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As a retirement plan sponsor, one of your responsibilities involves making sure every action taken for the plan is recorded and documented. While of course you hope not to receive an official request to provide history and documentation on actions taken, you must prepare for the possibility.
Part of properly preparing involves keeping detailed records of meetings that discuss your company's retirement plan. Accurate meeting minutes will help you in several ways:
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Keeping detailed meeting minutes shows your commitment to open, honest communication and accurate documents.
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If the Internal Revenue Service (IRS) or the Department of Labor (DOL) ever questions actions taken by your plan, your meeting records will explain the options discussed, actions taken, and reasons for those actions.
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In the event any plan records are accidentally lost or destroyed, detailed meeting minutes will help you reconstruct missing records, as required by law.
To get the best outcomes from your meetings, here are some rules for producing minutes for your retirement committees:
1. Outsource
Often, your service provider will be happy to record and distribute meeting minutes if you request it.
2. Stay consistent
Follow a template so that you don't need to start from scratch every time. Keep a consistent format and order of presentation. Here's a good order to follow in your meeting minutes documents:
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Review and approve the previous meeting minutes
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Document what's been accomplished since the previous meeting
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Document what needs to be done
3. Start with the basics
The beginning of your meeting minutes should cover the easiest topics:
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Who was in attendance
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When the meeting was held
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Where the meeting took place
4. Keep it simple
There's no need to record every word said. Who has time to write or read such a document? Just summarize the events of the meeting, discussions held, solutions offered, and decisions made. If supporting materials were part of the discussion, include a note that supplementary materials have been added to the minutes.
5. Note action items
Productive meetings often end with a number of assigned tasks. Document the tasks and assigned names. Creating this list will help save time in your next meeting, when you'll check progress on tasks.
6. Concentrate on opportunities for improvement
Discussing a problem with your retirement plan does no good unless you're attempting to remedy the problem. When documenting issues with the plan, be sure to phrase those issues as opportunities to improve the plan. For example, instead of simply documenting complaints about fund fees, document the committee's ideas for ways to decrease fees and actions taken.
Unfortunately, for purposes of legal documentation, if there is no record of a meeting, you have no proof the meeting took place. Protect yourself and your business by keeping accurate records of every meeting, using the tips above. For help from a partner with expertise in plan fiduciary duties, talk to an SWBC advisor.
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