Organizing Your Fiduciary File

As a plan sponsor and fiduciary of your company’s retirement plan, keeping an up-to-date fiduciary file is critical. To begin, Asset Advisors of America recommends preparing your file in four key sections: Documents, Administrative, Participant Communication, and Investments. Contents of each section could include the items listed in the table below.

Documents Section:

Plan Document and Amendments
IRS Determination Letter (Opinion Letter if prototype)
Summary Plan Description
Investment Policy Statement
404(c) Policy Statement and Notice
Form 5500 (5 years)
Service Provider Contracts
Salary Deferral Agreement
Material Modification

Plan Loan Documents
Form 5330 (if necessary)
Nondiscrimination Test Results
Corporate Tax Return copies
Corporate Board Resolutions
Summary Annual Reports (5 years)
RFP Results
Committee Charter
ERISA Fidelity Bond
ADV II and Schedule F (if required)

Administrative Section:

Evidence of Employer Contributions (5 years) Distribution Documents
Default Safe Harbor, Automatic Enrollment Notices
Audit Results (IRS, DOL)
Annual Plan Review Executive Summary
Participant Complaints
Significant Business Events (Sale, Purchase, etc.)
Fiduciary Liability Insurance Contract
Correspondence (DOL, IRS, etc.)

Participant Communication Section:

Enrollment Material
Documentation of all Communication Events (meetings, emails, posting, etc.)
Material to be provided automatically
Material to be provided upon request

Investments Section:

Enrollment Material
Documentation of Investment Activity
Executive Summaries from Committee Meetings
Current Fund Menu and Expenses

About Asset Advisors of America’s Retirement Plan Advisory Group
Asset Advisors of America’s Retirement Plan Group is a dedicated defined contribution consulting firm that provides fiduciary consulting to plan sponsors. Learn more contact 866-657-401(k) or email matt.scovanner@ioausa.com.