Upon first blush, to the extent an employee from the general populace can and wishes to make a contribution as a committee member, there seems to be no reason why they shouldn’t participate on the committee.
In practice, most committees consist of executives from finance (preferably the CFO), benefits and human resources. Due to the potential exposure, if there is interest from other lay people who wish to represent the vote of the participant base, they are best served participating as a non-voting member with no discretionary capabilities. This type of person should be identified and documented as a non-voting member assuming there is no intent to take fiduciary status and the potential liability attached to all retirement committee members.
ACR#161752 11/15
