Dear Records Managers:

I  had a question regarding records retention and 403(b) retirement plan 
audits.

Since 2009, the DOL has said that any entity with a 403b retirement plan with 
100 or more employees has to include an audited financial statement with 
their Form 5500 filing(s). Rather than keeping “everything, just in case” I am 
trying to get a better understanding of what kind of records need to be kept 
to aid in a successful audit. Especially, if these retention periods are longer for 
the audit than what the actual law requires you to keep. 

I found one resource online entitled “403(b)(9) Self-Audit Manual” which 
states:

Generally, you should keep most records for at least seven years; however, 
you may want to keep records related to participants’ accounts such as 
enrollment forms, salary reduction agreements and payroll records even longer. 
Here are some of the documents you should keep:

-Copies of plan documents (the basic plan document, adoption agreements 
executed by your organization and all other corresponding documents 
referenced under the plan), you may want to keep these records permanently; 

-Payroll master file or employee census records about all employees who 
performed any hours of service at any time during the plan year (The IRS will 
want these records to verify eligibility, participation and coverage);

-Copies of cancelled checks and other records about contributions made to 
your plan;

-Copies of salary reduction agreements (unless made via on-line website); and

-Information about maximum contribution limit calculations for your employees.

I would be very curious to hear what records other institutions have found 
useful to keep for their 403b audits and for how long.  I would also be curious 
to know how long institutions with 403(b) plans are keeping their payroll 
records and if they have encountered any problems with their 403b audit.  I 
would also welcome any other comments, suggestions and/or resources.  

Kind regards,

Anna

Anna Clarkson
Project Archivist 
The Baltimore Museum of Art
10 Art Museum Drive
Baltimore, MD 21218-3898
Tel:  443.573.1782
Fax:  443.573.1781
Email:  [log in to unmask]

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