Definition
A plan committee is the governance body, typically named in the plan document, through which a plan sponsor delegates administration of an ERISA-covered retirement plan, with committee members serving as ERISA fiduciaries when they exercise discretion over plan operations or assets.
Why it matters
Committee members act as ERISA fiduciaries by function, regardless of their day-job titles. The committee is where fiduciary decisions actually happen — investment menu selection, service provider retention, monitoring against the investment policy statement, and interpretation of the plan document — and where fiduciary responsibility can accordingly be documented, delegated, or breached.
How it works
A typical structure names a plan committee — sometimes titled the retirement plan committee, benefits committee, or administrative committee — in the plan document, with membership drawn from senior finance, human resources, treasury, and legal functions of the sponsor. The committee meets on a defined cadence (most commonly quarterly), reviews investment performance against the investment policy statement, reviews recordkeeper and adviser performance, receives 408(b)(2) service provider disclosures, decides on plan design changes within its delegated authority, and documents its deliberations in minutes. In many plans a separate investment committee handles investment-specific decisions while the plan committee retains administrative and design authority; in smaller plans the two functions are consolidated. Committee members are personally liable for fiduciary breaches — a structural feature typically addressed through fiduciary liability insurance and, in some cases, indemnification provisions in the plan document.
In practice
A participant does not typically interact directly with the plan committee, but the committee's decisions determine the investment menu, the recordkeeper, the fee structure, and the lifetime income options available in the plan. When a participant has a specific question about plan operations, fees, or investment options, the escalation path runs through the plan administrator's office and, if unresolved, to the committee. Sponsors evaluating whether their committee is functioning well should look at meeting cadence, quality of documentation, independence of the benchmarking process, and clarity of the delegation structure between the plan committee, the investment committee, and outside advisers.
Related terms
- ERISA fiduciary
- Named fiduciary
- Plan administrator
- Investment committee
- Investment policy statement
- Co-fiduciary liability
- Fiduciary liability insurance
- Plan document