Fiduciary oversight of 401k plans is vital during these uncertain times
Bradley Bartells, CPA
![Bradley Bartells, CPA]()
Bradley Bartells, CPA
Your “Go-To Guy” for retirement plan and nonprofit financial statement audit expertise!
Plan Sponsors and those charged with the oversight of their 401k plan need to remain diligent in ensuring the safety of their participant’s 401k accounts:
- Continue to meet regularly (at least quarterly) to review the Plan’s activity. Your employees are relying on you to monitor investments, fees, and other Plan activity.
- Make sure minutes are kept from these meetings to document discussions and decisions made.
- If you do not already use one, consider hiring a independent financial advisor to assist your Plan's oversight committee with their review and monitoring of your Plan's investments and activity.
- Communicate to your organization's employees who work with the Plan on a daily basis the continued importance of operating the Plan in accordance with DOL and ERISA guidelines.
- Make sure the members of your Plan oversight committee understand their roles, responsibilities, and duties required to effectively execute their fiduciary duties over the Plan.
- Encourage your employees to contact your plan’s financial advisor if they have questions regarding their investments.
- Provide education to your employees on recent relief programs provided by the government.
- Remember that your HR department personnel are not the fiduciaries. The committee charged with oversight of the Plan has the ultimate responsibility for monitoring the Plan.
- Continue to monitor fees charged by investment funds. Make sure investment fund fees are benchmarked against industry standards on an annual basis.
- If your Plan does not already have one, create an investment policy for your 401k plan. This will provide approved guidance for the roles, responsibilities, and monitoring activities of the Plan Fiduciaries.
- Fiduciaries should continue to monitor and evaluate all outside service providers and periodically review adequacy of services provided and costs charged to the Plan.
Looking for some other sources of 401k Plan Fiduciary Guidance? Here are a few…
EMPLOYER ACTIONS FOR 401(K) PLANS SICKENED BY CORONAVIRUS
http://hr.dickinson-wright.com/2020/03/19/employer-actions-for-401k-plans-sickened-by-coronavirus/
401k Plan Sponsors Fiduciary Duty in Light of Coronavirus Fear
https://fiduciarynews.com/2020/03/401k-plan-sponsors-fiduciary-duty-in-light-of-coronavirus-fear/
COO, CAO, CCO, ERISA consultant
2moadding an example of the Schedule H item 4.a
COO, CAO, CCO, ERISA consultant
2moadding the audit report format image. I am trying to understand the correct process of interpreting what is reported on Schedule H and in the audit report in relation to applying the Schedule H instructions.
COO, CAO, CCO, ERISA consultant
2moHi Bradley - I like you postings. I have scanned your articles to find something regarding the instructions relative to continued reporting of delinquent contributions until "fully corrected" and exactly what that means in relation to the 5500 Schedule H instructions and how the audit report required format of reporting seems to reflect. Given the instructions ... should the auditor continue to report any amount identified as delinquent until "fully corrected" under VFCP as well as have resolved the excise tax payment and filing (via Form 5330)? OR as long as the Plan Administrator makes some type of correction of the total amount of delinquent contributions (within or without VFCP and 5330 filings) - the amount can drop off of the Schedule H item 4.a. item and the audit report?