In Search of Missing Plan Participants (article)
One of the age-old problems for plan sponsors has been how to handle accounts of missing participants. The DOL’s Employee Benefit Security Administration (EBSA) has recently issued Field Assistance Bulletin (FAB) 2014-01 providing some additional guidance, specifically as it relates to terminated defined contribution plans; but which may be applicable in other circumstances as well.
Historically, one of the ways to locate missing participants was through a letter forwarding program offered by the Internal Revenue Service, as well as one offered by the Social Security Administration. Both of these letter forwarding programs have been terminated, due in large part to the availability of low cost methodologies, at least in part, made possible through the use of electronic media.
This FAB lists the following methodologies that can be used to reach missing participants:
- Use certified mail as a means to determine whether the participant can be located.
- Consult related employer-sponsored plan documentation or employer records for any updated contact information. Another way to locate missing participants is to verify the individual’s contact information with the employer’s human resources department and in certain instances, with other plan records. Caution should be exercised, though, to make certain that HIPAA privacy standards are not violated.
- Contact the designated beneficiary, such as the spouse or child, for updated contact information.
- Utilize free electronic internet search tools such as search engines, public record databases, obituaries and social media.
It is important that a plan fiduciary exercise its responsibility as a plan sponsor to ensure that efforts are made to reach missing participants and to preserve the account balance available to the participants, which means spending only as much money as the account may be worth.
The information contained in this article is provided as general guidance and may be affected by changes in law or regulation. This article is not intended to replace or substitute for accounting or other professional advice. Please consult a CBIZ professional. This information is provided as-is with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein.