What Goes into your Fiduciary File? Participant Related Documents

We’re heading into the last category of our blog series focused on what materials a plan sponsor should include in their fiduciary file. 

In review, we have covered: 

Below are the participant related documents you should keep in your file.

  • Participant records may include census data, account balances, and contributions and earnings
  • Hardship and loan documentation.
  • Statements and notices including the Summary Annual Report and 404(a)(5) fee disclosures.
  • Participant Education & Advice materials the vendor uses with participants.
  • Any written communications that promise a benefit, right or feature, such as the employer's commitment to an employer contribution to the plan.  

With the help of an experienced and knowledgeable plan advisor, keeping a plan in compliance and conducting best practices is achievableIf the DOL comes calling and you don’t have a Retirement Plan Committee or the committee does not meet regularly, answering their questions and requests can be unnecessarily difficult, time consuming, and uncomfortable. Keeping a current fiduciary file is not only prudentit makes sense. 

For a short guide on all five categories, download our "Fiduciary File: What Is It and What Do You Keep In It?" resource.


Multnomah Group is a registered investment adviser, registered with the Securities and Exchange Commission. Any information contained herein or on Multnomah Group’s website is provided for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and, unless otherwise stated, are not guaranteed. Multnomah Group does not provide legal or tax advice.

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