The importance of a fiduciary checklist.
In the Lifelock commercial about internet security recreating a bank robbery, the bank customers lying on the ground ask the guard standing and watching why he is not helping. The guard responds, “Oh, I’m not a security guard, I’m a security monitor. I only notify people if there’s a robbery…There’s a robbery.”
Companies sponsoring a defined contribution under ERISA can seem under siege when the DOL comes in to audit their plan or when hit by a lawsuit. The key is having professional “guards” like TPAs and advisors to not just tell plan sponsors when there is a problem but actually do something which can start with a fiduciary checklist and monitors.
At a TPSU training program held at NYU, the plan fiduciary of a young not for profit company with 130 employees led by Adjunct Lecturer Jamie Greenleaf noted that she feels the needs to be periodically reminded about deadlines and duties through a fiduciary calendar and checklist. The calendar and checklist makes her feel more empowered to run her plan just as the training at TPSU did which made her feel more equipped and empowered to run her plan.
A Noted TPA Employee Fiduciary has created a simple but complete fiduciary checklist for end of year tasks as well as well as 2016 obligations covering:
- Nondiscrimination testing
- Reporting to the government
- Participant disclosure
- Maintenance of Plan Docs
In addition, there are a number of important ad hoc tasks that may not have deadlines but are nonetheless important.
So if you want to know if your plan advisor and TPA are doing a good job, a good place to start is to ask if they are proactive. Because you don’t just want someone to tell you that there’s a problem – you want them to take steps to avoid problems to begin with which starts with fiduciary calendars and a fiduciary checklist.
