Do you have a Lost and Found folder on your desk? Whether it be a personal request or a business necessity, finding missing persons is just one of the many services that we provide to our clients. For this newsletter, I would like to concentrate on business necessity. Just when does it become a business necessity to find a missing former employee?
We are often called upon to help Defined Contribution Plan Fiduciaries find retirees or former employees who still have money in a current or terminating plan. With terminating plans, the IRS has specific requirements with regards to finding missing plan participants or beneficiaries before declaring them “missing”.
The DOL issued a new Field Assistance Bulletin 2014-01. This new bulletin is a long overdue release and replaces the Field Assistance Bulletin 2004-02.
>> For more information, click to follow this link: https://www.dol.gov/ebsa/regs/fab2014-1.html.
“Before making a distribution, the plan administrator has a responsibility to contact the plan’s participants for directions on how to distribute their account balances. This requirement extends to all participants, regardless of their length of service or the size of their account balances. Sometimes, however, participants fail to respond to the notices (or mail sent to their addresses is returned), creating a practical dilemma for the plan administrator who has a fiduciary obligation to search for missing participants and distribute their benefits. The Bulletin’s aim is to help fiduciaries properly discharge their obligations to these missing participants.” DOL FAB 2014-02
In general, the Field Assistance Bulletin requires that before ending a search for a missing participant, the plan administrator must use all of the following:
- Send plan notices by certified mail to the last known address.
- Check all related plan materials and plan sponsor records for information on participant’s/beneficiarie's contact information.
- Try to contact the designated beneficiary.
- Use other options such as public record databases, obituaries, professional locator services, and/or credit reporting agencies.
If you have exhausted the first two steps and gotten nowhere, CIC can help with the last two steps. Sometimes locating a beneficiary can be as difficult as locating the missing plan participant. The “other options” suggested in number 4, can be very time consuming for busy HR professionals and plan sponsors so why not ask CIC to help? We have the resources and the experience to bring you quick and accurate results.
Carolyn Klemett is the coordinator of our Pre-employment Screening Services at Corporate Intelligence Consultants. For more information about this article on Missing Persons, please contact our offices at 1.800.573.2201 / 419.874.2201.