401K Plan Sponsor: Records & Their Expiration Dates

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“What records should I keep? How long should I keep them? How should I organize my files?”  Advisors have been asked these questions time and time again by plan sponsors looking for a general guideline for record expiration dates.  Record retention doesn’t need to be a mystery, and the filing system doesn’t need to become a tomb. For audits, remember the following requirements.*

Documentation Retention Requirement for Audit Purposes
 

Plan Documents (including Basic Plan Document, Adoption Agreement, Amendments, Summary Plan Descriptions, and Summary of Material Modifications)

 

At least six years following plan termination

 

 

Annual Filings (including 5500, Summary Annual Reports, plan audits, distribution records and supporting materials for contributions and testing)

 

At least six years

 

 

Participant Records (including enrollment, beneficiary, and distribution forms; QDROs)

 

At least six years after the participant’s termination

 

Loan Records

 

At least six years after the loan is paid off

Retirement / Investment Committee meeting materials and notes  

At least six years following plan termination

 

As for organizing your fiduciary file, we suggest a format that includes the following sections:

1.   Documents with all plan documents, amendments, tax filings and so on.

2.   Administrative for all audit results, contribution records, Fiduciary Plan Review meeting minutes, fee benchmarkings, participant complaints.

3.   Participant Communication containing copies of enrollment materials, communications and memos, and meeting sign-in sheets.

4.   Investments with a listing of fund menu with expenses, Fiduciary Investment Review meeting minutes.

If a participant, auditor, or DOL agent requested plan information, could you find it quickly? The key is twofold: keep the things you need and store them so you can find them easily.

Of course, these are only general guidelines. For questions about your specific case, contact your plan advisor to discuss best practices for keeping records.

 *For litigation purposes, we recommend that documents be retained indefinitely.

 ACR#304542 12/18

Posted on December 31, 2018 by retirementtimesnewsletter

Acumen Wealth Advisors, LLC® is affiliated with RPAG and utilizes their robust retirement plan consulting tools and resources to deliver enhanced value to plan sponsor clients.  RPAG™, a wholly owned subsidiary of NFP (NFP Corp.), provides retirement advisors premier technology, systems, training, and resources through its practice management platforms.

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