Who needs to be bonded?
Anyone that “handles” retirement funds. Even if the individual is not a fiduciary, if they handle funds they need to be bonded. If an individual receives or disburses plan assets they are deemed to be handling funds. 2580.412-6 states that funds are handled by a person if that person’s duties or activities are such that there is a risk that such funds could be lost in the event of fraud or dishonesty. The person handling funds does not necessarily have to be a fiduciary. “Handling” is not an investment control concept, but rather one related to the receipt, safekeeping, or disbursement of funds.
