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Keeping a record

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The following documentation should be maintained regarding ERISA decisions:

o Journals, ledgers, bank statements, and appraisals that support plan assets and investments.

o Analysis and reports from investment managers and consultants, and performance data.

o Certificates, documents, statements of additional information (if a mutual fund), confirmations, and any and all necessary items depicting evidence of ownership in the plan assets and investments.

o Annual copies of a Form ADV for each money manager, along with certification by the manager that appropriate registrations under the Investment Advisers Act of 1940 and the State Securities Board are maintained. In addition, the manager should certify that there is no material litigation pending against the manager that involves allegations of a breach of fiduciary duty or securities law violations.

o Proof of satisfaction of the ERISA bonding requirements for all fiduciaries dealing with plan assets.

o A detailed report of investment transaction turnover, costs, fees, and expenses.


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