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Plan Document, SPD and Qualified Medical Child Support Order Procedures Record Retention

What documentation should be retained by the Plan Sponsor?

A copy of each Plan Document, Summary Plan Description, Plan Booklet, and Qualified Medical Child Support Order Procedures should be retained by the Plan Sponsor and Related Employer in their permanent files. It should be readily available if ever an IRS or DOL examiner asks to inspect it. (Keep the current and any prior versions in the permanent files.) Also, keep notes regarding distribution of SPDs and , if you distribute a QMCSO Procedure, keep notes on that also, including dates and methods.

What copies must be kept for review for participants?

Copies of the Summary Plan Description, the Plan Document, the Trust, the latest Form 5500, and "other instruments under which the Plan is established or operated" must be made available for review upon request by participants and beneficiaries.

Where do the copies need to be kept for participant/beneficiary access?

The general rule requires that copies must be available for examination by participants or beneficiaries at the prinicpal office of the plan administrator and in such other places as may be necessary to make available all pertinent information to all participants and beneficiaries. Documents have to be "current, readily accessible, and clearly identified, and copies must be available in sufficient number to accommodate the expected volume of inquiries."

Plans typically are required to make documents available:

At the principal office of the plan administrator; and

At the principal office of the employer (if different form the principal office of the plan administrator) and at each employer "establishment" in which at least 50 participants covered under the Plan are customarily working. "Establishment" means a single physical location where business is conducted or where services or industrial operations are performed. Where employees are engaged in activities which are physically dispersed, the "establishment" is the place to which the employees report each day. If they do not report to a location, it is the location from which they customarily carry out their activities. Unlike the plan administrator principal office location requirement, a Bank does not have to keep the documents at these other employer establishments at all times, but must make them available within ten calendar days following the day on which a request for disclosure at that location is made. Thus, a Bank may need to provide documents at other locations if there are at least 50 participants customarily working there.

See Department of Labor Reg. Sec. 2520.104b-1.