Is your Documentation up to Par?

Tips to ensure proper documentation of retirement plan committee meetings

If your organization offers its employees retirement plan benefits, then you know, as the employer, that the fiduciary responsibilities of selecting and monitoring the plan’s investment options is the job of a retirement plan committee. This committee meets quarterly, annually or as needed to address the objectives of the plan, the plan provider’s fees and services as well as other investment due diligence. Many organizations dedicate their human capital and accounting personnel to the committee, as these individuals most often interact with the aspects of the company’s retirement plan.

While it’s important that organizations have these committees in place, it is just as important to properly document the meetings or other key decisions. Without substantial notes and documentation, there’s no concrete evidence that committee members are fulfilling their duties, which can lead to employee questions and concerns. We recommend your meeting minutes or executive summaries include:

• A list of all attendees and their roles, which can include committee member, guest, provider representative, attorney and more
• Identification of materials reviewed during the meeting
• Documentation of all issues discussed during or in addition to the meeting, ranging from achieving and maintaining a successful plan, participant communication and education initiatives to provisional reviews, market summaries, fund performance of investments offered, plan design changes or plan document amendments
• Explanations of decisions made during the meeting as well as logic and analysis that support each decision
• Documentation of topics to consider at later meetings

Key Takeaways

It’s more important than ever to make sure you are documenting not only your meetings but key decisions as well. For example, if you recently adopted the CARES Act provisions in your plan, did you document it? Or if you did not adopt the provisions, did you document the reason to not select or postpone the decision? Take the time now to document these crucial decisions in the form of an executive summary.

Secondly, establish how you are going to store the information. Determine a process that works best for you and your team. One of the easiest ways to do this is to create a binder that contains all the meeting minutes/executive summaries in chronological order, making it convenient for anyone to quickly reference the documentation. Another option is to create a shared document file that provides for quick, in-real-time access by designated persons or committee members. Lastly, work with your retirement plan advisor on questions you have as you develop the best way to create and keep your minutes/executive summaries. By implementing a process and following through on a consistent basis, you will easily achieve successful plan documentation.

If you have any questions about your retirement plan and its committee meetings, please contact our team of dedicated retirement plan experts to discuss. We are here to help you achieve plan success.

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