My last employer was a CPA firm. I worked in the TPA division. We had a handful of plans that we were both the auditor and TPA. The compliance department confirmed that because of independence, this was permitted, as long as we weren't also the recordkeeper. The TPA division was titled "....Benefit Consultants" while the accounting division was "..., CPAs". We were the same company, but were run differently. I questioned it when I first started because they wanted me to work on business development but was told that it had run through our compliance group. They are very big on compliance, independence, security, etc.