By Debbie Herbert, CPA, Director at Blue & Co.
Have your plan auditors ever asked you for plan governance committee meeting minutes or agendas? There’s a good reason for that. Auditors are required to consider entity-level controls, including monitoring and oversight, as part of their audit procedures. Plan governance committee meetings may help support existence of these controls. The frequency and structure of committee meetings may vary, and a plan’s specific features and provisions will affect agenda items of relevance. However, some agenda items of interest to the auditor may include the following:
- Review of investment policy and investment performance; changes to investment lineup
- Forfeitures, including available balance and requirements for use in accordance with plan provisions
- Current interest rates on participant loans, and the frequency of updates in accordance with plan provisions
- Balance of uncashed distribution checks and how these are reported by the recordkeeper
- Discussion and approval of discretionary employer contributions
- Review of the plan’s annual participant activity records
- Review of plan expenses and provider fees, under ERISA Section 408(b)(2)
- Review of the auditor’s annual governance letter (AU-C 260 letter), including consideration of any next steps for corrective action for identified control deficiencies or reportable findings
Additional agenda items may include:
- Upcoming plan amendments, including those applicable under Secure Act 2.0
- Plan merger or transfer activity
- Contribution and compensation limit changes, and necessary updates in the payroll application
- Regulatory updates and deadlines, including Form 5500 filing and any audit requirements
- Required communications, including participant fee disclosures, summary annual report, SPD and SMM
- Benchmark considerations of plan health
- Discussion of current service providers, including any concerns and whether expectations are being met
- Review of annual compliance testing results
Of equal importance to the meeting itself, is documentation thereof; this may include a list of individuals present, agenda points, items discussed, and decisions reached. Appropriate documentation will help satisfy auditor’s requests, and more importantly, will allow plan fiduciaries to maintain evidence of their fiduciary duties and responsibilities. The best way to document such meetings is through formal minutes taken during the meeting and approved by those present.
As benefit plan auditors, we also appreciate the opportunity to give a presentation at our clients’ annual committee meetings, summarizing our procedures, results, and insights. For more information, please reach out to us today!
Debbie Herbert
Director
Phone/fax: 812-405-1733
Email: dherbert@blueandco.com
