The Investment Policy Statement is a legal plan document. It needs to be treated accordingly. This means to deliberate it with diligence before adopting it. Even when it is adopted, it must be regularly inspected and revised as needed.
Compliance
There are many different types of plans, particularly when plan sponsors pick a 3(21) or 3(38) adviser. Which service provider arrangement a plan sponsor chooses impacts how the IPS will be constructed – and how the relevant parties contribute to that draft.
When you’re not an expert in an important job that you need done, what do you do?
MEPs have the potential to do what state-sponsored plans may not be able to offer – protection under ERISA. That’s in the employees’ best interests. If many embrace this concept, September 30, 2019 may indeed signal the dawn of a new day in retirement saving. Still, due diligence remains an imperative.
Just as summer changes into fall, Reg BI will change the way all participants – investors, service providers, and 401k plan sponsors – interact with each other. These are the changes we might expect.
As we approach clarity with regards to Congressional action and/or implementation of the Trump Executive Order, we may find need to expand these MEP guidelines. Until then, though, companies in business associations where commonality exists may wish to use these ground rules when determining if a 401k MEP is the right course to take.