He also reveals the greatest misconception regarding MEPs, what the SECURE Act really did, and when we might begin to see the mass media start paying attention.
Tag "plan sponsor"
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.
“As far as adopting employers, I would recommend an ERISA attorney because an MEP isn’t the right fit and fiduciary solution for every plan sponsor.”
Including these will make 401k plans safer for plan sponsors and more successful for plan participants.
Perhaps, just as plan sponsors have developed onboarding programs for new hires when it comes to saving for retirement, maybe they should add “unboarding” programs as a bookend for those nearing retirement.
Whether a plan sponsor decides to adopt a 401k IPS remains an open question. It’s not a question that should be treated casually. Every plan situation is different. Plan sponsors therefore must conduct a thorough due diligence to determine what’s best for their plan.
Although we’ve seen a broader acceptance of using an IPS, their use is by no means universal and particularly lacking among smaller employers. Perhaps there’s a realization that, if you don’t get the IPS right, you’ll only increase your liability.
Not being able to easily monitor how former employees apply these tools, however, can increase the fiduciary liability of plan sponsors.
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.
