Auditing Recordkeeper Statements—A Fiduciary Duty?

Adhering to prudent standards includes auditing quarterly statements from the recordkeeper. However, there is no explicit requirement for plan fiduciaries to do so.

With regard to plan assets, fiduciaries have the explicit duty to ensure that:

• employee deferrals are contributed in a timely manner;
• the plan does not engage in prohibited transactions; and
• plan assets are used exclusively to pay plan benefits and defray reasonable plan expenses.

Fiduciaries must act prudently in carrying out these duties. A bright-line test for the exact definition of prudent does not exist. It depends upon the facts and circumstances.

The plan trustee has the duty to keep plan assets safe. If you are the plan trustee, you should oversee how your recordkeeper handles plan assets. Auditing their quarterly statements helps to accomplishing this.