Plan sponsors are less likely to maintain meeting minutes, use an independent party to analyze fees, or establish a clear chain of authority for their plan’s governance committee, according to a new survey from Grant Thornton, Drinker Biddle & Reath and Plan Sponsor Advisors.

It’s a recipe for trouble, according to Grant Thornton’s Debbie Smith, a partner in the firm’s employee benefits practice. “In an investigation, the DOL will not expect a sponsor to have the benefit of ‘20/20 hindsight,’ but will look for a well-documented and carefully undertaken decision-making process,” according to Smith.

Minute-taking dropped 21 points to 58%. Independent fee review dropped 18 points to 27%. And the number of sponsors reporting they have established a clear chain of authority for their plan’s governance committee dropped 12 points, falling to 29%.

“Our respondents this year would have difficulty supporting the prudence of their fiduciary decisions in the face of a DOL audit,” Smith says.

The survey of 275 plan sponsors was conducted online between October and November last year. A copy of the survey report is available online.

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