Frequently when retirement plans are established, the ongoing governance of plan operation is not sufficiently spelled out. Failure to articulate the fiduciary governance and appropriate delegations of responsibility ultimately enlarges the pool of plan fiduciaries that may be exposed to the risks associated with plan operation.
To follow best practices, a 403(b) Plan Sponsor should establish clear delegations of fiduciary authority, through board resolutions and committee charters. Responsibility for daily plan administration operations, such as approving distributions and loans, should be clearly established. An Investment Policy Statement (IPS) governs the initial selection of suitable investments, outlines the benchmarks for ongoing investment monitoring, and sets forth the criteria for replacement of an investment. Additionally, fiduciary indemnification can be managed through bonding and insurance for the Plan and its named fiduciaries.
At a minimum a 403(b) Plan Sponsor should confirm that the following governance documents (signed copies if applicable) are in the organization’s fiduciary file and up to date. Please use our following 403(b) Fiduciary Governance Document Checklist below as a general guide for assistance:
|Fiduciary Documents||Current Status?||Recommended / Comments|
|Plan Document - Is it Signed?|
|Summary Plan Description|
|Group Custodial Contract - Signed?|
|Annuity Contracts - Signed?|
|Fidelity Bond & Fiduciary Insurance|
|Investment Policy Statement - Signed?|
|Investment Performance Reports|
|Retirement Plan Committee Charter|
|Retirement Plan Committee Meeting Minutes|
|Fiduciary Acknowledgement Letter (FAL)|
|Documents Pertaining to the Selection of Service Providers|
We hope this blog post provides you a solid framework you can follow if you're just getting started in evaluating your 403b fiduciary governance process or if you're concerned about what you may be missing. If you have more questions about your fiduciary duties to your retirement plan, feel free to download our free Fiduciary Responsibility Guide eBook below.
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