401(k) Plan Committees

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The plan’s Named Fiduciary will delegate the administration of the company’s employee benefits plans to a Benefit and Investment Committee. The committee usually serves under the appointed Plan Administrator and Trustee, where, like the named fiduciaries, each committee member must acknowledge his/her fiduciary duties, responsibilities, and accountability to the plan, its participants, and beneficiaries.

Committee Members

Who should be on the committee? It is recommended that a Benefit or Investment Committee include:

Committee Decisions

Committee(s) members, while serving as fiduciaries, are expected to make both “informed and reasoned” decisions on behalf of those whom they serve. A prudent process by which a plan fiduciary can make reasoned and informed decisions would include the following:

Finally, before settling on a course of action, answer these four questions in the affirmative:

  1. Is the course of action appropriate, given the stated objective?
  2. Is the course of action reasonable, given the known facts and circumstances?
  3. Is the course of action permitted by the governing documents and regulations?
  4. Is the course of action solely in the best interests of the participants and beneficiaries?

Committee Administration

The benefit committee should function as expected when it was conceived. As such, it should establish its officers and By-Laws, which denote their responsibilities to the plan, their respective duties to the committee, the frequency of meetings, required attendees, routine agenda items, reporting and record keeping expectations, etc. Many of the duties of the committee will likely be outlined in the plan(s) governing documents.