Running a fully compliant retirement plan under the Employee Retirement Income Security Act (ERISA) is undoubtedly a critical responsibility, a new Arnerich Massena white paper argues, but that doesn’t mean it has to be overly difficult.
To help plan sponsors and other fiduciaries meet their prescribed duties under ERISA in an efficient way, the investment services and consulting firm has published “Retirement Plan Best Practices: Plan Governance.” The white paper spells out the main areas of retirement plan governance and compliance, offering clear pathways for plans to consider following in order to improve compliance processes.
For example, the paper argues that all ERISA-covered plans must have a handful of specific procedures and documentation in place. “Best practice is to have at least these three governing documents: Summary Plan Description (SPD), a Committee Charter and an Investment Policy Statement (IPS).” According to Arnerich Massena researchers, these three plan documents together will “outline the key features, philosophy, processes, and procedures of the plan.”
“The plan documents should be maintained and reviewed at regular intervals, typically annually except in cases where changing circumstances necessitate a review and update sooner,” the white paper recommends.
In terms of what each document should include, the paper suggests the SPD should “outline the key features of the plan.” The document fulfills legal requirements and provides participants with an understanding of basic plan provisions. As such, a plan’s SPD must outline the rules by which the plan is governed, and covers such topics as employer contribution and vesting information, eligibility, plan loans and withdrawals, distributions, and contact information for questions. Importantly, the paper recommends the SPD “should be written in language participants can easily understand.”
When it comes to the Investment Committee Charter, this document “doesn’t need to be elaborate, but it should outline some fundamentals, providing committee members with the scope and range of authority to empower them to manage the plan and fulfill their fiduciary responsibilities.”
Further, according to Arnerich Massena, the charter should “specify activities for which the committee is responsible, such as coordinating vendor analysis and recommending plan design features; define the governing bodies with whom the committee must consult and to whom they need to provide recommendations; define how committee members are selected or appointed; establish how often regular committee meetings should occur; and define the roles of any outside consultants.”
NEXT: Sizing and managing the committee