We hear time and time again, “what records should I keep, how long should I keep them, and how should I organize my files?” Remember several rules of thumb when it comes to record retention.
- Plan Documents should never be discarded. This includes Basic Plan Documents, Adoption Agreements, Amendments, and Summary Plan Descriptions.
- Annual Filing Reports should be maintained for at least six years. This includes 5500s, supporting materials for contributions, testing results, plan audits, Summary Annual Reports, and distribution records.
- Participant Records should be retained during the participant’s employment and at least six years after the participant’s termination. This includes enrollment forms, beneficiary forms and distribution forms. Loan records should be maintained at least six years after the loan is paid off.
As for organizing your Fiduciary File, we suggest a format that includes the following sections:
- Documents − for all plan documents, amendments, tax filings, etc.
- Administrative − for all audit results, contribution records, Fiduciary Plan Review meeting minutes, fee benchmarkings, participant complaints.
- Participant Communication − copies of enrollment materials, communication memos, meeting sign-in sheets.
- Investments − listing of fund menu with expenses, Fiduciary Investment Review meeting minutes.
The key is twofold: keep the things you need, and store them so you can find them easily. If a participant, auditor, or DOL agent requested plan information, could you find it quickly?
