I can\u2019t tell you how many times I hear this from plan sponsors: \u201cThe plan is fine. No one\u2019s complaining.\u201d<\/p>\n
Silence is not a fiduciary audit.<\/p>\n
Participants rarely complain about fees they don\u2019t understand, investment lineups they didn\u2019t choose, or administrative errors they can\u2019t see. A quiet plan is often just a disengaged plan. And disengagement is not a compliance strategy.<\/p>\n
When was the last time your committee benchmarked recordkeeping fees? Not glanced at a report \u2014 actually benchmarked them. When did you last review your investment policy statement and compare it to what\u2019s actually in the lineup? Do your target-date funds reflect your workforce demographics, or are they there because they were \u201cgood enough\u201d ten years ago?<\/p>\n
Fiduciary responsibility under ERISA isn\u2019t about reacting to problems. It\u2019s about process. Documented, consistent, thoughtful process.<\/p>\n
Markets fluctuate. That\u2019s normal. But stale governance is avoidable. If your committee meets once a year to rubber-stamp reports, that\u2019s not oversight \u2014 that\u2019s ceremonial.<\/p>\n
I\u2019ve seen plans that were \u201cfine\u201d for years until a DOL investigator asked for meeting minutes, fee benchmarking reports, and service agreements. Suddenly \u201cfine\u201d turned into \u201cwe meant to get to that.\u201d<\/p>\n
The absence of complaints is not evidence of prudence. It\u2019s often evidence that no one is looking closely.<\/p>\n
If you\u2019re a plan sponsor, assume your plan is not fine until you can prove it is \u2014 with documentation, benchmarking, and regular review.<\/p>\n
Quiet plans don\u2019t stay quiet forever.<\/p>\n
<\/span><\/p>","protected":false},"excerpt":{"rendered":" I can\u2019t tell you how many times I hear this from plan sponsors: \u201cThe plan is fine. No one\u2019s complaining.\u201d Silence is not a fiduciary audit. Participants rarely complain about fees they don\u2019t understand, investment lineups they didn\u2019t choose, or … Continue reading