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What is proper documentation of retirement plan committee meetings?


With most retirement plans, the fiduciary responsibility of selecting and monitoring the plan’s menu of investments is delegated to a retirement plan investment committee. This committee usually includes the employer’s financial officers and HR officers. The committee meets periodically (anywhere from annually to quarterly) to consider agenda items such as investment due diligence, fees and services of plan providers, the status of plan goals, etc.

From a fiduciary perspective, it is just as important to properly document these meetings as it is to hold the meetings; proper documentation serves as proof that the committee’s responsibilities are executed prudently. Often, plan committees question the degree of documentation necessary. Below are a few suggestions of what retirement plan investment committee meeting minutes should include:

  • A listing of all parties present, with identification of roles (e.g., committee member, guest, financial professional, provider representative, attorney, accountant, etc.).
  • A description of all issues considered at the meeting (e.g., fund performance of investments offered, participant communication/education initiatives, plan demographics and provisional review, investment policy statement review, market summary and other topics relevant to achieving and maintaining a successful plan).
  • Documentation of all materials reviewed during the meeting.
  • Documentation of all decisions made and the analysis and logic supporting each decision.
  • Identification of any topics to be continued in subsequent meetings.

For those topics related to services provided by RSM, complete documentation will be included in the executive summary, which your financial professional provides after each meeting. These documents should also be saved so you can access at any time during the year.

For more information, contact your plan’s financial professional.

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