“What records should I keep? How long should I keep them? How should I organize my files?”
Advisors have been asked these questions time and time again by plan sponsors looking for a general guideline for record expiration dates.
Record retention doesn’t need to be a mystery, and the filing system doesn’t need to become a tomb. For audits, remember the following requirements.*
Retention Requirement for Audit Purposes
Plan Documents (including Basic Plan Document, Adoption Agreement, Amendments, Summary Plan Descriptions, and Summary of Material Modifications)
At least six years following plan termination
Annual Filings (including 5500, Summary Annual Reports, plan audits, distribution records and supporting materials for contributions and testing)
At least six years
Participant Records (including enrollment, beneficiary, and distribution forms; QDROs)
At least six years after the participant’s termination
At least six years after the loan is paid off
Retirement / Investment Committee meeting materials and notes
As for organizing your fiduciary file, we suggest a format that includes the following sections:
If a participant, auditor, or DOL agent requested plan information, could you find it quickly? The key is twofold: keep the things you need and store them so you can find them easily.
Of course, these are only general guidelines. For questions about your specific case, contact us.
This information is not intended as authoritative guidance or tax or legal advice. You should consult your attorney or tax advisor for guidance on your specific situation. In no way does advisor assure that, by using the information provided, plan sponsor will be in compliance with ERISA regulations.
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