Locating Missing Plan Participants

Dealing with missing participants can create a very serious operational defect if the proper procedures are not followed.  Both the IRS and DOL have specific procedures, as outlined in the resource below. Missing participants and beneficiaries have the same rights as active participants in a qualified ERISA plan.  Not documenting and attempting to follow the guidelines for the distribution of the following notices and disclosures can create an operational and fiduciary breach of duty by the named plan administrator, the plan sponsor.

Here is a listing of the notices and disclosures:

• Summary Annual Report
• Annual 404(a)(5) disclosure
• Annual Qualified Default Investment notice (if applicable)
• Fund change notice
• Blackout notice if the plan is beginning a conversion

This list may not be exhaustive, depending on the specific plan features.