Pammie57 Posted September 19, 2016 Posted September 19, 2016 Can someone tell me whether this IPS is required or just suggested? If required, who prepares it normally, and is there a generic version with some fill-in the blanks or is each plan's IPS custom? Does anyone have a sample? Thanks
rcline46 Posted September 19, 2016 Posted September 19, 2016 Suggested, but the DOL thinks it is required. All doc providers have a simplified one with their documents, usually prepared by the financial advisor.
Mr Bagwell Posted September 19, 2016 Posted September 19, 2016 I'm pretty sure the IPS is a suggestion. From my experience, it is used to show that the employer has a policy\procedure in place to replace clunker funds. Some providers that provide a 3(21) fiduciary service will typically have a boiler plate IPS. Some brokers will use a boiler plate IPS from like a fi360 like application. I have not seen a generic fillable version outside a "pay for play" version or service provider version. Although, some investment committee may come up with their own.
david rigby Posted September 19, 2016 Posted September 19, 2016 Older discussion from 2007: http://benefitslink.com/boards/index.php/topic/35378-does-a-db-plan-need-an-investment-policy-statement/ I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Belgarath Posted September 19, 2016 Posted September 19, 2016 Question for the ERISA attorneys - is it worse (from plan sponsor liability perspective) to have an investment policy statement and NOT FOLLOW IT (which is by no means uncommon) or to simply not have one, and rely on a sort of "Well, we tried to do a good job for the participants..." Or are they equally bad? Just curious.
GMK Posted September 19, 2016 Posted September 19, 2016 Here's Vanguard's sample IPS:https://institutional.vanguard.com/iam/pdf/IAMIPS.pdf It may not match your needs, but it gives an example of things to include in your IPS. You can see other samples by googling: investment policy statement template Pammie57 1
MoJo Posted September 19, 2016 Posted September 19, 2016 Belgarath: Would you rather be shot and die quickly, or die slowly from poisoning? Having an IPS and not following it (without a really good reason) is "fatal" quickly - as you have provided the standard of conduct against which you will be judged. Not having an IPS and "winging it" means you leave it to the judge (never, ever a good idea) to determine the standard by which you will be judged and held to before he or she strings you up based on what they think would be prudent.... Speaking of which, I'm not aware of anything that "specifically" says an IPS is required EXCEPT that one must be a "prudent expert" (with the care, skill, etc.) as a fiduciary, and I can't think of a "prudent" investment manager who would do without one.... RatherBeGolfing 1
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