To steal a joke from Chris Rock, when I worked at a TPA as the lead ERISA attorney, I used to joke that if you wanted to hide something from one of our plan administrators, just put it in the plan document file. Nobody ever cracked one open. Why? Because someone had already plugged the plan specs into Relius, and that’s all anyone looked at.
The problem, of course, was that the woman running the show back then was a complete buffoon. Things were constantly wrong — specs didn’t line up, operational errors piled up, and everyone assumed Relius was the gospel truth. Meanwhile, the plan document — the actual governing instrument under ERISA — sat ignored, like an unread instruction manual stuffed in a drawer.
Here’s the point: plan specs are only as good as the plan document they’re based on. If they don’t match, you’re courting disaster. I’ve seen plan sponsors dragged into compliance nightmares, IRS corrections, and even litigation simply because the specs in the recordkeeping system didn’t mirror what was written in black and white.
So, whether you’re a TPA, advisor, or plan sponsor, don’t treat the plan document like some dusty artifact. Specs, procedures, Relius entries, prototypes — all of it needs to reflect what’s actually in the governing document. Otherwise, you’re just building mistakes into the system and waiting for the IRS or DOL to find them.
Trust me, when they do, you won’t be laughing at the Chris Rock joke anymore.
