Find Those Participants!
Does your plan have any participants who are missing? I can nearly guarantee that it does, as I have never come across a plan where at least one participant’s mail has been returned as undeliverable. In large plans, there are sometimes hundreds, or even thousands, of these missing individuals.
As a long-time advocate of encouraging plan sponsors to stay on top of bad addresses, I have always thought that the DOL and IRS would catch on to the fact that it is quite difficult for most participants to remain “missing” for long, given the advent of private locator services, whose job it is to, well, locate people!
And indeed, they have caught on.
The DOL is targeting Defined Benefit (DB) plans after discovering in audits that a number of plan sponsors had done a poor job of locating participants to whom the plan owed money. And, more recently, the IRS provided relief from what would normally be serious required minimum distribution (RMD) failures, if plan sponsors simply took some common sense steps to track down missing participants who failed to take RMDs.
There are a myriad of ways to locate participants, and a good recordkeeper should take advantage of at least some of these methods (be sure to check in with your plan’s recordkeeper to see what steps they are taking). The IRS guidance outlines a number of methods that will qualify plans for RMD relief if participants are not located after utilizing these methods:
- Search plan and related plan (e.g., other benefit records), sponsor (e.g., employment records), and publicly available records or directories (yup, the white pages still exist, among other records) for alternative contact information (just Google “How can I find someone’s address?” for details)
- Use a commercial locator service, a credit reporting agency, or a proprietary internet search tool for locating individuals
- Attempt contact via United States Postal Service (USPS) certified mail to the last known mailing address and through appropriate means for any address or contact information (including email addresses and telephone numbers). (Note: the DOL found this latter method to be surprisingly effective in their audits.)
So what are you waiting for? Find those missing participants today!
Note: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.
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