More Common Than It Should Be

September 13, 2013

There is an obvious compliance oversight that happens all too often. And, surprisingly, this oversight is just as common in both large and small organizations. Many companies are inconsistent on their fiduciary governance requirements and create undue risk on their organizations and named fiduciaries merely by failing to properly document meetings and activities of plan committees.

Does your company have a Benefits or Investment Committee that governs the fiduciary aspects of your retirement plans? If so, do they meet with some frequency? Are the agenda, meeting materials and minutes from the previous meeting distributed in advance? Do the meeting minutes appropriately confirm the items discussed and the decisions made? Is there open discussion or do some voices count more than others? Asking these questions can uncover exposure to fiduciary liability that can be easily addressed with proper documentation.

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