Fiduciary Calendar 401k
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401(k) Fiduciary & Plan Administrative Support Calendar and Resource Center

For Plan Year Jan 2018-Dec 2018

An interactive look at the key retirement plan compliance dates.*

Select Your Plan's Calendar Year:
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* Compliance dates and fiduciary milestones may vary from plan to plan, but these sample quarterly calendars provide a great starting point from which to create a schedule specific to your plan.

Q1 Key Fiduciary Milestones

Plan Investment Assessment: Plan investments should be regularly evaluated to ensure that they remain prudent investments for plan participants.

Investment Policy Statement Assessment: If you have an Investment Policy Statement (IPS), an annual review in conjunction with a review of your plan's investment options over the past year may help you determine whether the IPS is either too broadly or too narrowly drafted.

Assess Plan Effectiveness: Evaluate relevant data about your retirement plan from the previous year. Look at participation rates, investment diversification, utilization of tools, and other measures of employee engagement. Consider plan design alternatives, education campaigns, and other ways of maximizing engagement.

Q2 Key Fiduciary Milestones

Assess Fiduciary Committee Structure and Other Governing Documents: An annual review of your fiduciary committee structure will help to optimize your fiduciary approach. Evaluate the frequency of committee meetings, the level of organizational representation,and other structural elements and governing documents.

Review Operational Procedures: Ensure that the plan has established operational procedures designed to achieve compliance with applicable laws and regulations. If any plan operational errors occurred over the last year, it is particularly important to make sure procedures have been put in place to prevent future errors.

Assemble Fiduciary Records: Fiduciaries are required to document fiduciary activity. In the second quarter, make sure all records of due diligence activity for the previous year are assembled and properly filed. Verify that the plan's administrative records for the previous year, such as nondiscrimination test results, are assembled and filed as well.

Q3 Key Fiduciary Milestones

ERISA 408(b)(2) Audit: Fiduciaries should identify all covered service providers to the plan and ensure that each of them has disclosed all information about fees and services as required under ERISA Section 408(b)(2). Fiduciaries have a duty to determine that the fees paid to service providers are reasonable in light of the nature and extent of the services provided in advance of hiring a service provider.

ERISA 404(c) Audit: Fiduciaries seeking the protection of ERISA 404(c) should periodically ensure that they are complying with its provisions. ERISA 404(c) has both structural requirements and disclosure Plan Asset Audit requirements.Compliance with both should be documented. Note: Many disclosures required to obtain 404(c) protection are mandatory under ERISA Section 404(a).

Plan Asset Audit: The Department of Labor routinely audits employer plan sponsors regarding the timing of remitting employee contributions and loan repayments to plans. Conduct an annual self-audit to identify any potential issues.

Fidelity Education: Prudently undertaking your fiduciary duties requires knowledge of the law and fiduciary best practices. Take steps to learn about the latest fiduciary developments.

Q4 Key Fiduciary Milestones

Disclosure Requirements under ERISA Section 404(a): Confirm that participant disclosure information is being provided, including annual notices. Although commonly referred to as an "annual" notice, it does not have to be provided 30 days prior to the beginning of the next plan year. Instead, a notice generally needs to be provided at least once every 12 months starting from the date of the first notice.

Fidelity Bond: Fiduciaries should ensure that the ERISA Fidelity bond for the plan is in place for the coming year in the proper amount.

Fiduciary Insurance: Any fiduciary liability policy should be examined to ensure that there is adequate coverage and that any changes in plan fiduciaries are reflected in the coverage of the policy.

Plan Document: Review the plan document to ensure that all required amendments are made by year-end. If a plan amendment is not required until a later year, any plan changes adopted administratively should be documented. All plan amendments and adopted administrative changes should be communicated to plan service providers.

Cost-of-Living Adjustments: In October, when the IRS makes any necessary adjustments to the various statutory limits governing defined contribution plans, fiduciaries should ensure that plan service provider(s), and any payroll provider(s), make necessary updates to their systems. Note that respective statutory limits apply to different time periods (e.g., plan year, limitation year, calendar year).

Fidelity does not provide legal advice. The information provided herein is general in nature and should not be considered legal advice.
Consult an attorney regarding your plan's specific legal situation.

For plan sponsor use only.

Fidelity Investments Institutional Operations Company, Inc.

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