Other than as part of a DOL settlement, plan fiduciaries are not required to get formal training on how to run their DC plan. According to Fiduciary Plan Governance’s Charles Humphrey, however, fiduciary training is becoming a best practice, and there is growing evidence that more DOL field people are asking about it.
Humphrey lists the items that should be covered in a fiduciary training program:
• Who is a plan fiduciary, and why?
• What is a plan fiduciary expected to do, and what is their personal liability?
• Why it may not be a great idea to have a member of senior management serve as plan fiduciary.
• How to select and monitor plan service providers, consultants, record keepers and investment consultants.
• How to communicate with employees.
• When and how do you conduct a plan review?
• Where can you find advice on your fiduciary questions?
• What is ERISA 404(c) compliance and how is it achieved?
Sources for information about training include the plan’s attorney, accountant and consultant/advisor — and even service providers, via newsletters and webinars. However, Humphrey believes, “… training must be structured, regularly provided, and focused on the specific features of the plan.”
It makes sense that professionals with personal liability — as well as the serious social responsibility to provide a retirement plan that gives their employees the best chance to retire successfully — should get formal training. And short of requiring it, the DOL seems to be indicating that formal training will be evidence of a prudent process, just like keeping meticulous and well-ordered plan records.
