Retention of Plan documents

[mbozek]

How long does an employer need to keep obsolete plan documents after restatement. For example client adopted a prototype HR-10 plan in 1994. Plan was restated for two sucessive mergers of the sponsor. The assets were then transferred to a prototype plan of different financial organization. The new plan as well as the old plans all had IRS determination letters issued to the ptype sponsor including gust amendments. The client wants to know if the 4 inch stack of prior prototype documents, SPDs, forms and adoption agreements need to be kept indefinitey or can just the prior determination letters and adoption agreements be retained with the current document.

[david rigby]

Not sure about your plan, but in the DB world, I have occassion to look for documents back to the 60s, generally to verify benefit or eligbility of VT's, but sometimes also to verify unusual death or disability provisions. Then there is the case where a former EE gets the letter from the SSA ("you may have a benefit from ..."). If that person is not in your database, it may require old documents to verify anything.