Locating Missing Participants in Qualified Retirement Plans

Summary

This practice note addresses the steps that plan sponsors and fiduciaries must take to locate and notify missing participants in qualified defined contribution and qualified defined benefit plans regarding benefits that are due to them under the plan. Plan administrators are obligated under the Employee Retirement Income Security Act (ERISA) to conduct a diligent search to locate missing participants and beneficiaries. Losing track of participants and beneficiaries poses a problem for plan administrators in active plans when a distribution is required and in terminated plans since the plan administrator must liquidate the benefit trust. The Pension Benefit Guaranty Corporation (PBGC) opened its missing participant program to terminating defined contribution plans and other previously excluded defined benefit plans in 2018. This practice note summarizes Department of Labor (DOL) and IRS guidance regarding missing participants, provides an overview of the revised PBGC program, and offers ...