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What to Have in Your Department of Labor (DOL) Audit File

When managing a qualified retirement plan, it is important to retain proper documentation that establishes compliance with the Employee Retirement Income Security Act of 1974 (ERISA). The following list contains various items that should be retained in what is oftentimes called a DOL Audit File. Although this list is intended to help you further your fiduciary compliance, it may not contain all necessary items. Please review this list, as well as your actual compliance files, with your corporate counsel.

Plan Documents

  • Plan Document
  • Plan Amendments and corresponding Resolutions
  • Summary Plan Description (SPD)
  • Summary of Material Modifications (SMM)
  • Trust Documents if applicable
  • Summary Annual Report
  • Evidence of Fidelity Bond Coverage (if applicable)
  • Fiduciary Liability Insurance Policy (if obtained)
  • Notice to plan participants that the Plan intends to comply with the requirements of 404(c) of ERISA (usually contained within the Summary Plan Description)

Service Agreements

  • With 401(k) Plan Platform
  • With Third Party Administrator (TPA)
  • With Financial Advisor

Participant Documents – may be retained in personnel file

  • Enrollment Forms – participants who choose not to defer, must also complete Enrollment
  • Forms upon becoming eligible for the plan.
  • Beneficiary Designations
  • Requests to Change Deferral Amount (in writing, or electronic)

Form 5500 series filing, including all applicable schedules

Records of Nondiscrimination Testing required for your plan type

Hefren-Tillotson Annual Fiduciary Review

  • Investment Policy Statement
  • Investment Performance Reporting
  • Plan Cost disclosure
  • Hefren-Tillotson Form ADV Part 2A

Hefren-Tillotson Annual Retirement Plan Scorecard

  • Participation Rates
  • Deferral Rates
  • Investment Performance Reporting
  • Plan Cost disclosure
Investment Advisory Team

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