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