If a fiduciary must vote proxies, following the DOL’s guidance may represent the most practical alternative.
Compliance
Do you know the answers to the most important MEP/PEP questions – or do you only think you know the answers to the most important MEP/PEP questions?
Unless state-sponsored efforts can defy the stultifying reality of any political process, they are unlikely to pivot fast enough to overcome the fast-paced offerings coming from these private sector offerings.
This isn’t free money. It comes at a price. Many naïve folks might be salivating at the prospect of releasing these big bucks from the prison of their retirement plan… until they read the fine print.
When doing what’s in the best interests of the employees takes on an entirely new meaning.
An IPS must be thoroughly documented and clearly written and understood by all interested parties. Here’s what to include.
Since the plan sponsor tends to rely on third party service providers (usually the recordkeeper) to maintain and operate these web-based gateways, this should be a significant factor when deciding which vendor to select.
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.
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.
Including these will make 401k plans safer for plan sponsors and more successful for plan participants.
