One of my co-workers attended Corbel's advanced penson conference in Chicago last month and asked one of the presenters "Who is responsible for maintaining a plan document after a client leaves?" (i.e., we no longer do the record- keeping). She may have misinterprepted the answer, but here it is anyway. If a client leaves and has tpa X do the recordkeeping, we are responsible for maintaining the plan doc (assuming they don't adopt another sponsor's doc)!! He went on to add that this responbibility goes on for several years (3 or 5, I forget which).
Now here's how I think this works, someone please give me a sanity check.
- Once a client leaves, he's on his own re: the document. BTW, I have been telling departing clients this in writing.
- If a plan terminates, we would make sure the doc has been amended for recent law changes, i.g., GUST, and that's it.
Thanks fellow soldiers in the great ERISA war.
Maverick