fiduciary here.
Options for your plan
How do I complete a plan transfer to a new provider?
You should contact a new provider as soon as possible to understand their onboarding process and transition timelines.
Once you choose your new provider, please let us know right away so we can initiate the change in our system. We will work with them to facilitate the transfer of assets and plan documents. You will need to complete several tasks in your dashboard to continue the process. See detailed steps for the plan transfer process here.
Please note that if your plan is not moved before January 2, 2026, it will become self-service, and you will be responsible for continuing the administrative and fiduciary tasks until the transfer is complete.
Alternatively, you can change your decision regarding the consent to the assignment of the plan investment advisor. See below for more details.
Can I change my decision to consent?
Yes, if you wish to change your response and want to continue with existing services with Accrue, you can email our Sponsor Support team at [email protected]. Please clearly state that you would like to change your decision and consent to the assignment of the investment advisor.
To speed the process, please be sure to include the applicable plan names and account IDs.