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401(k) Plan Setup Checklist

Whether you are starting a first 401(k) or moving an existing plan to a new provider, the work follows a predictable 60- to 90-day path. This is the same checklist we use with plan sponsors — free to read, copy, and share. No email required.

Documents to gather first

Collect these before the kick-off call. Nearly every delay we see traces back to a missing plan document or an incomplete payroll census.

  • Master Plan Document (current restatement)
  • Adoption Agreement, including all amendments
  • Summary Plan Description (SPD)
  • Most recent Form 5500 filing and related schedules
  • Most recent recordkeeper and TPA fee disclosures (ERISA 408(b)(2))
  • Current investment lineup and any investment policy statement (IPS)
  • Employee census file from payroll
  • Existing fiduciary service agreements (3(21) and 3(38))

The 9-step setup process

  1. 01Kick-off Call

    Week 1 · Shared

    GateKeeper, the current plan sponsor, and Royal Fund Management meet to align on scope, timeline, responsibilities, and the documents we’ll need along the way.

    • Gather the Master Plan Document, Adoption Agreement, and Summary Plan Description (SPD)
    • Identify the plan’s named fiduciary and day-to-day administrative contact
    • Confirm the target go-live date and any blackout constraints
  2. 02Weekly Cadence Established

    Week 1–2 · Shared

    Recurring status calls are scheduled so no one is in the dark. Clear expectations, a shared checklist, and transparency by default.

    • Set a standing weekly call with HR, finance, and payroll representatives
    • Agree on a single shared task list and document repository
  3. 03New Plan Documents Prepared

    Week 2–3 · GateKeeper

    We draft the updated plan documents — adoption agreement, restated Master Plan Document, and SPD — and circulate them for review and sign-off.

    • Review draft eligibility, vesting, match, and auto-enrollment provisions
    • Route documents to counsel if the sponsor requires legal review
    • Obtain authorized signatures on the adoption agreement
  4. 04Employee Census Collected

    Week 3–4 · Sponsor

    Typically a single payroll file. We confirm eligibility, compensation, deferral elections, and employment dates so nothing slips through the cracks.

    • Export a census with hire/termination dates, hours, compensation, and deferral elections
    • Flag any part-time employees approaching long-term part-time eligibility
    • Reconcile the census against the current recordkeeper’s participant list
  5. 05Recordkeeper Training

    Week 4–5 · Shared

    One of our favorite parts — we schedule Empower recordkeeping software training so your team is confident well before go-live.

    • Name the administrative users who need portal access
    • Complete contribution submission and reporting walkthroughs
  6. 06Payroll Integration & Training

    Week 5–6 · Shared

    Depending on your payroll provider, we set up 180° or 360° integration and train your payroll contact to make ongoing contributions as easy as possible.

    • Confirm the payroll provider and whether 180° or 360° integration is available
    • Test a sample contribution file before the first live payroll
    • Document the deposit timing standard for elective deferrals
  7. 07Data Load & QA

    Week 6–8 · GateKeeper

    Behind the scenes we load employee data, double-check every field, and reconcile balances so the transfer and enrollment are seamless.

    • Validate balances, sources, and vesting service against prior-provider records
    • Resolve any data exceptions before the blackout window opens
  8. 08Prior Provider Handoff

    Week 8–10 · Shared

    We contact the incumbent recordkeeper, set blackout dates for the asset transfer, and distribute the required participant notices.

    • Issue the ERISA 404(c) and blackout notices within required timeframes
    • Send written termination notice to the incumbent recordkeeper
    • Retain copies of all participant notices in the plan’s fiduciary file
  9. 09Enrollment Meeting

    Week 10–12 · Shared

    Time to launch. We schedule an on-site or virtual enrollment session where your advisor meets employees, answers questions, and helps them enroll.

    • Schedule on-site or virtual enrollment sessions across all shifts and locations
    • Distribute enrollment materials and the updated SPD
    • Confirm the first payroll contribution posts correctly after go-live

Fiduciary roles to settle early

Setup is also the moment to document who is responsible for what. GateKeeper Investment Advisers serves as your ERISA 3(21) Adviser, and investment fiduciary responsibility is held by an independent third-party ERISA 3(38) Investment Manager — not by GateKeeper. Keep signed service agreements for both roles in the plan’s fiduciary file.

This checklist is general information for plan sponsors and is not legal, tax, or investment advice. See our sources and references for the underlying rules.

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