DOL issues missing participant guidance

The Department of Labor recently issued informal “best practices” guidance designed to help employers locate missing retirement plan participants to ensure they receive their promised benefits.

Locating missing retirement plan participants has long been a DOL priority, and is often the focus of plan audits. In issuing the guidance, the DOL noted its nationwide compliance initiative in this area and encouraged employers to implement effective policies and procedures to locate missing participants and beneficiaries. The guidance focused on the areas described below.

Maintaining accurate census information. The DOL explained the importance of ensuring that plan records are complete and current, and offered specific practices that included:

• Including participant contact information change requests in plan communications with reminders to advise the plan of any changes in contact information
• Flagging undeliverable mail and uncashed checks for follow-up
• Providing prompts for participants to confirm contact information on the plan’s website

Implementing effective communication strategies. The DOL noted several effective communication strategies, including:

• Communicating information about how employees can roll over prior employer and/or IRA benefits to the plan
• Encouraging contact through the plan’s website and toll-free phone numbers
• Using plain language in plan communications

Missing participant searches. If a participant cannot be located, the DOL provided the following tips to locate them:

• Using free online search engines and public record databases
• Attempting contact through U.S. certified mail sent to the last known address
• Attempting contact by other means, such as email addresses and phone numbers

Union Bank & Trust expects the DOL and/or IRS to issue additional missing participant guidance later this year or early next year. After reviewing the guidance, UBT will provide recommendations to employers on improving their procedures for locating missing participants.

If you have any questions about missing participants, please contact your UBT Relationship Manager.