Where Are Your 401(k) Plan Documents?

If someone asked you, as one of those involved with management of your company’s defined contribution plan, to provide a copy of the 401(k) plan document and related amendments, would you know where to find them?  All too often plan sponsors are unable to locate the current version of their 401(k) plan documents and amendments.   Frantically, they scour their files, emails and folders for the documents, only to find multiple versions of what looks to be similar documents which are unsigned and therefore lacking formal execution.  In other instances, the plan sponsor will even be unable to secure a signed and executed version from the company who assisted them with the implementation of the plan.

As a plan sponsor, it is paramount to maintain a complete copy of the signed plan documents and all related amendments for all of your defined contribution and defined benefit plans.  A common mistake observed by the Internal Revenue Service is unsigned plan documents, which can lead to penalties being accessed on the plan sponsor. Thankfully there are ways to fix this mistake, so avoid delay!  The time to determine if you have all of your plan’s documents is now. 

Denise Finney is a Director in the Pension Services Group dedicated to employee benefit plan audits. With 15 years of public accounting experience, she specializes in assisting clients with annual audit requirements regarding employee benefit plans.

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