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Ask the Experts June 4, 2013
(b)lines Ask the Experts – Fiduciary Training for Committee Members
June 4, 2013 (PLANSPONSOR (b)lines) – “I chair a Committee for our ERISA 403(b) plan in which we make decisions regarding plan administration as well as the investment options.
Reported by PS
“I realize that we are plan fiduciaries, but I recently heard that we should be conducting formal “fiduciary training” for the Committee members. Is this true?”
Michael A. Webb, Vice President, Retirement Plan Services, Cammack LaRhette Consulting, answers:
Though the Department of Labor (DOL) has not offered any official guidance on the matter, the Experts believe a best practice would be to conduct fiduciary training. The DOL has unofficially made positive comments regarding the merits of fiduciary training programs, and apparently, during some recent plan audits, the DOL has requested evidence that fiduciary training has been conducted in the past year.
The training should encompass ALL fiduciaries even those who do not serve on your Committee. And, of course, your meeting minutes should document that such training was conducted. Training should be conducted on an annual basis so that any new fiduciaries receive training, and as a refresher for existing fiduciaries.
As for content, your own personal plan experts (e.g. your benefits counsel well versed in such matters and/or your plan consultant) will likely serve as an excellent resource. For detail about the types of issues about which fiduciaries should be trained, one of the items from last week’s Ask the Experts’ summer reading list, Meeting Your Fiduciary Responsibilities (see “Ask the Experts: 2013 403(b) Reading List”), is an excellent reference!
Thank you for your question!
NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.