Did you know Department of Labor investigations consistently find failures in over 70% of retirement plan audits? These findings could be anything from failing to monitor the plan to defects in plan administration to misinterpreting plan provisions. Since spring is now officially upon us, consider a few suggestions for cleaning up your retirement plan.
Review your plan documents
First of all, it’s pretty helpful to know where they are – an auditor would certainly want to. Plan documents include the adoption agreement, amendments, summary plan description, investment policy statement, and so on. If you don’t have a fiduciary file or secure online vault in which to store these documents, start one today. Request any missing documents from the appropriate parties. Next, verify your plan documents are compliant with laws and regulations; amend them as required. Most importantly, though, ensure you are adhering to them!
Know your roles
To be compliant, the people running your day-to-day operations need to understand both the plan documents and their fiduciary duties. Define roles and clarify responsibilities. Don’t forget to document these assignments, as well as the processes to implement them – it may be beneficial to utilize a committee charter, fiduciary acceptance and acknowledgement letters, or a retirement plan internal controls policy. It’s important to be aware of all the fiduciaries serving your plan, because you have potential liability for their actions. And even if you have delegated certain fiduciary duties to others, you still retain fiduciary responsibility for prudently monitoring their performance.
Monitor the contribution process
The most common ERISA violation is making delinquent contributions and loan repayments. No matter who is responsible for remitting contributions, you must know your plan’s reasonable standard and understand the overall remittance process. Take care to monitor the responsible parties so you are attuned to issues as they arise; if they do, work with an advisor to determine how you should correct late payments, as well as report delinquent payments on your Form 5500.
Schedule your audit
If you haven’t done so already, schedule your plan’s required audit. Take care as you select your auditor: an auditor plays an important role in the health of your plan, so be sure to ask clarifying questions regarding their capabilities, workload, credentials, etc. Exhibit due diligence by documenting your selection process.
Clear the clutter
You also have a fiduciary responsibility to monitor the assets held in your plan and prudently act on your participants’ behalf. This includes terminated participants with account balances in the plan. And that’s not all. Those terminated participants are also required to receive benefit statements and plan disclosures. Depending on your service agreements, you may be paying a per-participant fee to maintain these terminated account balances. Discuss with your advisor if it would be beneficial to initiate a force-out campaign – following the terms of your plan document, of course!
Look ahead
You have three quarters left to achieve the goals initially set for 2018. Preparing participants for retirement might be high on the list (we sure hope so!), but have you put plans in place to make it happen? Pull out your calendar and prioritize time for your employees – schedule enrollment and engagement meetings to increase their financial wellness. Equip them with the tools they need to succeed. Determine the metrics you’ll use to track their progress, then decide next steps based on that data.
Being a plan fiduciary is not a duty to take lightly – there are many administrative and compliance-related tasks to perform. But we do believe you should take pride in being a good steward of your company’s retirement plan assets, because it means you are better equipping your employees for retirement. After all, the primary purpose of a retirement plan is to provide benefits for plan participants and beneficiaries. So roll up your sleeves and take time to polish your plan.
Indiana is renowned for its litany of sports legends. You’ve likely heard of fan favorite Peyton Manning or a trash-talking guy named Reggie Miller. Perhaps you’ve seen those little cinematic gems, Hoosiers and Rudy? And in the month of May, it’s commonplace to see Indianapolis flooded with spectators, all eager to witness what’s known as The Greatest Spectacle in Racing – the Indy 500.
Drivers complete 200 laps to try and win this 500-mile race. Their prize? It’s unique – winners get an ice-cold bottle of milk to celebrate their triumph at the Speedway. Yes, there is a monetary prize as well, but many drivers have claimed getting to drink the milk is the better reward – it’s symbolic, celebratory, and a refreshing end to a grueling race.
Here at Shepherd Financial, our passion is helping individuals and plan participants navigate their personal roadmap to retirement. Like Indy 500 drivers, many things are needed along the way: clear vision, endurance, and support from others. The process starts by asking yourself these questions:
· How much money will I need at retirement?
· Where is my retirement income going to come from?
· How much should I be contributing today?
· How should I invest my retirement savings?
· What steps do I need to take right now?
It’s important to remember your working years are a long race, and some seasons may feel achingly repetitious. There are other times when, out of necessity, you must take a pit stop. Life changes – like having a baby, buying a house, or losing a spouse – happen and can feel frustrating (and maybe even like you’re spinning your tires), but we’d encourage you to use those moments to reset and refocus.
Ask for support and let other people help you. A driver may have a great understanding of how his or her car works, but their job on race day is to drive. Changing tires, refueling, and making mechanical tweaks are the responsibilities of the pit team. The driver simply needs to radio the crew and ask for help. In the same way, financial professionals can walk through the roadmap questions with you, enabling you to focus on your current race.
Visualize your end goal and think about what it requires to get there. Yes, you are striving for the monetary prize of funding your retirement income goal. But how will you celebrate actually reaching the finish line? What’s your bottle of milk?