Fiduciary Audit File Checklist
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This document is a checklist for conducting a fiduciary audit of a retirement plan. It contains 11 sections that correspond to tabs in the audit file, including plan documents, government filings, financial records, compliance with regulations, and records of service providers and meetings. Maintaining documentation is important for fulfilling fiduciary duties. The checklist includes over 50 items to verify that required documents are retained and located properly. Regulations require maintaining most documents for 6 years.
Fiduciary Audit File Checklist
- 1. Page 1 of 9 Fiduciary Audit File Checklist The Fiduciary Audit Checklist has been organized into eleven major sections as listed below which represent the tabs of the Fiduciary Audit File to be maintained. Documentation is critical in fulfilling the role of fiduciary. 1. Plan Documents 2. Government/Regulatory Requirements and Communications 3. Journals and Ledgers 4. Section 404(c) Compliance 5. ERISA Fidelity Bond 6. Participant Communication Documents 7. Investment Policy Statement 8. Third Party Service Providers 9. Plan Procedures and Minutes of all Meetings 10. Section 408 (b) (2) Compliance 11. Section 404a-5 Compliance
- 2. Page 2 of 9 *Regulations require that plan documentation be maintained for a minimum of six years after the filing date (United States Code, Department of Labor, Pub. L. 93406, title I, Sec. 107, Sept. 2, 1974, 88 Stat. 850; Pub. L. 10534, title XV, Sec. 1503(d)(5), Aug. 5, 1997,111 Stat.1062.) Retaining documents for longer periods may serve as a prudent safeguard against ongoing liability for plan fidu ciaries. No. Fiduciary Audit Item Document Location Document Date Notes 1 Plan Documents 1a Plan and Trust Documents with all amendments, addenda, and attachments □ Located in Audit File □ Documents Located: _________________ 1b Summary Plan Description including all amendments, addenda, and attachments □ Located in Audit File □ Documents Located: _________________ 1c Summary of Material Modifications to the plan with all amendments, attachments, and addenda □ Located in Audit File □ Documents Located: _________________ 1d Adoption Agreement if prototype plan □ Located in Audit File □ Documents Located: _________________ 1e Summary Annual Reports for past six plan years* □ Located in Audit File □ Documents Located: _________________ 1f Trustee Reports (including all reports and statements from service providers) for past six plan years* □ Located in Audit File □ Documents Located: _________________
- 3. Page 3 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 2 Government/Regulatory Requirements and Communications 2a Internal Revenue Service Form 5500 as filed for the past six plan years* □ Located in Audit File □ Documents Located: _________________ 2b Audited Financial Statements that accompany the 5500’s and any applicable notes □ Located in Audit File □ Documents Located: _________________ 3 Journals and Ledgers 3a Journals, ledgers, account statements (including bank and trust statements), appraisals and other evidence to support all assets/investments □ Located in Audit File □ Documents Located: _________________ 4 404(c) Compliance 4a Completed 404(c) Checklist detailing compliance activities □ Located in Audit File □ Documents Located: _________________ 4b 404(c) Letter of intent, including -List of investments -Description of frequency of allowed investment changes -Notification to participants of intent to be 404(c) compliant -instructions to obtain further information □ Located in Audit File □ Documents Located: _________________ 4c Record/Log of Plan Participant Information Requests and how fulfilled □ Located in Audit File □ Documents Located: _________________
- 4. Page 4 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 5 ERISA Fidelity Bond 5a Copy of the Fidelity Bond Policy- amount of the bond that must be at least 10% of the value of the plan assets, but not less than $1,000. The ERISA bond is not required to (but may) exceed $500,000 □ Located in Audit File □ Documents Located: _________________ 6 Participant Communication Documents 6a 401(k) Plan Promotional Materials- copies of all plan marketing materials, including education materials □ Located in Audit File □ Documents Located: _________________ 6b Investment Options- documents showing description of all options and related changes since the inception of the plan □ Located in Audit File □ Documents Located: _________________ 6c Participant Communications- from the plan administrator or plan sponsor □ Located in Audit File □ Documents Located: _________________ 6d Prospectus- or other disclosure material relating to the investment options provided to the participants □ Located in Audit File □ Documents Located: _________________ 6e Sample of Participant Account Statement □ Located in Audit File □ Documents Located: _________________
- 5. Page 5 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 7 401(k) Investment Policy Statement 7a Executed IPS prepared in sufficient detail to include the following information *Evaluation of the specific needs of the plan and its participants *Investment objectives and goals of the plan *Definition of the duties and responsibilities of all parties involved *Due diligence criteria for selecting investment options for the plan *Classes, styles and restrictions on investments authorized *Standards and benchmarks of investment performance for comparison *Policy and procedures related to the hiring, monitoring and replacement of investment managers *Procedures for monitoring and controlling investment expenses □ Located in Audit File □ Documents Located: _________________
- 6. Page 6 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 8 Third Party Service Providers 8b Investment manager reports on performance, fees, and compliance to investment guidelines □ Located in Audit File □ Documents Located: _________________ 8c Third Party Administrator Copies of service agreements, correspondence and fees. □ Located in Audit File □ Documents Located: _________________ 8d Attorney and/or CPA Copies of service agreements correspondence and fees □ Located in Audit File □ Documents Located: _________________ 8e Copies of all service agreements and all related correspondence with all former, current, and potential consultants, asset allocation, and/or recordkeeping and custodians □ Located in Audit File □ Documents Located: _________________ 9 Plan Procedures and Minutes of all Meetings 9a Investment Committee Meeting Minutes □ Located in Audit File □ Documents Located: _________________ 9b Administrative Committee Meeting Minutes □ Located in Audit File Documents Located: _________________
- 7. Page 7 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 9 Plan Procedures and Minutes of all Meetings 9c Plan Procedure Manual to include: *Enrollment forms and procedures *Loan and hardship withdrawal forms and procedures *QDRO and claim procedures *Forms: rollover requests, plan distributions, and other miscellaneous forms used □ Located in Audit File □ Documents Located: _________________ 10 Section 408 (b) (2) & 404a-5 Compliance 10a List of service providers A list of services provided to the plan. □ Located in Audit File Documents Located: _________________ 10b A statement that confirms if the services are provided as a fiduciary. □ Located in Audit File Documents Located: _________________ 10c The amount of compensation expected in exchange for these services, including: • Compensation to be received directly from the plan. • Compensation to be received indirectly from other parties. • Payments among related parties, including affiliates and subcontractors. • Compensation in connection with termination of the contract or arrangement. The manner in which compensation is to be received. □ Located in Audit File Documents Located: _________________
- 8. Page 8 of 9 No. Fiduciary Audit Item Document Location Document Date Notes 11 Section 404a-5 Compliance Plan Related Information • Explanation of the circumstances under which investment instructions may be given and any specified limitation of such instructions; identification of the investment options available under your plan. • Explanation of administrative fees/expenses for general plan administration services, such as legal, accounting and recordkeeping services, and how these fees will be allocated to the participants and beneficiaries, and • Explanation of individual fees and expenses that will be charged to the participants and beneficiaries (e.g. loan fees and transaction fees). Investment-related information about each investment option available under your plan: • Identifying information about each investment option, • Performance and benchmark data, • Fees and expense information, • Glossary of terms, and • Website address for each investment option to access additional information for that option. □ Located in Audit File □ Documents located: ________________
- 9. Page 9 of 9 Authorizations Completed by: _____________________________ Title___________________ Date ____________________________ (print name) _____________________________ Reviewed by: ____________________________ Title Trustee Date____________________________ (print name) _____________________________