Page 145 - MayDefComp
P. 145

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
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