What Constitutes 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 designated to a retirement plan investment committee. This committee usually includes financial officers and human resources officers of the employer. The committee meets periodically (anywhere from annually to quarterly) to consider agenda items including investment due diligence, fees and services of plan providers, 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 being prudently executed. Often plans question the degree of documentation necessary. Below are a few suggestions of what the retirement plan investment committee meeting minutes should include:

• A listing of all parties present with identification of roles (committee member, guest, financial professional, provider representative, attorney, accountant, etc.);

• A description of all issues considered at the meeting: fund performance of investments offered, participant communication/education initiatives, plan demographic and provisional review, investment policy statement review, market summary and other topics as appropriate 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; and

• Identification of any topics to be continued in subsequent meetings.