RETIREMENT SOLUTIONS

Fiduciary Vault

Plan governance is complex. We are here to help simplify.

Your Pillar Advisor
Adriana Courts, AIF®, CPFA®
adriana.courts@pillarintl.com | 206-736-0509

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Overall Plan Governance: Processes and Procedures

Document the work we (client + Pillar) have done together related to prudent plan administration.

File list:

  • Administrative documentation
    • Outside service providers and consultants
    • Department of Labor (DOL) 408(b)(2) plan fee and service disclosure form
    • Service organization controls reports
    • Committee Changes
    • Fiduciary Liability Insurance
    • Fidelity Bond
    • Plan committee activity
      • Fiduciary acknowledgments
        • Fiduciary acknowledgments template
      • Meeting minutes
        • Meeting Minutes Template
      • Succession planning steps
      • Attendance Records
      • Training and educational materials

Plan Documents

  • Plan administrators
  • Plan documentation (for each plan retained)
    • Signed Plan Document and Adoption Agreement
    • Amendment Process
    • Plan Amendments
    • Board Resolutions
      1. Sample board resolution template
    • Summary Plan Descriptions (SPD) and Summary of Material Modification (SMM)
    • Funding vehicles
  • IRS Opinion Letter or Determination Letter (if applicable)
  • Participant Notice File

Investment Policy and Management

  • Investment Policy Statement (IPS)
  • Quarterly Investment Monitoring Reports and Notes
  • ERISA section 404(c) (If applicable) – Demonstrate compliance
  • Vendor Compliance – Representation from providers stating their ability to meet applicable legislative and regulatory requirements (e.g. SECURE Act)

Compliance Monitoring

  • Vendor Representatives
  • Operational Compliance
    • Contributions
    • Nondiscrimination and other Compliance Testing
    • Distributions
    • Required Minimum Distributions (RMD)
  • Transactional Compliance
    • Loan documentation
    • Ongoing contribution limits monitoring
    • Service Organization Controls Report – process for coordinating (formerly SSAE 16)

Participant Disclosure and Communication

  • ERISA participant disclosures
  • Federal tax code required disclosures
  • Financial education…
  • Targeted Communications

Annual Plan Review and Reporting

  • Form 5500 – Working Files
  • IRS Form 5500 and 8955-SSA filings – include audited statements
  • Participant Fee Disclosure (404(a-5)
  • Annual Plan Review (one per plan)

Contracts and Agreements

(May include service provider agreements, annuity contracts, etc.)

  • Recordkeeper Agreement
  • Financial Advisor Agreement
  • Investment Model Manager Agreement
  • Miscellaneous

Templates

  • Overall Plan Governance | Processes and Procedures
    • Initial meeting minutes template
    • Fiduciary acknowledgment template
    • Ongoing meeting minutes template
  • Plan Documents
    • Sample board resolution template