Fiduciary Checklist

Following this checkist of retirement plan guidelines can help manage your fiduciary responsibility as a plan sponsor.  We suggest reviewing this checklist annually to determine how well your plan adheres to each guideline.

Document your investment policy statement

  • Create and maintain a written document, monitor it and follow it.
  • Select prudent investments.
  • Periodically review your investment policy statement and investment options.

Select investment options

  • Select a group of prudent investments that helps the plan meet 404(c) requirements.
  • Offer at least three “core” investments with materially different risk and return characteristics.
  • Allow participants to build portfolios from the investment menu with risk and return characteristics suited to individual situations.
  • Permit participants to transfer among core investments at least every three months.
  • Explain plan provisions and investment options to participants.

Notify participants that yours is a 404(c) plan and provide disclosures

  • Explain that your plan voluntarily complies with 404(c) and that plan fiduciaries may be relieved of liability for investment losses.
  • Explain procedures and limitations for giving investment instructions.
  • Identify the fiduciary responsible for providing 404(c) disclosure information.
  • Explain employees’ voting rights and restrictions.
  • Disclose transaction fees and expenses, including commissions and sales loads.
  • Describe information that is available on request.

Explain investment options to plan participants

  • Describe investment options, including objectives and risk and return characteristics.
  • Provide printed or online copies of fund prospectuses either immediately before or after initial investment.

Educate employees about retirement planning

  • Explain the benefits of participating.
  • Provide general financial planning and investment information.
  • Use asset-allocation models for participants with varying risk tolerances and time horizons.
  • Use interactive materials (worksheets, questionnaires, software, etc.) to help participants estimate retirement income needs and assess the effect of various asset allocations on those needs.
  • Maintain records of all education efforts.

Consider adding a corporate trustee to your retirement plan for overall plan assistance and additional fiduciary protection.