Do you have what it takes to make it through a retirement plan audit unscathed? A labor and employment law attorney has revealed the secrets to shrugging off the DOL’s compliance cops.
On his Employee Benefits Legal Blog, Keith R. McMurdy of the Philadelphia law firm Fox Rothchild, LLP, recently posted a list of the most common document requests from the DOL.
Here’s what he says you’ll need:
- Plan document and all amendments to it
- Summary plan description (SPD)
- Investment policy statement
- Copy of the most recent IRS determination letter
- Copies of Forms 5500
- All plan notices, communications and meeting minutes
- Investment analyses and reports
- Discrimination testing results
- Account statements for participants and beneficiaries, along with contribution reports, and
- Loan applications and repayment schedules.
How long should you keep these documents around? McMurdy recommends keeping at least six years of information. But the best practice would be to keep it all as long as possible.
One way he recommends keeping older info: Scanning all the plan documents and filing them electronically. It saves space and allows for quicker access/reference.
The most common mistakes McMurdy says plan sponsors make:
- Failing to keep signed plan documents
- Keeping an incomplete record of amendments to the plan, and
- Having lax loan documentation procedures and repayment schedules.