Apologies to the very funny comedian Gary Gulman for tweaking his bit and taking it for my own but as I read an article earlier this morning his tagline was all that was running through my head.
Changes within a company obviously can happen every year but this year has seen more change for many companies than what is generally expected. This year some businesses have been able to make it through unscathed, some have seen downsizing and consolidating of positions and some unfortunately have had it even worse than that.
For those that fall into the "downsizing and consolidating" category there will be employees who are now having to assume new roles and responsibilities. As it relates to the 401(k) plan that may mean that there are new members being introduced to the 401(k) Plan Committee which should have its own best practices process attached to it. A quote from a November Plansponsor Magazine article reads "Training new members of a retirement plan committee is challenging in any environment but is more so during a pandemic, when many people are working remotely". ('Onboard" Education) It is easy in a normal year to find more important work related items for employees to spend their time on than going through a fiduciary training education sessions but in a year where many people's commute still consists of walking down a hallway from the bedroom to a computer desk in another room (or a laptop propped up on an ironing board for a Zoom meeting), fiduciary training can easily tumble down the importance scale from "Something we'd like to get to" to "Fiduciary Training? In this pandemic?" status.
However tempting it might be to just punt on the idea of training for new committee members for something to put on next year's agenda (or the year after that or after that, etc.) the Department of Labor would probably recommend that you think otherwise. Although there is no fiduciary training requirement it is one of the things that the DOL consistently asks about during their audit investigations, meaning even though they may not have it in the "must do" category it would almost certainly fall into their "we HIGHLY suggest you do this" category.
To help you satisfy that requirement you should hopefully be working with an advisor that can accomplish this task in the best of times but the need doesn't go away in the less than optimal times. There are programs out there that can allow for fiduciary training either in person or virtual, my practice elects to go with the Fi360 "Fiduciary Essentials" training program (Fiduciary Essentials for Defined Contribution Plans), others may choose a different method/version but I strongly suggest to all clients and non-clients alike that every company and committee have SOME sort of systematic and repeatable training program to lean on. Not doing so puts all new committee members immediately behind the eight ball and likely struggling to understand and fully grasp the responsibilities (and liabilities) that comes with their new role.
NO NEW MUSIC SUGGESTIONS: For the 2 or 3 people who may have read more than one or two of these blog posts they would already know this but for those first timers, music is one of my favorite personal escapist activities and seeking out new music in particular. Earlier in the year I was still into the seeking out of new music but as this particularly interesting year has continued to unfold I have found myself retreating to "old" music that I already know that I love. So all I might say here is that if you are possibly looking for something different I might suggest a handful of names: American Aquarium, Tyler Childers, Lucero, Turnpike Troubadours, Brittany Howard, California Honeydrops, Chuck Ragan, Frank Turner, JD McPherson, John Moreland just off the top of my head. {Full disclosure: I am one of the odd breed who is guilty of being in the Sad Songs Make Me Happy crowd (Its a thing, I promise!) so consider yourself forewarned if you decide to look into any of suggestions above}
The foregoing information has been obtained from sources considered to be reliable, but we do not guarantee that it is accurate or complete, it is not a statement of all available data necessary for making an investment decision, and it does not constitute a recommendation. Any opinions are those of Matt Callan and not necessarily those of Raymond James. Expressions of opinion are as of this date and are subject to change without notice. There is no guarantee that these statements, opinions or forecasts provided herein will prove to be correct.
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