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QOTW: Plan Documents

For our last QOTW in 2022, we asked members about their plan documents. We have heard that plan documents can be a challenge to read and understand, especially if they have been updated and amended repeatedly. PSCA’s National Conference Committee is planning a session at next year’s National Conference to help plan sponsors understand these documents and wanted to know what challenges sponsors face with regard to their plan documents. We asked plan sponsors how frequently they review their documents, and if they have any specific concerns.

Nearly half review their documents annually while nearly 40 percent review it every few years. Some plan sponsors review it more frequently than annually, and several stated that they review it when a specific issue arises or if there is new legislation that will require the plan to be updated. More comments about plan documents follow.

  • All plan documents must have a common thread.  What is the best approach to learning a new plan document?  What is the best approach to reviewing your company's plan documents?
  • At least annually with TPA. More often as questions or consideration of changes arise.
  • Frequency also depends if anything passed in congress that causes amendments, especially in relation to existing plan sections
  • I refer to the Plan Document regularly as issues arise.  I also teach my staff to use it as the authoritative resource for answering questions.  The last full review was in 2019 when we restated the document.
  • I wish we still could get determination letters from the IRS.
  • If there are any relevant legislative changes, we would review and update at an earlier time, however, for major plan design changes we've limited those to an annual update.
  • No concerns regarding our plan document. The semi-annual review is to ensure we remain compliant with emerging laws and regulations as there are times we are mandated to incorporate changes and have limited time to do so. Therefore, we include the review as part of our semi-annual retirement plan review.
  • No concerns.  We just completed a Spin-Off, and a Restatement.  We made some very minor adjustments to the Plans (especially the spin-off).  It's certainly beneficial to review the plan frequently so we ensure we are in compliance.
  • No present concerns for 2022.
  • No, it's important to me to have a good understanding of the document and make notes in anticipation for recommended design changes to meet the challenges of today's employee market.
  • No.  The Advisory Committee documents all modifications in our meeting minutes and update the plan document as needed.
  • No.  We have our ERISA attorney review it along with TIAA.
  • No. We just like to revisit and discuss options quarterly to ensure we are staying up to date with the latest options with plan designs.
  • Our plan document recently went through an extensive review, internally as well as with external attorneys.
  • Our provider keeps us informed of changes that need to be made as laws are changed.  Our company board has not asked to see the doc. since we did a switchover 10 years ago.
  • Recently restated, pretty up to date.
  • The plan document is reviewed as we consider changes to the plan on annual basis.
  • Though it's tedious, I'm finding it's important to review it to update accordingly to current practice instead of adding onto it with new information - clean up should be consistent with updates.
  • We are always double checking our plan document to make sure we are compliant with our current process or if we want to do a new initiative.
  • We are completing a plan restatement by 12/31/22. No concerns.
  • We generally review the document and any potential amendments annually.
  • We have our ERISA attorney update our Plan Document for legislative updates.  We review our Adoption Agreement every several years.
  • We just restated our plan document last July.  We had a new recordkeeper and it was difficult process.  We already have to do an amendment to fix something they did wrong.
  • We just rolled over our plan to a new provider in 2021; therefore, I was involved in a thorough review.  Before that, I had not ever fully reviewed.
  • We revised the plan document this plan year so we are very familiar. Very templated.
  • We try to keep our plan document as flexible as we can to attract as many participants as possible and to give them features that benefit them now and in the future such as immediate enrollment, no vesting for company match, Roth option, in plan withdrawals, and in plan Roth conversions.
  • We use a Volume Submitter Plan Document. Our custodian updates the Plan Document about every 4 years, and we update our Adoption Agreement at the same time.  From time to time, we may amend our Adoption Agreement, if we have a need to.
  • Which the plan document was laid out better for those of us that are not "professionals" it is sometimes difficult to find the section that applies to the question or issue that you have.