Every Plan should have a pension plan committee in charge of Plan oversight. Meetings should be held periodically and minutes should be maintained for each meeting. This issue of For Your Benefit addresses some items that should be included on your organization’s board meeting checklist and other helpful hints as you file your Form 5500s.
The following is a list of items that should be documented in the pension plan committee meeting minutes.
- Date, time, location and list of those present at the meeting.
- Administrative and investment fees
- Investment performance
- Employee participation in the plan
- Any decisions made related to underperforming funds or participant issues with the plan
- Plan amendments
Investment professionals should be invited to pension plan committee meetings in order to provide information regarding plan investment performance and fees. They will generally provide the documentation to help the fiduciaries meet their responsibilities.
Are you asking yourself the right questions?
There are some important topics worth considering as you approach the Form 5500 filing deadline for calendar year end Employee Benefit Plans. If you ask yourself the following questions, you can help avoid problems down the road.
Do your plan assets include a forfeiture balance at year end? Forfeited non-vested monies generally should not accumulate in plan assets. Forfeited monies can be used to reduce employer contributions, pay plan expenses, or be reallocated to plan participants; refer to your Plan document for guidance on when and how to use forfeitures.
Remember, the Employer restatement period for the Pension Protection Act of 2006 of prototype plan documents ends April 30, 2016.
Do plan participants have an updated Summary Plan Description (SPD)? The SPD should be distributed to participants within 90 days of becoming eligible to participate in the plan. Further, an updated SPD must be furnished to all participants every 5 years. With restatement, new SPDs will be provided to you by your vendor.
Does your plan have un-cashed benefit checks outstanding? Follow up on outstanding benefit checks with your third party administrator (TPA) and determine the best course of action. Plans cannot terminate until all participant allocated accounts have been distributed.
Does your TPA track participant ages in order to make required minimum distributions or are you responsible? Generally, required minimum distributions should be made by April 1 following the year the participant reaches 70 ½ years of age or the participant retires, whichever is later. Find out if your TPA is making this calculation or if you should be.
If you have questions about your checklist or any of these helpful hints, please contact the TBC Employee Benefit Plan Audit leaders Christine Oliver or Kathleen O’Neil by calling 456-6663 or contacting either of them via email at [email protected] or [email protected].