The first step to becoming the best 401(k) administrator, committee member or concerned party that you can be, is to understand what you have. To understand what you have, you must get organized. In fact, you are anything like me, you cannot get started on a project until everything is order (I had to sweep my floor before I could start writing this blog post this morning) which is why when working with our current clients or prospective clients, the first thing that we do is take inventory of the documents and records that are pertinent to the 401(k) plan.
Before going any further you may be asking, “Why is keeping up with my plan documents a big deal?” First and foremost, because the Department of Labor (DOL) says so. It is required that all Retirement Plan Documents, i.e. the Basic Plan Document, Adoption Agreement, any Amendments and Summary Plan Descriptions (SPD), must be stored for the life of the plan and for at least six years after the plan terminates. It is also important that the documents that you maintain on file are fully executed with all required signatures and dates. The second category of documents that must be maintained by you, the plan sponsor, are the Annual Filings which include annual compliance testing results, form 5500, audits (if applicable), Summary Annual Reports (SAR), and all supporting documents for contributions and distributions. This type of plan record should be maintained for at least six years.
The other reason that is paramount that you are easily able to access your plan documents, and I would argue the most important reason, is that the Adoption Agreement and subsequent Summary Plan Description serve as the instruction manual for your plan. The rules on everything from eligibility requirements to distribution options and employee contributions to employer contributions are contained with the Adoption Agreement and SPD. Without a working knowledge of these documents, it is nearly impossible to properly administer your 401(k) Plan.
Which brings us back to getting organized. We recommend to our clients maintaining a “fiduciary file” where all important plan related documents are easily accessible. You may be gather your plan documents from your third party administrator (TPA) and/or recordkeeper’s website; however, keep in mind that is ultimately the responsibility of the plan sponsor to have the documents and not that of your providers.
Need Direction in organizing your plan documents?
Give me a call at 205-970-9088, email firstname.lastname@example.org.
Jamie Kertis, AIF®, QKA
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162