What the “F” ? – Part 3 – Fiduciary

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What the “F” ?
A four part series that will address important themes of plan management  

Thus far we have looked at some complicated “F”s in funds and fees, in today’s blog we are going to address one of the most overused and misunderstood “F”s in our industry: fiduciary. The basic definition of fiduciary is any individual or entity that has, or exercises discretionary control over the management of the plan or the plan’s assets. A plan may have one than one fiduciary and/or one individual serving in more than one fiduciary capacity. From there, the functional definition of fiduciary goes in several different directions.

When assessing whether or not you fall into a fiduciary role using the functional test you must consider the following: even with no expressed appointment or delegation of fiduciary authority if you are considered in control or procession of authority over the plan’s asset, management, or administration than you are considered a functional fiduciary. Many times this will include members of the Employer’s Board of Directors or Trustees, voting and non-voting, with power to exercise discretion and control. One important distinction to make is that the person who performs administrative ministerial functions, such as processing payroll, approving distributions or loans, or submitting data for testing, is not considered a fiduciary. In other words, the president of the company is usually a fiduciary because he or she has the discretion to implement plan decisions and to hire parties to assist in the administration of the plan; while a payroll clerk is not a fiduciary if he or she is processing the payroll in the 401(k) vendor’s website.

As a plan fiduciary, you may also be presented with opportunities to hire or appoint additional co-fiduciaries. There are different varieties of co-fiduciaries including 3(16), 3(21) , and 3(38) fiduciaries. A 3(16) co-fiduciary acts as the plan administrator and is responsible for managing the day-to-day operations of the plan. Some functions may include determining the eligibility of employees, maintaining all plan documents and records, providing annual notices, rendering decisions regarding participant claims, and fixing plan operational errors. This may be confusing since we have already determined that the individual within your company that provides many of these administrative functions like sending out notices and approving distributions is not a fiduciary; the difference is in that a named 3(16) fiduciary is an individual outside of your company that provides these administrative duties without consulting you, the plan sponsor. A 3(21) fiduciary is a paid professional who provides investment recommendations to the plan sponsor, but the plan sponsor retains ultimate decision-making authority and approves or rejects the advice of the 3(21) fiduciary. There is no discretion given to the 3(21) fiduciary. A 3(21) provides investment advice on a regular basis to the plan that the plan sponsor relies on to make a decisions pursuant to a mutual agreement or understanding (written or not) that is specialized to the plan for a fee. Finally, a 3(38) fiduciary is an investment manager in that the investment manager has discretion to make changes in the plan investment line-up or allocation without consent of the plan sponsor. A 3(38) must be appointed in writing by contract. The main difference between a 3(21) and a 3(38) is discretion. It is also important to note that even if you as a plan fiduciary hire a 3(16), a 3(21), and a 3(38), you still cannot absolve yourself of your personal fiduciary responsibility.

If you’ve made it this far in the blog, I’m sure it is clear to you why the definition of a fiduciary is anything but clear and you may be asking yourself why you should take the time to even bother with trying to understand your role and whether or not you are or are not a fiduciary. The reason understanding your role and acting properly as a fiduciary can be so important is that fiduciaries who do not follow the basic standards of conduct may be personally liable to restore any plan losses to the plan, or to restore any profits made through improper use of the plan’s assets resulting from their actions. While this is very true and taken directly from the Department of Labor’s commentary on fiduciary responsibility, it can be hard for many plan fiduciaries to conceptualize because chances are you have not, do not, and will not ever know anyone who loses their home or personal assets over a fiduciary breach. Nonetheless, there are very real examples of plan fiduciaries who have cost their companies a significant amount of many and/or lost their job due to improper fiduciary management. Look no further than Caterpillar, Fidelity, Lockheed Martin, Intel, Boeing and State Farm for companies that have faced or are currently facing case action lawsuits involving the management of their respective 401(k) plans (not all cases have been settled, nor have all companies been found guilty).

Moreover, as a plan fiduciary you have the unique and important role of providing the greatest opportunity for retirement savings that most of your employees will have. By properly managing the plan, you are playing a vital part in helping your valued employees get to their retirement goals. Check out my next installment when we will look closer at this role you play in the ultimate “F”.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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What is Your Millennial Employee Retention Strategy?

turnoverDoes your company have a millennial retention strategy? The rapidly growing millennial workforce is changing ideas of loyalty and employee retention in the workforce. According to the The Deloitte Millennial Survey 2016, two-thirds of Millennials express a desire to leave their organizations by 2020. Businesses must adjust how they nurture loyalty among Millennials or risk losing a large percentage of their workforces. Since most young professionals choose organizations that share their personal values, it’s not too late for employers to overcome this “loyalty challenge”. Companies that approach employee retention in the same way that they did even five years ago may lose their most valuable young talent; as our Employee Education Specialist, Caleb Bagwell wrote about just last week, the cost of replacing employees is high.

Here are 4 job drivers to implement into your company’s culture to influence Millennials in the workplace and how you can translate those concepts into effective employee retention programs.

Recognizing Generational Differences

Generational differences in the workplace has become a HR hot topic and for good reason.   More than one-in-three American workers today are Millennials (adults ages 18 to 34 in 2015), and this year they surpassed Generation X to become the largest share of the American workforce, according to 2015 Pew Research Center analysis of U.S. Census Bureau data. It is likely that experienced baby boomers approaching retirement may have different benefit and lifestyle priorities than your new millennial. While compensation and the quality of the work experience remain important across segments, failing to understand that different generations may have different expectations and preferences can lead to challenges at all levels of the organization. With the youngest baby boomer being age 52, doing the math lets you know that in 10 years, your company is going to look a lot different than it does today.   Utilizing a workforce leadership and education consultant to bridge the communication gap is integral to growing a sustained, experienced new group of employees.

Benefits and Compensation

gen diffMillennials are bringing to the table a new set of benefit expectations for you to examine; therefore, it can be easy to lose sight of traditional compensation and benefits. However, these areas still give employers an edge in recruiting and retention. One study discussed by SHRM found that 62 percent of Millennials would leave their jobs for better family benefits. The same study found that 41 percent indicated that a lack of family-friendly support had negatively impacted their work experience. As a result, it’s useful for companies to evaluate what their competitors are offering their employees. Are compensation and benefits on par with industry best practices or averages? Millennials need to feel valued and do not need any extra incentive to look for a job with your competitor. It is a good business practice for all generations of your employees to make sure their compensation and benefits are in line with industry standards.

Flexibility

The continued rise of trends like telecommuting, flexible scheduling, freelancing, and job sharing has shaped Millennials’ expectations of the workplace. As they advance in their careers, they’re more likely to be concerned about work-life balance, whether it’s in response to family demands, health, or outside interests. Companies that provide some level of flexibility are often able to hire more millennial talent by taking steps such as experimenting with unlimited vacation time and implementing structured telecommuting policies. While there are a wide variety of benefits around the idea of work-life balance, it’s important to be realistic about what works for your company, workflows, and culture. However, in general, the more you’re able to provide your workers with flexible benefits, the easier it may be to retain millennial employees.

Collaboration and Learning

shutterstock_126190568.jpgCollaboration and feedback are critical to keeping Millennials satisfied at work. Businesses are faced with how to make that crucial communication a reality. Finding ongoing ways to support learning and collaboration, from formal mentorship programs to investing in training programs, may also help increase retention. Today’s younger workers have a strong desire to contribute, but also want work-life balance, flexibility, and collaborative environments. By recognizing what energizes Millennials at work, it may be easier to create more effective employee retention programs.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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What the “F” ? – Part 2 – Fees

wtfpt2A four part series that will address important themes of plan management

 

Last installment we tackled the first 4 letter “F”, fund as in mutual funds. This entry will examine the next 4 letter “F” – Fees. Fees and funds go hand and hand as every dollar that you pay in fees lessen the dollars available for retirement. However, I must disclose that I do not believe that cheapest is best and to date, there are not any federal regulations that state your plan has to be the cheapest. What the regulations do state is that as a fiduciary to your company’s retirement plan you have a duty to understand and monitor the fees associated with operating the plan.

The first fee to consider when analyzing the overall cost of your plan is the mutual fund expense ratios. On http://www.morningstar.com an expense ratio is defined as the annual fee that all funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for fund expenses, including 12b-1, management fees, operating costs, and all other asset-based costs incurred by the fund. Let’s breakdown each component by first looking at the 12b-1 fee. A 12b-1 fee is earmarked for the financial professional’s compensation and can range from 0.25% up to 1.00%. It should be noted that not all mutual funds have a 12b-1 fee. If you work with a financial professional that is fee-based or fee for service, then that adviser may select funds that do not pay a 12b-1 fee since he or she does not rely on that fee for compensation. The information on how much each fund in your plan pays in 12b-1s should be accessible through the fund prospectus. Next management fees and operating costs are the portion of the expense ratio that is used to compensate the mutual fund manager for his or her expertise in running the fund and for any costs the mutual fund company incurs in managing the fund (producing prospectuses, mailing costs, building costs, etc). This is typically the largest portion of the overall cost of the fund and is usually higher in actively managed funds than in passively managed funds. Finally there is the mysterious “all other” portion. In the retirement space the “all other” can be especially important since many times this is referring to the recordkeeping service fees (RSFs) or subtransfer agents fees (subTA) that are paid to the recordkeeper of your 401(k) plan. In general both the RSF and subTA fees are paid by the mutual fund to the recordkeeper for keeping all the individual records of its investors; in the retirement plan space that means all of your participant’s records on their individual investments. The tricky thing about these fees in particular is that they are negotiated between each recordkeeper and each mutual fund; therefore they are not consistent or readily disclosed. For example, ABC mutual fund may pay DEF recordkeeper 0.15% in an subTA fee, but ABC fund might also pay GHI recordkeeper 0.10% in a subTA. While the RSF or subTA fee may not be the largest portion of the overall expense ratio, it can be very important to understand the next aspect of your overall retirement cost and that is the cost associated with your recordkeeper and third party administrator (TPA).

In February 2012, the Department of Labor issued its final regulations on plan level fee disclosure under section 408(b)(2); now simply known as the 408(b)(2) disclosure. The very simplistic explanation over the 408(b)(2) regulation is that it was designed to disclosed to the plan sponsor the cost of doing business with covered service providers (CSPs) including recordkeepers and TPAs. While it did help to uncover some hard dollar fees and the formulas for calculating compensation, it is still fairly difficult in some cases to truly understand what you are paying to whom. If you work in a bundled arrangement, where the same provider serves as your recordkeeper and TPA, then chances are that the subTAs or RSFs that they are receiving from the mutual funds may cover all costs associated with administering the plan; resulting in a $0 hard dollar billable to you the plan sponsor. These plans are sometimes sold as “free” because there is not a hard dollar cost; however, you know now know that the plan is not in fact “free” but rather that the cost is being subsidized by the money received from the mutual funds. If you are working in an unbundled arrangement where there is a separate firm providing recordkeeping services and another providing TPA services, then you may experience a bill from your TPA and “free” services from the recordkeeper. Again, note that the recordkeeper may be receiving money from the mutual funds to cover their costs. Also, in many cases the recordkeeper may be sharing revenue with the TPA in order to help lessen their billed fees to you. If as a plan you are currently receiving any billable expenses that you pay from the company or pass on to your participants to pay, then chances are the mutual funds in your plan have no or low subTAs or RSFs that do not cover the entire cost to run the plan.

The final cost to understand is what you are paying your financial representative. He or she may receive the 12b1 from the mutual fund if you are not in a fee based arrangement. Please note that if compensated by a 12b-1 fee, then his/her compensation is determined by the share class of mutual fund in your plan. In general an A Share fund pays 0.25% and an R share pays 0.50% (there are other share classes, but these are the most common in retirement plans). If you are in a fee based arrangement with your representative, than he/she may charge a flat hard dollar fee or an asset based charge (0.25% of plan assets). There is not a right or wrong way to compensator your financial professional for their time, but like all of the other fees that we have discussed it is just important that you understand how they get paid.

One of my favorite business quotes is “Cost is only an issue in the absence of value.” and this is especially true as it pertains to your company’s 401(k) plan. As I said in the outset, you don’t necessarily have to have the cheapest plan, but you do have to be able to demonstrate that you understand what you are paying and what you are getting for those dollars. If you are unsure of what you are paying any of your vendors or if those costs are reasonable, then please contact me. We are happy to help you answer this “What the “F”?”!

 

Investments are subject to risk, including the loss of principal. Because investment return and principal value fluctuate, shares may be worth more or less than their original value. Some investments are not suitable for all investors, and there is no guarantee that any investing goal will be met. Past performance is no guarantee of future results. Talk to your financial advisor before making any investing decisions.

 

Please consider the investment objectives, risks, charges, and expenses carefully before investing. The prospectus, which contains this and other information about the mutual fund, can be obtained from your financial professional. Be sure to read the prospectus carefully before deciding whether to invest.

jamie kertis headshotJamie 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
www.grinkmeyerleonard.com

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Calling All COIs

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Poll most business owners, presidents of companies, or C-level executives about who are there most trusted advisors are and chances are you will get the same answers: their spouse, their attorney, and their CPA.

As a CPA, who are your most trusted advisors?  Do you have an attorney or other professional who you can turn to for ideas or advice to help you expand your knowledge base and bring new ideas to your clients?

Argument for an Attorney

When determining which attorney to work with as a center of influence, first take a look at your own practice and where your clients may have a specific need.  If you work with a large number of business owners, there may be a need for an attorney that has a strong working knowledge of buy-sell agreements, estate planning, or liability.  Additionally, if you are a CPA who deals with business clients and their qualified retirement plans, there is a good chance that you will come across a situation that will require an outside opinion, sometimes even a legal opinion, on the operation of the qualified plan.  I would argue that it makes more sense to have already vetted and established an relationship with a legal professional before the situation arises that you need to recommend one.  Attorneys also can provide you with insights and opinions that can help you guide your clients away from trouble to begin with.

Argument for a Financial Advisor

Similarly when deciding which advisor to partner with as a center of influence, first take a look at your practice to determine if it would make more sense to partner with a professional that specializes in personal wealth management or qualified plan management.  If you find that most of your practice is focused on personal returns and individual tax preparation, then it would make more sense for you to team up with an advisor that also focuses on that form of client service.  On the other hand, if your practice is focused on qualified plan audits and business tax preparation, then working with an advisor who also works on qualified plans is the best way to go.  The pool of advisors that focuses on qualified plans, such as 401k plans, is much smaller, but our knowledge base of the challenges that our 401(k) clients face can be very valuable.  For instance, a qualified plan advisor is integral in changing plan service providers.  Although a service provider change may not seemingly have an impact on your ability to conduct an audit, it certainly can when you consider the reports that you need to complete your audit and the vast differences when it comes to the availability of reports on a provider website.  If you have a relationship with that advisor prior to the conversion taking place, you will have a better chance to give your opinion on the new provider that is chosen.

Cultivate the Relationship

In both cases, attorney and advisor, these professionals are more than likely looking to add value to their clients and you as a CPA have an excellent opportunity to do just that.  Perhaps you could consider hosting joint lunch and learns, seminars, or webinars that offer content to clients from your unique perspective as a CPA.  For example, I recently learned there is a significant difference between a limited scope and full scope audit offered to plans with over 100 employees; I would not have gained this useful information had it not been for my relationship with a trusted CPA partner.  Vice versa, I was able to inform this CPA group about the short-comings that we have seen in plan audits and what are clients felt were the most overlooked items in their audits.  In both cases, we were able to add value to our own practices while gaining information that we can pass along to our respective clients.

jamie kertis headshotJamie 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
www.grinkmeyerleonard.com

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What the “F” ? – Part 1 – Funds

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No this entry is not about all of the things that your participants and employees might do to make you go “What the “F”?” (although I am you all have some great stories). Instead over the next four weeks, I will be covering the four topics that should be top of mind for plan administrators, investment committees, and human resource professionals concerning plan management. Today’s “F” is Funds. 

A fund or mutual fund is defined by the Securities and Exchange Commission (SEC) as a company that brings together money from many people and invests it in stocks, bonds or other assets. The combined holdings of stocks, bonds, or other assets the fund owns are known as its portfolio. Each investor in the fund owns share, which represent a part of these holdings. As someone who works on your company’s 401(k) plan it is important to have a good understanding of how mutual funds work since mutual funds are the most common investment vehicles offered in 401(k) plans. According to FINRA’s website (www.finra.org) the majority of 401(k) plans offer 8 – 12 investment options, but I have seen plans out there that offer 40 + mutual fund options. There are certainly different schools of thought as it pertains to the number of investment options that you should make available to your plan participants. Some committees believe the more the merrier; that by offering a large number of options, their participants will be able to design a portfolio that works best for them. Others believe, limit the plan options to a handful of funds that represent the main asset classes (equity, fixed income, and cash).   We tend to believe that the plan should offer the fund option in each of the 404(c) style boxes: large, mid and small cap in the growth, value and blend categories with a additional options in international and fixed income.

Another important aspect of your plan’s investment menu is the Qualified Default Investment Alternative (QDIA). Your plan’s QDIA is the fund or funds that a participant defaults into if he or she falls to make an investment election. Under the Department of Labor’s guidelines, a QDIA may be a life-cycle or targeted-retirement-date fund, a balanced fund or a professionally managed account. The committee should take the task of selecting a QDIA very seriously because if used correctly, it can offer the plan and its fiduciaries valuable safe harbor protections.

Regardless of the number of funds in your plan or what option you have designated as the QDIA, one thing is constant: the fiduciaries of the plan have an ongoing responsibility to monitor the investment options. In the Tibble v. Edison case, the Supreme Court sent a clear message that the fiduciaries of a qualified retirement plan have an ongoing duty to monitor fund investment choices. A quote taken from the ruling reads “The trustee must systematically consider all investment of the trust at regular intervals to ensure that they are appropriate.” Please note this case did not center around fund performance or if one asset class is better than another, but rather underscored the importance of having a prudent process for review and decisions to keep or remove a fund option.

In this blog edition, I mentioned several industry terms like 404(c), QDIA and the prudent process required for monitoring funds. If you or the your investment committee are unsure if you have one or all of these in place, please contact me and we can further discuss the importance of this “F” to successfully running your 401(k) plan.

-Jamie

 

Investments are subject to risk, including the loss of principal. Because investment return and principal value fluctuate, shares may be worth more or less than their original value. Some investments are not suitable for all investors, and there is no guarantee that any investing goal will be met. Past performance is no guarantee of future results. Talk to your financial advisor before making any investing decisions.

Please consider the investment objectives, risks, charges, and expenses carefully before investing. The prospectus, which contains this and other information about the mutual fund, can be obtained from your financial professional. Be sure to read the prospectus carefully before deciding whether to invest.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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PPA Document Restatement Deadline Looming

ppa.jpgEvery six years, the IRS requires that employers using a pre-approved prototype or volume-submitter 401(k) document restate their plan document to incorporate any and all changes made to the regulations and tax laws that impact retirement plans. This go-around is labeled the Pension Protection Act of 2006 (PPA) restatement process and will pick up the changes made by the Pension Protection Act of 2006, the final 415 regulations, the Heroes Earnings Assistance and Relief Act (HEART) of 2008 and the Worker, Retiree and Employer Recovery Act (WRERA) of 2008. The window for restating your plan document opened on May 1, 2014 and will close April 30, 2016 which means if this is the first time that you are hearing about this restatement phase it is of the utmost importance that you contact your third party administrator (TPA) as soon as possible to get your restatement started.

Do I Have To?

The long and the short of it is “Yes”! Your retirement plan must follow the written plan document and the written plan document must follow the rule, regulations, and guidelines set forth by the IRS and the Department of Labor (DOL). Therefore, when one of these governing bodies makes changes to the rules, your plan must adopt to follow these rules. Most of the time, these changes can be handled through an interim or “snap-on” amendment to the plan, but when the number or the complexity of the changes gets to be too great, a restatement is required.

Who Should be Helping Me?

Your plan’s third party administrator (TPA) is more than likely the party that will be assisting you with the restatement of your document. Keep in mind that it is common for your TPA and your record keeper to be the same company, but that is not always the case. It is also important to determine if your plan is using a prototype or volume submitter document or if your plan is an individually drafted or designed plan. In most cases, your plan will be either a prototype or volume submitter, but it is definitely important to make sure you are clear on what type of plan you have as that will impact when and how your plan has to be restated.

Anything Else I Should Know?

Now could be a good time to review your plan to determine if any changes should be made to the plan provisions that are not specifically covered by the required restatement. For example, your plan could review the definition of compensation, Roth options, and/or automatic enrollment procedures and make updates to these or other provisions during the mandatory restatement. Just be ware not to change any “protected benefits” such as the timing or forms of distributions during the process.

By this time, hopefully your provider has already completed the restatement process or at least you plan’s TPA has reached out to you to discuss the restatement process; however, if not, it is time to make a call to your plan provider to get the process started! If you have any questions about the restatement process, what it means to your plan, or where to go for assistance, please let me know by calling 205-970-9088 or emailing me at jamie@grinkmeyerleonard.com.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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You Don’t Know What You Don’t Know

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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 jamie@grinkmeyerleonard.com.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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IRS: Skip Optional Compliance Questions on the 5500, 5500-SF for 2015

IRS: Skip Optional Compliance Questions on the 5500, 5500-SF for 2015

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For 2015, plan sponsors should skip the compliance questions that were just added to the Forms 5500 and 5500-SF, and to Schedules H, I and R for the 2015 plan year. Revised versions of the 2015 instructions for both forms contain the new information regarding the optional questions.

The Department of Labor (DOL) announced this change in a Feb. 16 message to software developers for EFAST-2, the electronic system by which Forms 5500 are submitted. While the DOL has not yet posted these revised versions on the website of the DOL’s Employee Benefits Security Administration (EBSA), the agency says that it plans to do so.

The revised instructions read as follows:

Form 5500

IRS Compliance Questions. New Lines 4o, 4p 6c, and 6d were added to Schedules H and I. The IRS has decided not to require plan sponsors to complete these questions for the 2015 plan year and plan sponsors should skip these questions when completing the form.

New Part VII (IRS Compliance Questions) was added to Schedule R for purposes of satisfying the reporting requirements of section 6058 of the Code. The IRS has decided not to require plan sponsors to complete these questions for the 2015 plan year and plan sponsors should skip these questions when completing the form.

Form 5500-SF

IRS Compliance Questions. New Lines 10j, 14c, 14d, and new Part IX (IRS Compliance Questions) were added to this Form for purposes of satisfying the reporting requirements of section 6058 of the Code. The IRS has decided not to require plan sponsors to complete this question for the 2015 plan year and plan sponsors should skip this question when completing the form.

The IRS added questions to the Form 5500 and its schedules relating solely to IRS compliance issues because the IRS now requires that certain filers submit the Form 5500 Series electronically. It had said that answering the IRS compliance questions it added to the form was optional for the 2015 plan year.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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An Investor’s Worst Enemy

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An Investor’s Worst Enemy

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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Take Care of Your Employees

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Take care of your employees.

Jamie Kertis, AIF®, QKAjamie kertis headshot
Retirement Plan Specialist
Grinkmeyer Leonard Financial
1950 Stonegate Drive / Suite 275 /Birmingham, AL 35242
Office: 205.970.9088 / Toll-Free: 866.695.5162
www.grinkmeyerleonard.com

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