You don't have to have an Investment Policy Statement for your 401(k) plan. It's a blade that can cut both ways. Written well, an IPS offers a template to easily protect both the plan sponsor and the plan participant. Written poorly, it exposes the plan sponsor to unnecessary liabilities.
Whether the IPS is crafted well or poorly will depend on who's doing the crafting – and who's not, (see "Who Is Generally Responsible For Designing, Detailing, And Approving The 401k IPS?" FiduciaryNews.com, January 30, 2020).
Let's focus on trying to avoid those unnecessary liabilities. This is perhaps the greatest unforced error when it comes to a 401(k) IPS. It's too easy to treat the exercise of creating an IPS as a statement of elegance, not pragmatism. This is how plan sponsors expose themselves.
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