PLANSPONSOR - December/January 2021 - 36

ADMINISTRATION & GOVERNANCE | DOCUMENTS
Electronic
Upgrade
Guidelines to protect
plan documents that
go digital
E
mployers are required to follow
rules relating to electronic documentation
under two sections of the
Employee Retirement Income Security
Act (ERISA). First, under Section 107,
plan sponsors must keep records, including
plan and trust documents, annuity
contracts, 5500 forms and more for at
least six years from the report filing date.
Sponsors should hold onto these
documents longer, though, and establish
a written record retention statement,
suggests Carol Buckmann, an
ERISA attorney and founding partner of
Cohen & Buckmann, P.C., in New York
City. " This is important if you're using
electronic records and destroying paper
records, " she says.
Because every document has a
different filing deadline, says Alison
J. Cohen, a partner with the Ferenczy
Benefits Law Center in Atlanta, it is
imperative to have a written procedure for
document retention and include it in the
plan document-doing so ensures best
practices. " Having that type of written
procedure is key so that everybody knows
how long you have to keep the documents,
as they don't all have the same [time
requirement], " she says.
The second electronic documentation
rule requirement is under ERISA Section
209. According to a report by Certified
Public Accountants (CPAs) McKonly &
Asbury, 209 requires employers to save
certain paper records indefinitely and
leaves it up to the states whether to permit
electronic storage. These records include
employee demographic information,
participant compensation information,
contribution election/change form(s),
loan documents, a participant's designated
beneficiary, records of any distribution
requested by the participant and qualified
domestic relations orders (QDROs)
that assign part or all of a participant's
account to an alternate payee.
Section 209 also provides rules for
electronic filing. These include ensuring
that: records are safe, secure, manageable
and properly ordered; controls are in place
36 PLANSPONSOR.COM December 2020 - January 2021 Art by Melinda Beck
to ensure accurate, reliable and authentic
information; electronic versions can be
easily converted to paper copies; documents
are legible and viewable in a screen
format; and no ERISA reporting or disclosure
requirements are violated in the
operation of the system, the report states.
If a document has a diagram or
attachment that cannot be converted
to a digital format, it is best to keep the
paper version as a precautionary measure,
Buckmann notes. Documents such as
QDRO notices may be filed electronically.

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PLANSPONSOR - December/January 2021

Table of Contents for the Digital Edition of PLANSPONSOR - December/January 2021

The Truth About Plan Lawsuits
2020 PLANSPONSOR Best in Class DC Providers
Administrative Assistance
Striking the Right Balance
Electronic Upgrade
PLANSPONSOR - December/January 2021 - Cover1
PLANSPONSOR - December/January 2021 - Cover2
PLANSPONSOR - December/January 2021 - 1
PLANSPONSOR - December/January 2021 - 2
PLANSPONSOR - December/January 2021 - 3
PLANSPONSOR - December/January 2021 - 4
PLANSPONSOR - December/January 2021 - 5
PLANSPONSOR - December/January 2021 - 6
PLANSPONSOR - December/January 2021 - 7
PLANSPONSOR - December/January 2021 - 8
PLANSPONSOR - December/January 2021 - 9
PLANSPONSOR - December/January 2021 - 10
PLANSPONSOR - December/January 2021 - 11
PLANSPONSOR - December/January 2021 - The Truth About Plan Lawsuits
PLANSPONSOR - December/January 2021 - 13
PLANSPONSOR - December/January 2021 - 14
PLANSPONSOR - December/January 2021 - 15
PLANSPONSOR - December/January 2021 - 2020 PLANSPONSOR Best in Class DC Providers
PLANSPONSOR - December/January 2021 - 17
PLANSPONSOR - December/January 2021 - 18
PLANSPONSOR - December/January 2021 - 19
PLANSPONSOR - December/January 2021 - 20
PLANSPONSOR - December/January 2021 - 21
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PLANSPONSOR - December/January 2021 - 28
PLANSPONSOR - December/January 2021 - 29
PLANSPONSOR - December/January 2021 - Administrative Assistance
PLANSPONSOR - December/January 2021 - 31
PLANSPONSOR - December/January 2021 - 32
PLANSPONSOR - December/January 2021 - Striking the Right Balance
PLANSPONSOR - December/January 2021 - 34
PLANSPONSOR - December/January 2021 - 35
PLANSPONSOR - December/January 2021 - Electronic Upgrade
PLANSPONSOR - December/January 2021 - 37
PLANSPONSOR - December/January 2021 - 38
PLANSPONSOR - December/January 2021 - 39
PLANSPONSOR - December/January 2021 - 40
PLANSPONSOR - December/January 2021 - Cover3
PLANSPONSOR - December/January 2021 - Cover4
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