The rollout of the Affordable Care Act, together with a variety of new plan regulations, made last year anything but typical. Now is the time to check on your retirement plan – before the Department of Labor comes calling.

  • Begin your review by making sure that the retention period of plan records meets DOL regulations. As a rule of thumb: 1) never discard key documents – the plan itself, adoption agreement, amendments and summary plan descriptions; 2) keep annual filing reports – including form 5500s (even though these are filed electronically) and supporting materials – for six years; and 3) retain participant records during the worker’s period of employment, and for at least six years after termination. Store these records in a safe, easily accessible location.
  • Send payroll and employee census data to the plan record keeper for year-end compliance testing.
  • Audit fourth-quarter payroll and plan deposit dates for compliance with DOL rules on timely deposit of participant contributions and loan repayments.
  • Make sure employees who became eligible for the plan between Oct. 1 and Dec. 31 received and returned an enrollment form.
  • Update the plan’s ERISA fidelity bond coverage to reflect plan assets as of Dec. 31. Remember that if the plan holds stock in the employer, bond coverage is higher than for non-stock plans.
  • Remind all employees by e-mail to review and their beneficiary designations for all plans and update them if necessary.
  • Review and revise the roster of plan fiduciaries to confirm each individual’s responsibilities and duties in writing.

Remember that an ounce of prevention can go a long way in case you face a plan audit. We stand ready to offer our professional advice at all times.

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Further Reading
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