As a plan sponsor, have you ever wondered how long you should maintain various plan records? Are you running out of storage space for your existing records?
When it comes to 401k record retention and document storage, remember that your number one goal should be to have materials preserved in a format that allows for quick and easy retrieval. It’s appropriate to store plan records electronically whenever possible.
401k Record Retention Guidelines
|Plan Documents (including Basic Plan Document, Adoption Agreement, Amendments, Summary Plan Descriptions, and Summary of Material Modifications)||At least six years after the termination of the plan|
|Annual Filings (including 5500, Summary Annual Reports, plan audits, distribution records and supporting materials for contributions and testing)||At least six years after the termination of the plan|
|Participant Records (including enrollment, beneficiary, and distribution forms; QDROs)||At least six years after the participant's termination|
|Loan Records||At least six years after the loan is paid off|
|Retirement / Investment Committee meeting materials and notes||At least six years following plan termination|
First, Retirement Plan Documents should never be discarded, and they should be stored for the life of the plan. This would include items such as the Basic Plan Document, Adoption Agreement, Amendments and Summary Plan Descriptions (SPDs).
Retirement plan documents are often amended and restated. Here are some helpful record retention tips:
- You need to keep all prior versions of plan amendments and any plan documents that have been subsequently revised.
- A best practice would be to keep signed originals copies in files marked “Plan Documents- Current Version” and “Plan Documents- Prior Versions”.
- If you have scanned electronic copies, the documents should be fully executed with all required signatures and dates.
- Keep in mind that signed originals (not electronic copies) need to be available onsite for review by Department of Labor auditors.
Second are the Annual Filing Items, including the 5500 and all the supporting materials for contributions, testing, plan audit, Summary Annual Reports, and distribution records, and these should be maintained for at least six years.
401k Record Retention for Participant Forms
Finally, all Participant Records should be maintained to determine the amount of benefits accrued by each participant. Enrollment forms, beneficiary forms, and distribution forms should be maintained at least six years after the participant’s termination. Also, loan records should be maintained for six years after the loan is paid off.
Here’s the good news: Most participant records can be maintained by your retirement plan vendor, so take the time to understand what they do and do not archive. For example, if beneficiary designations are not maintained online by your vendor, you as the employer are responsible for keeping these forms current.
If you have any questions about 401k record retention, please contact us, your 401k Advisors.Related Topics
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