Page 145 - MayDefComp
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Background
According to the IRS, a plan fiduciary is defined as:
“anyone who exercises discretionary authority or discretionary control over
management or administration of the plan, exercises any authority or control
a fee or other compensation with respect to assets of the plan.”
over management or disposition of plan assets, or gives investment advice for
The Employee Retirement Income Security While the County’s designated personnel
Act of 1974 (ERISA) states that plan trustees, include the above-mentioned representatives,
plan administrators and members of a plan’s other individuals can be considered, such as
investment committee are all plan fiduciaries. important stakeholders, alternative trustees,
Below is a list of a few important best practices policy-making bodies, or others as desired.
to help guide this responsibility:
• Document! Document! Document! Measurable Benefits
It is imperative to keep files of any
paperwork, correspondence, meetings, Compiling and housing these documents
and conversations regarding the in a single place provides three
retirement plan(s). distinct advantages:
• Creation of a pension and/or investment
committee and an investment 1. Reference for current committee —
policy statement. Centralized location of important key
• Regularly scheduled oversight meetings documents allows Defined Contribution
with the plan recordkeeper. Advisory Committee members a
“one-stop-shopping” solution to access:
• Periodically reviewing the Summary Plan
Document, Adoption Agreement, Base – crucial documents and policies that
Plan Document and service agreements. govern plan operations
and administration
With these best practices in mind, we wanted – current budgetary information
current and prospective Committee members – a quick listing of recent activities
to be able to access documents easily, as by the committee as summarized in
well as provide quick access for internal and quarterly agendas and minutes for the
external audits. The Fiduciary Briefcase brings previous calendar year(s)
what once was material scattered in different
places: websites, past meeting material and 2. New committee member onboarding
minutes, electronic copies of policies and resource — All committees and
procedures, etc. into one place. supporting personnel experience
turnover. Therefore, new plan trustees
Access to the electronic Fiduciary Briefcase and support staff become responsible
is provided to a select group of individuals for committee participation. Even the
interacting with the plan. This includes plan primary contacts at the recordkeeper,
committee members, administrative staff, and consultants experience periodic
and key contacts of the recordkeeper and turnover. This Fiduciary Briefcase allows
consultant. San Mateo County identified all new personnel access, allowing them
an initial group of personnel with the to review plan history and documents
understanding that the County would that may be critical to performing
review the potential designees for further their roles in relation to the plan. It
consideration. The briefcase can be easily represents an efficient method, assuring
modified to add or delete individual access. all parties can expeditiously understand

