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What Constitutes Proper Documentation of Retirement Plan Committee Meetings?

With most retirement plans, the fiduciary responsibility of selecting and monitoring the plan’s menu of investments is designated to a retirement plan investment committee. This committee usually includes financial officers and human resources officers of the employer. The committee meets periodically (anywhere from annually to quarterly) to consider agenda items including investment due diligence, fees and services of plan providers, status of plan goals, etc.

From a fiduciary perspective it is just as important to properly document these meetings as it is to hold the meetings. Proper documentation serves as proof that the committee’s responsibilities are being prudently executed. Often plans question the degree of documentation necessary. Below are a few suggestions of what the retirement plan investment committee meeting minutes should include:

    • A listing of all parties present with identification of roles (committee member, guest, financial professional, provider representative, attorney, accountant, etc.)
    • A description of all issues considered at the meeting: fund performance of investments offered, participant communication/education initiatives, plan demographic and provisional review, investment policy statement review, market summary and other topics as appropriate to achieving and maintaining a successful plan
    • Documentation of all materials reviewed during the meeting
    • Documentation of all decisions made and the analysis and logic supporting each decision
    • Identification of any topics to be continued in subsequent meetings.

These documents should be posted for you to access at any time during the year.

 

For more information, contact your dedicated Plexus Financial Services advisor.

ACR# 350849 06/20

Plexus Financial Services, LLC (“PFS”) does not provide specific investment, tax, and/or legal advice and the information referenced/provided is not specific to any company’s or individual’s circumstances. These materials are general in nature and provided for educational purposes based upon publicly available information from sources believed to be reputable and reliable; we cannot assure the accuracy or completeness of these materials and as a result, personal diligence should be completed before relying or acting upon the information presented. Any general information referenced/provided is not be construed as personalized investment, tax, and/or legal advice. Always consult an advisor, attorney and/or tax professional regarding your specific situation.

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Retirement Plan Advisory Group (“RPAG”) is not in the business of providing legal advice with respect to ERISA or any other applicable law. The materials and information do not constitute, and should not be relied upon as, legal advice. The materials are general in nature and intended for informational purposes only. All content, including any brochures or other materials designed for potential use with plan sponsors, fiduciaries, and plan participants, must be reviewed and approved by the compliance and legal department(s) of the financial professional and/or firm prior to any use to confirm that they meet the firm’s legal and compliance policies and standards. The financial professional and his/her firm are solely responsible for the use of content and any materials included herein, and for ensuring that all services provided by the financial professional conform to the firm’s legal and compliance policies and standards.

 

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