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The Eternal 401(k) Plan Sponsor” Question: Should I Have a PAC or a PIC or None at All? (Really!) 

5/17/2015

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Every plan sponsor should ask this question.  
The good thing is that there is no one right answer. Your response depends on who you are and what you have --- your facts and your circumstances. 

First, what are PACs and PICs? A PAC is my shorthand for a plan administration committee. Similarly, a PIC refers to a plan investment committee. 

Why have a PAC or a PIC?
Why establish a PAC or a PIC? There are at least two good reasons. Committees are an excellent way to establish accountability and control over important plan processes. They can also be effective way of spreading around plan work to folks with the skills  and ability to handle that work. 

But PACs and PICs are not for everyone.
Small employers such as sole proprietors may not have the person power or tolerance for the formalities of a committee structure. They’re likely to want something a bit simpler, such as calendars and checklists.
Larger employers may find the PAC and PIC structure quite valuable for the aforementioned reasons. Some will opt for both a PAC and PIC. Others may reason that a PAC is all they need or can stand and wrap investment oversight/management responsibilities into the one committee.

What structure you decide on should be the one that best helps you protect your interests and the interests of your employees.

If you are a plan sponsor, have a conversation with your adviser and discuss with them what is best for you.  If you are an adviser, make the question an item of discussion with your clients. 
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    Author

    Chuck Humphrey, an experienced employee benefits attorney and a a leading exponent of the fiduciary ethos, shares his thoughts on current developments in this important area and provides advice on how to survive life as a plan sponsor, fiduciary,  or plan plan advisor. He can be reached at chumphrey@cghbenefitslaw.com or at 978-688-2162.

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