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401k Investment Committee Checklist

Generally, the Investment Committee or the fiduciary with investment authority should review the following items. The frequencies below are noted as a suggestion. Frequency will depend on the plan's particular circumstances which may require a different frequency than noted here. If the review is being done by a designated fiduciary, a report should be prepared by them covering their work and findings and submitted on a regular basis to the Investment Committee.


Review accounting and allocation reports:

  • Review market values for reasonableness.
  • Review assets to ensure that they are consistent with your Investment Policy Statement.
  • Review disbursements to ensure that they are correct and correspond with those authorized by plan fiduciaries.
  • Review fees and other costs charged to the plan for reasonableness.
  • Review transactions for any unusual activity.


  • If the plan is using an independent consultant to monitor investment options, have the consultant present findings and monitoring reports. Document any action to be taken as a result of recommendations made by the consultant.
  • Review plan assets with investment policy guidelines, including company stock if applicable.
  • For each investment option:
    • Compute the rate of return on each option for at least a one, three and five year period.
    • Compare each investment option against an appropriate benchmark and against a universe of like funds using the same investment style.
    • Monitor each investment fund for "style drift." Style drift is the tendency of a fund or investment manager with a particular investment style to alter that style over time.
    • Determine if there has been any significant portfolio developments, major changes in ownership, organizational structure or personnel for each investment option and money management firm being used.
  • Ensure that all contributions are being deposited to the plan properly and invested correctly.
  • Compare mutual fund statements or investment manager reports with those provided by the custodian. Resolve any discrepancies.
  • Review each investment manager's and vendor's fee computation for accuracy and compliance with agreements.
  • Review any investment options placed on the "watch list" to determine if any additional action is required.


  • Ensure, if appropriate, that a current ADV has been received, reviewed and filed for each investment manager (not required for mutual funds).
  • Ensure that the Committee has obtained, reviewed and filed the most current mutual fund prospectus, Statement of Annual Information, Annual Report, and other fund reports or correspondences.
  • Determine if there has been any industry or regulatory disciplinary actions taken against any of the investment options or money management firms being used.
  • Review the proxy voting record of each investment option.
  • Review total costs of each investment option against like mutual funds or investment managers using the same investment style.
  • Review the manager's trading and brokerage activities to ensure they are achieving "best execution" on any individually managed options.
  • Review the manager's trading and brokerage practices on any individually managed options including:
    • Commission costs.
    • Soft dollar use.
    • Portfolio turnover.
    • Style consistency.

Documentation and Records Retention

Maintain good records, minutes, and other documentation. Good documentation, including detailed meeting minutes, can demonstrate adherence to the criteria established in the IPS for selecting, monitoring and replacing investment funds or managers. Be sure that it is well organized and filed for easy access.

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