Plan Sponsors Ask…

Q: When moving our office, we came across some old retirement plan records. That sparked a conversation about what we need to keep with regard to our 401(k) plan. Can you provide any guidance?

A: Just as you do with your personal income tax documents, you need to maintain records related to the plan. This is for a couple of reasons, one of which is being ready to defend actions and decisions if the plan is ever audited. We suggest you review the IRS and the DOL websites for complete information about what you need to keep and for how long. In the meantime, here are some items that come to mind. Keep the original and signed plan document, along with any amendments, the adoption agreement (if any), the Determination Letter from the IRS, and all trust records and investment statements. Make sure you maintain records of all notices to participants, like the Summary Plan Description, the Summary Annual Reports, notices about blackout periods, and fee disclosures. You should also keep proof that the notices were sent and any proof they were received or opened. Of course, keep the plan’s 5500 reports and audits of the financial statements. Click here to find a discussion on this topic in the Journal of Pension Planning & Compliance, Volume 43, Number 4.


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