by MHA

When it comes to plan-related document storage, remember that your primary goal should be to preserve materials in a format allowing for quick and easy retrieval. It’s appropriate to store plan records electronically whenever possible. Also, be sure to retain an executed copy (or countersigned copy, as applicable) of each record, not the unsigned original that may have been sent to you for signature.

We encourage you to follow your company’s internal procedures for disaster recovery for your plan documentation. Disaster recovery plans may include protocol for offsite backup storage, retrieval, and inputting and tracking each document’s retention requirements.

While most vendors can provide reports and current plan documents, the plan administrator ultimately remains responsible for retaining adequate records that support the plan document reports and filings. In addition, you are required to maintain records sufficient to determine the amount of benefits accrued by each participant.

Document Type Retention Requirements:

• Plan Documents (including Basic Plan Document, Adoption Agreement, Amendments, Summary Plan Descriptions and Summary of Material Modifications). Should be retained for at least six years following plan termination.
• Annual Filings (including 5500, Summary Annual Reports, plan audits, distribution records and supporting materials for contributions and testing). Should be retained at least six years.
• Participant Records (including enrollment, beneficiary and distribution forms; QDROs). Should be retained at least six years after the participant’s termination.
• Loan Records should be retained at least six years after the loan is paid off.
• Retirement/Investment Committee meeting materials and notes should be retained for at least six years following plan termination.