Payroll Setup - Settlor expense?

We have a client converting from one recordkeeper to another. Their payroll vendor is charging them to set up the new payroll files.  Would this be considered a qualified plan expense that can be paid from plan assets or is considered a settlor expense? We have received varying opinions. 

I would say it depends on the reason for the RK conversion. Was is necessary because (1) the RK dropped the client, (2) because the employer did a fiduciary due diligence RFP which resulted in a decision to change RK, or (3) some discretionary decision which may have originated for some reason? 

I think (1) definitely and (2) likely could be situations where these conversion fees could be paid from the plan. If (3), I think not. If the fees are substantial, then getting legal counsel to opine might be warranted. If the fees are not substantial then I say play it safe and do not pay from plan unless clearly supportable (1).