We all know the critical year-end duties all 401(k) plan sponsors must complete (and if you don't, you can read about them in "5 Tasks Every 401(k) Fiduciary Must Do Right Now," FiduciaryNews.com, Dec. 2, 2014). We'll set those aside and talk for a moment about a laundry list of good ideas for plan sponsors to put on their annual review list.
1. Review and update the plan's Investment Policy Statement (IPS). If you don't have one, you should. Just make it broad enough so it doesn't pigeonhole the plan into doing something it doesn't want to (or worse, something it can't do). If you've got a solid IPS, it should not require much in the way of change. Indeed, it might be years before you need to change it. The main things to look for are any regulatory changes or fundamental shifts in investment theory that might outdate some of the language in the IPS. Here's something to be especially wary of: ERISA attorneys often opine on the content of the IPS. ERISA attorney are not experts in investment theory, so their suggestions there may themselves be outdated. (Along these lines, don't assume just because it's "industry-accepted" that it's appropriate for your IPS.)
2. Review and update the plan's Investment Option Menus. As IPS's have been updated, so, too, have plans' investment option menus. This has been a popular plan improvement for several years now as more and more plans are abandoning the "style box" maze of dozens of fund options. Replacing this older model is the behavioral-based "tiered" or "category" approach. This segments funds into specific attitude-based groups, rather than investment-based groups. Much has been written about this for some time, so I won't belabor the point here. Once this shift has been made, don't expect many changes in fund offerings. On the other hand, changes shouldn't wait for year-end. The fiduciary adviser should be continually supervising the investment menu and take immediate action if necessary.
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