Plan sponsors aren\u2019t the greatest keeper of plan records because as a plan fiduciary, they think they get too many reports, prospectuses, and plan documents.\u00a0 It\u2019s a lot paper to keep, but in a world of mobile storage thanks to scanning, plan sponsors get even less sympathy for all that paper.<\/p>\n
Plan sponsors after a certain time can toss out certain reports. A 2001 investment policy statement is of little use now, but all plan documents and amendments should be kept. In most plan audits, the one thing that plan sponsors don\u2019t have are fully executed plan documents and that\u2019s a problem because an unsigned or undrafted amendments from 1993 can be a problem for the plan sponsor today. If plan documents and amendments are unsigned or missing, the government auditor usually takes the position that they were never done.<\/p>\n
So when you get copies of plan documents and amendments to sign by your third party administrator or ERISA attorney, sign and date it the day you get it. Then scan it to make sure you have a copy of it if you misplaced the original. It\u2019s just common sense, but most of the time, I rarely see all plan documents fully dated and executed. So get those plan documents signed and dated and put them in a safe place.<\/p>\n
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